Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Repeat Finding 2022-010)
U.S. Department of Education / Passed-through Opportunity 180
Federal Assistance Listing Number 84.282B– Charter Schools (CSP) Award Number S282A200009-20A, Subgrantee Number CSP-2021-08655, Award Date 4/1/21-8/31/23
Criteria – Management is responsible for internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles in accordance with the Uniform Guidance.
Condition – Eight expenditures tested did not have evidence of review and approval.
Questioned Costs - None
Context/Sampling – A non-statistical sample of eight expenditures out of 50 expenditures was selected for testing. We also tested the corresponding request for reimbursement of allowable cost submission for each expenditure tested.
Cause – The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented.
Effect or potential effect – Unallowable costs may be charged to the program and submitted for reimbursement and not detected by the School.
Recommendation – We recommend that the School document review and approval of all expenditures to ensure compliance with the Uniform Guidance.
Views of responsible officials and planned corrective actions – A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
U.S. Department of Education / Passed Through Nevada Department of Education and State of Neveda State Public Charter School Authority (SPCSA)
Federal Assistance Listing Numbers 84.425C, 84.425D, and 84.425U – COVID-19 - Education Stabilization Fund
Pass-Through Entity Identifying Number 22-748-110000
84.425U
Award Number S425U200018, Subgrantee Number T27044315, Award Date 7/1/21-9/30/24
84.425D, 84.425C
Award Number S425D200018, S424C210033, Subgrantee Number T27044315, Award Date 12/29/21-9/30/23
Criteria – Management is responsible for internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles in accordance with the Uniform Guidance.
Condition – 12 expenditures tested did not have evidence of review and approval.
Questioned Costs: None
Context/Sampling – A non-statistical sample of 22 expenditures out of 141 expenditures was selected for testing. We also tested the corresponding cost submission for each expenditure tested.
Cause – The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented.
Effect or potential effect – Unallowable costs may be charged to the program and submitted for reimbursement and not detected by the School.
Recommendation – We recommend that the School document review and approval of all expenditures to ensure compliance with the Uniform Guidance.
Views of responsible officials and planned corrective actions – A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
U.S. Department of Education / Passed Through Nevada Department of Education and State of Neveda State Public Charter School Authority (SPCSA)
Federal Assistance Listing Numbers 84.425C, 84.425D, and 84.425U – COVID-19 - Education Stabilization Fund
Pass-Through Entity Identifying Number 22-748-110000
84.425U
Award Number S425U200018, Subgrantee Number T27044315, Award Date 7/1/21-9/30/24
84.425D, 84.425C
Award Number S425D200018, S424C210033, Subgrantee Number T27044315, Award Date 12/29/21-9/30/23
Criteria – Management is responsible for internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles in accordance with the Uniform Guidance.
Condition – 12 expenditures tested did not have evidence of review and approval.
Questioned Costs: None
Context/Sampling – A non-statistical sample of 22 expenditures out of 141 expenditures was selected for testing. We also tested the corresponding cost submission for each expenditure tested.
Cause – The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented.
Effect or potential effect – Unallowable costs may be charged to the program and submitted for reimbursement and not detected by the School.
Recommendation – We recommend that the School document review and approval of all expenditures to ensure compliance with the Uniform Guidance.
Views of responsible officials and planned corrective actions – A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
U.S. Department of Education / Passed Through Nevada Department of Education and State of Neveda State Public Charter School Authority (SPCSA)
Federal Assistance Listing Numbers 84.425C, 84.425D, and 84.425U – COVID-19 - Education Stabilization Fund
Pass-Through Entity Identifying Number 22-748-110000
84.425U
Award Number S425U200018, Subgrantee Number T27044315, Award Date 7/1/21-9/30/24
84.425D, 84.425C
Award Number S425D200018, S424C210033, Subgrantee Number T27044315, Award Date 12/29/21-9/30/23
Criteria – Management is responsible for internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles in accordance with the Uniform Guidance.
Condition – 12 expenditures tested did not have evidence of review and approval.
Questioned Costs: None
Context/Sampling – A non-statistical sample of 22 expenditures out of 141 expenditures was selected for testing. We also tested the corresponding cost submission for each expenditure tested.
Cause – The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented.
Effect or potential effect – Unallowable costs may be charged to the program and submitted for reimbursement and not detected by the School.
Recommendation – We recommend that the School document review and approval of all expenditures to ensure compliance with the Uniform Guidance.
Views of responsible officials and planned corrective actions – A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
U.S. Department of Education / Passed Through Nevada Department of Education and State of Neveda State Public Charter School Authority (SPCSA)
Federal Assistance Listing Numbers 84.425C, 84.425D, and 84.425U – COVID-19 - Education Stabilization Fund
Pass-Through Entity Identifying Number 22-748-110000
84.425U
Award Number S425U200018, Subgrantee Number T27044315, Award Date 7/1/21-9/30/24
84.425D, 84.425C
Award Number S425D200018, S424C210033, Subgrantee Number T27044315, Award Date 12/29/21-9/30/23
Criteria – Management is responsible for internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles in accordance with the Uniform Guidance.
Condition – 12 expenditures tested did not have evidence of review and approval.
Questioned Costs: None
Context/Sampling – A non-statistical sample of 22 expenditures out of 141 expenditures was selected for testing. We also tested the corresponding cost submission for each expenditure tested.
Cause – The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented.
Effect or potential effect – Unallowable costs may be charged to the program and submitted for reimbursement and not detected by the School.
Recommendation – We recommend that the School document review and approval of all expenditures to ensure compliance with the Uniform Guidance.
Views of responsible officials and planned corrective actions – A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
Reporting
U.S. Department of Education/Passed Through Nevada Department of Education
Federal Assistance Listing Numbers 84.425C and 84.425D – COVID-19 - Education Stabilization Fund
Pass-Through Entity Identifying Number 22-748-110000
84.425D, 84.425C - Award Number S425D200018, S424C210033, Subgrantee Number T27044315, Award Date 12/29/21-9/30/23
Criteria – Management is responsible for internal controls over compliance with Reporting in accordance with the Uniform Guidance.
Condition – The School did not report grant expenditures on the correct grant tab of the report to the Nevada Department of Education, there was no support maintained for the data that was submitted including FTEs, and there was no review of the report before it was submitted.
Questioned Costs: None
Context – The Nevada Department of Education (NDE) requires information to be reported by Local Education Agencies in order to complete the NDE’s annual ESSER Reporting.
Cause – The School did not have adequate internal controls to ensure that the data reported to the NDE was accurate, that the form was completed correctly, and that a review was performed prior to submission.
Effect or potential effect – Inaccurate data was reported to the grantor.
Recommendation – We recommend the School put in place controls over reporting required by the School’s grants to ensure complete and accurate reporting in accordance with the compliance requirement.
Views of responsible officials and planned corrective actions – Due to unexpected turnover a secondary review was not performed to verify the preparation of the ESSER reporting. To strengthen the oversight of financial management of the School, Academica Nevada, the School’s management company, filled all open positions and realigned staff responsibilities to reduce individual workloads and provide additional oversight and review. In addition, a financial controller has been added to ensure that secondary reviews occur on all required filings and reconciliations.
Reporting
U.S. Department of Education/Passed Through Nevada Department of Education
Federal Assistance Listing Numbers 84.425C and 84.425D – COVID-19 - Education Stabilization Fund
Pass-Through Entity Identifying Number 22-748-110000
84.425D, 84.425C - Award Number S425D200018, S424C210033, Subgrantee Number T27044315, Award Date 12/29/21-9/30/23
Criteria – Management is responsible for internal controls over compliance with Reporting in accordance with the Uniform Guidance.
Condition – The School did not report grant expenditures on the correct grant tab of the report to the Nevada Department of Education, there was no support maintained for the data that was submitted including FTEs, and there was no review of the report before it was submitted.
Questioned Costs: None
Context – The Nevada Department of Education (NDE) requires information to be reported by Local Education Agencies in order to complete the NDE’s annual ESSER Reporting.
Cause – The School did not have adequate internal controls to ensure that the data reported to the NDE was accurate, that the form was completed correctly, and that a review was performed prior to submission.
Effect or potential effect – Inaccurate data was reported to the grantor.
Recommendation – We recommend the School put in place controls over reporting required by the School’s grants to ensure complete and accurate reporting in accordance with the compliance requirement.
Views of responsible officials and planned corrective actions – Due to unexpected turnover a secondary review was not performed to verify the preparation of the ESSER reporting. To strengthen the oversight of financial management of the School, Academica Nevada, the School’s management company, filled all open positions and realigned staff responsibilities to reduce individual workloads and provide additional oversight and review. In addition, a financial controller has been added to ensure that secondary reviews occur on all required filings and reconciliations.
Procurement, Suspension and Debarment
U.S. Department of Education / Passed-through Opportunity 180
Federal Assistance Listing Number 84.282B– Charter Schools (CSP) Award Number S282A200009-20A, Subgrantee Number CSP-2021-08655, Award Date 4/1/21-8/31/23
Criteria – Management is responsible for internal controls over compliance with Procurement, Suspension and Debarment in accordance with the Uniform Guidance.
Condition – The School has policies and procedures which make reference and are in accordance with state regulation and state law, but have not been updated with sufficient clarity and detail to ensure compliance with federal law in accordance with the Uniform Guidance. Four vendors tested did not have evidence of review and approval of the bids/quotes obtained. One vendor tested did not have evidence of review and approval of the process of verifying suspension and debarment procedures.
Questioned Costs – None
Context/Sampling – A non-statistical sample of four vendors was selected for testing.
Cause – The School did not have adequate internal controls over compliance with Procurement, Suspension and Debarment in accordance with the Uniform Guidance.
Effect or potential effect – The School may follow its documented procurement policies and not identify non-compliance with federal procurement law in cases where federal procurement law is more restrictive. The School could select a vendor without proper approval. The School could enter into a transaction with a suspended or debarred vendor.
Recommendation – We recommend the School review its procurement policy and include federal procurement requirements with proper minimum and maximum thresholds and requirements of the type of bids/quotes and documentation required to meet federal compliance requirements. We recommend that the School document review and approval of all approvals and quotes/bids to ensure compliance with the Uniform Guidance. We recommend that the School maintain documentation that vendors have been verified to not be suspended or debarred before entering into a transaction with a vendor.
Views of responsible officials and planned corrective actions – Going forward, as part of the process of verifying suspension and debarment a screenshot will be saved as evidence of the process. Additionally, Academica Nevada, the School’s management company, is in the process of reviewing all existing policies and procedures to ensure clarity and compliance with federal and state standards.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Repeat Finding 2022-010)
U.S. Department of Education / Passed-through Opportunity 180
Federal Assistance Listing Number 84.282B– Charter Schools (CSP) Award Number S282A200009-20A, Subgrantee Number CSP-2021-08655, Award Date 4/1/21-8/31/23
Criteria – Management is responsible for internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles in accordance with the Uniform Guidance.
Condition – Eight expenditures tested did not have evidence of review and approval.
Questioned Costs - None
Context/Sampling – A non-statistical sample of eight expenditures out of 50 expenditures was selected for testing. We also tested the corresponding request for reimbursement of allowable cost submission for each expenditure tested.
Cause – The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented.
Effect or potential effect – Unallowable costs may be charged to the program and submitted for reimbursement and not detected by the School.
Recommendation – We recommend that the School document review and approval of all expenditures to ensure compliance with the Uniform Guidance.
Views of responsible officials and planned corrective actions – A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
U.S. Department of Education / Passed Through Nevada Department of Education and State of Neveda State Public Charter School Authority (SPCSA)
Federal Assistance Listing Numbers 84.425C, 84.425D, and 84.425U – COVID-19 - Education Stabilization Fund
Pass-Through Entity Identifying Number 22-748-110000
84.425U
Award Number S425U200018, Subgrantee Number T27044315, Award Date 7/1/21-9/30/24
84.425D, 84.425C
Award Number S425D200018, S424C210033, Subgrantee Number T27044315, Award Date 12/29/21-9/30/23
Criteria – Management is responsible for internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles in accordance with the Uniform Guidance.
Condition – 12 expenditures tested did not have evidence of review and approval.
Questioned Costs: None
Context/Sampling – A non-statistical sample of 22 expenditures out of 141 expenditures was selected for testing. We also tested the corresponding cost submission for each expenditure tested.
Cause – The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented.
Effect or potential effect – Unallowable costs may be charged to the program and submitted for reimbursement and not detected by the School.
Recommendation – We recommend that the School document review and approval of all expenditures to ensure compliance with the Uniform Guidance.
Views of responsible officials and planned corrective actions – A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
U.S. Department of Education / Passed Through Nevada Department of Education and State of Neveda State Public Charter School Authority (SPCSA)
Federal Assistance Listing Numbers 84.425C, 84.425D, and 84.425U – COVID-19 - Education Stabilization Fund
Pass-Through Entity Identifying Number 22-748-110000
84.425U
Award Number S425U200018, Subgrantee Number T27044315, Award Date 7/1/21-9/30/24
84.425D, 84.425C
Award Number S425D200018, S424C210033, Subgrantee Number T27044315, Award Date 12/29/21-9/30/23
Criteria – Management is responsible for internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles in accordance with the Uniform Guidance.
Condition – 12 expenditures tested did not have evidence of review and approval.
Questioned Costs: None
Context/Sampling – A non-statistical sample of 22 expenditures out of 141 expenditures was selected for testing. We also tested the corresponding cost submission for each expenditure tested.
Cause – The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented.
Effect or potential effect – Unallowable costs may be charged to the program and submitted for reimbursement and not detected by the School.
Recommendation – We recommend that the School document review and approval of all expenditures to ensure compliance with the Uniform Guidance.
Views of responsible officials and planned corrective actions – A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
U.S. Department of Education / Passed Through Nevada Department of Education and State of Neveda State Public Charter School Authority (SPCSA)
Federal Assistance Listing Numbers 84.425C, 84.425D, and 84.425U – COVID-19 - Education Stabilization Fund
Pass-Through Entity Identifying Number 22-748-110000
84.425U
Award Number S425U200018, Subgrantee Number T27044315, Award Date 7/1/21-9/30/24
84.425D, 84.425C
Award Number S425D200018, S424C210033, Subgrantee Number T27044315, Award Date 12/29/21-9/30/23
Criteria – Management is responsible for internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles in accordance with the Uniform Guidance.
Condition – 12 expenditures tested did not have evidence of review and approval.
Questioned Costs: None
Context/Sampling – A non-statistical sample of 22 expenditures out of 141 expenditures was selected for testing. We also tested the corresponding cost submission for each expenditure tested.
Cause – The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented.
Effect or potential effect – Unallowable costs may be charged to the program and submitted for reimbursement and not detected by the School.
Recommendation – We recommend that the School document review and approval of all expenditures to ensure compliance with the Uniform Guidance.
Views of responsible officials and planned corrective actions – A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
U.S. Department of Education / Passed Through Nevada Department of Education and State of Neveda State Public Charter School Authority (SPCSA)
Federal Assistance Listing Numbers 84.425C, 84.425D, and 84.425U – COVID-19 - Education Stabilization Fund
Pass-Through Entity Identifying Number 22-748-110000
84.425U
Award Number S425U200018, Subgrantee Number T27044315, Award Date 7/1/21-9/30/24
84.425D, 84.425C
Award Number S425D200018, S424C210033, Subgrantee Number T27044315, Award Date 12/29/21-9/30/23
Criteria – Management is responsible for internal controls over Activities Allowed or Unallowed and Allowable Costs/Cost Principles in accordance with the Uniform Guidance.
Condition – 12 expenditures tested did not have evidence of review and approval.
Questioned Costs: None
Context/Sampling – A non-statistical sample of 22 expenditures out of 141 expenditures was selected for testing. We also tested the corresponding cost submission for each expenditure tested.
Cause – The School did not have adequate internal controls to ensure review of costs charged to the program occurred and was documented.
Effect or potential effect – Unallowable costs may be charged to the program and submitted for reimbursement and not detected by the School.
Recommendation – We recommend that the School document review and approval of all expenditures to ensure compliance with the Uniform Guidance.
Views of responsible officials and planned corrective actions – A process was put in place in May 2023 to ensure that all principal approvals are documented in writing or electronic approval in the system which can be date stamped by the system. Payroll will not be run, nor grants submitted, until proper approval is received.
Reporting
U.S. Department of Education/Passed Through Nevada Department of Education
Federal Assistance Listing Numbers 84.425C and 84.425D – COVID-19 - Education Stabilization Fund
Pass-Through Entity Identifying Number 22-748-110000
84.425D, 84.425C - Award Number S425D200018, S424C210033, Subgrantee Number T27044315, Award Date 12/29/21-9/30/23
Criteria – Management is responsible for internal controls over compliance with Reporting in accordance with the Uniform Guidance.
Condition – The School did not report grant expenditures on the correct grant tab of the report to the Nevada Department of Education, there was no support maintained for the data that was submitted including FTEs, and there was no review of the report before it was submitted.
Questioned Costs: None
Context – The Nevada Department of Education (NDE) requires information to be reported by Local Education Agencies in order to complete the NDE’s annual ESSER Reporting.
Cause – The School did not have adequate internal controls to ensure that the data reported to the NDE was accurate, that the form was completed correctly, and that a review was performed prior to submission.
Effect or potential effect – Inaccurate data was reported to the grantor.
Recommendation – We recommend the School put in place controls over reporting required by the School’s grants to ensure complete and accurate reporting in accordance with the compliance requirement.
Views of responsible officials and planned corrective actions – Due to unexpected turnover a secondary review was not performed to verify the preparation of the ESSER reporting. To strengthen the oversight of financial management of the School, Academica Nevada, the School’s management company, filled all open positions and realigned staff responsibilities to reduce individual workloads and provide additional oversight and review. In addition, a financial controller has been added to ensure that secondary reviews occur on all required filings and reconciliations.
Reporting
U.S. Department of Education/Passed Through Nevada Department of Education
Federal Assistance Listing Numbers 84.425C and 84.425D – COVID-19 - Education Stabilization Fund
Pass-Through Entity Identifying Number 22-748-110000
84.425D, 84.425C - Award Number S425D200018, S424C210033, Subgrantee Number T27044315, Award Date 12/29/21-9/30/23
Criteria – Management is responsible for internal controls over compliance with Reporting in accordance with the Uniform Guidance.
Condition – The School did not report grant expenditures on the correct grant tab of the report to the Nevada Department of Education, there was no support maintained for the data that was submitted including FTEs, and there was no review of the report before it was submitted.
Questioned Costs: None
Context – The Nevada Department of Education (NDE) requires information to be reported by Local Education Agencies in order to complete the NDE’s annual ESSER Reporting.
Cause – The School did not have adequate internal controls to ensure that the data reported to the NDE was accurate, that the form was completed correctly, and that a review was performed prior to submission.
Effect or potential effect – Inaccurate data was reported to the grantor.
Recommendation – We recommend the School put in place controls over reporting required by the School’s grants to ensure complete and accurate reporting in accordance with the compliance requirement.
Views of responsible officials and planned corrective actions – Due to unexpected turnover a secondary review was not performed to verify the preparation of the ESSER reporting. To strengthen the oversight of financial management of the School, Academica Nevada, the School’s management company, filled all open positions and realigned staff responsibilities to reduce individual workloads and provide additional oversight and review. In addition, a financial controller has been added to ensure that secondary reviews occur on all required filings and reconciliations.
Procurement, Suspension and Debarment
U.S. Department of Education / Passed-through Opportunity 180
Federal Assistance Listing Number 84.282B– Charter Schools (CSP) Award Number S282A200009-20A, Subgrantee Number CSP-2021-08655, Award Date 4/1/21-8/31/23
Criteria – Management is responsible for internal controls over compliance with Procurement, Suspension and Debarment in accordance with the Uniform Guidance.
Condition – The School has policies and procedures which make reference and are in accordance with state regulation and state law, but have not been updated with sufficient clarity and detail to ensure compliance with federal law in accordance with the Uniform Guidance. Four vendors tested did not have evidence of review and approval of the bids/quotes obtained. One vendor tested did not have evidence of review and approval of the process of verifying suspension and debarment procedures.
Questioned Costs – None
Context/Sampling – A non-statistical sample of four vendors was selected for testing.
Cause – The School did not have adequate internal controls over compliance with Procurement, Suspension and Debarment in accordance with the Uniform Guidance.
Effect or potential effect – The School may follow its documented procurement policies and not identify non-compliance with federal procurement law in cases where federal procurement law is more restrictive. The School could select a vendor without proper approval. The School could enter into a transaction with a suspended or debarred vendor.
Recommendation – We recommend the School review its procurement policy and include federal procurement requirements with proper minimum and maximum thresholds and requirements of the type of bids/quotes and documentation required to meet federal compliance requirements. We recommend that the School document review and approval of all approvals and quotes/bids to ensure compliance with the Uniform Guidance. We recommend that the School maintain documentation that vendors have been verified to not be suspended or debarred before entering into a transaction with a vendor.
Views of responsible officials and planned corrective actions – Going forward, as part of the process of verifying suspension and debarment a screenshot will be saved as evidence of the process. Additionally, Academica Nevada, the School’s management company, is in the process of reviewing all existing policies and procedures to ensure clarity and compliance with federal and state standards.