Activities Allowed or Unallowed and Allowable Costs/Cost Principles
(Repeat Finding 2022-011)
U.S. Department of Education / Passed-through Opportunity 180
Federal Assistance Listing Number 84.282B – Charter Schools
Award Number S282A200009-20A, Subgrantee Number CSP-2021-56278, Award
Date April 1, 2021–August 31, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – 13 of the expenditures tested did not have evidence of review and
approval prior to the expenditure.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 26 expenditures out of 170
expenditures was selected for testing.
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 grant reimbursement requests submitted, until proper approval is
received.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
U.S. Department of Education/Passed-through the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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 the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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 the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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 the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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 the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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 the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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 the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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.
Procurement, Suspension and Debarment (Repeat Finding 2022-012)
U.S. Department of Education/Passed-through Opportunity 180
Federal Assistance Listing Number 84.282B – Charter Schools
Award Number S282A200009-20A, Subgrantee Number CSP-2021-56278,
Award Date April 1, 2021–August 31, 2023
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 that make reference to state
regulation and law, but the policies have not been updated with sufficient clarity and
detail to ensure compliance with federal law and standards. Nine vendors tested did
not have evidence of review and approval of the bids/quotes obtained. Eight vendors
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 10 vendors was selected for testing.
Cause – The School did not have adequate internal controls to review its policy and
procedures to include federal procurement requirements.
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 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 the School document review
and approval of all approvals and quotes/bids to ensure compliance with the Uniform
Guidance. We recommend 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.
Reporting
U.S. Department of Education/Passed Through Nevada Department of Education
Federal Assistance Listing Number 84.425C and 84.425D – COVID-19 –
Education Stabilization Fund
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Reporting in accordance with the Uniform Guidance.
Condition – The School did report the correct amount of grant expenditures 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/Sampling – 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 of the report was performed prior to submission.
Effect or Potential Effect – Inaccurate data was provided 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
Maintenance of Effort 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 Number 84.425C and 84.425D – COVID-19 –
Education Stabilization Fund
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Reporting in accordance with the Uniform Guidance.
Condition – The School did report the correct amount of grant expenditures 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/Sampling – 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 of the report was performed prior to submission.
Effect or Potential Effect – Inaccurate data was provided 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
Maintenance of Effort 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.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
(Repeat Finding 2022-011)
U.S. Department of Education / Passed-through Opportunity 180
Federal Assistance Listing Number 84.282B – Charter Schools
Award Number S282A200009-20A, Subgrantee Number CSP-2021-56278, Award
Date April 1, 2021–August 31, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – 13 of the expenditures tested did not have evidence of review and
approval prior to the expenditure.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 26 expenditures out of 170
expenditures was selected for testing.
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 grant reimbursement requests submitted, until proper approval is
received.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles
U.S. Department of Education/Passed-through the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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 the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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 the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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 the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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 the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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 the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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 the
State of Nevada Public Charter School Authority
Federal Assistance Listing Numbers 84.425, 84.425C, 84.425D, 84.425U –
Education Stabilization Fund
ARP ESSER, APP-01634-Z4J7-A1, Award Date July 1, 2021–September 30, 2024
ARP ESSER Final One-Third Allocation, Award Date
July 1, 2022–September 30, 2024
ARP ESSER Summer & Afterschool, Award Date
July 1, 2022–September 30, 2024
CRRSA ESSER II, APP-01393-L1S1-A1, Award Date
January 15, 2021–September 30, 2023
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Activities Allowed/or Unallowed and Allowable Costs/Cost Principles in accordance
with the Uniform Guidance.
Condition – Five expenditures tested did not have evidence of review and approval
prior to the expenditure. One submission for reimbursement did not have evidence of
review and approval prior to submission.
Questioned Costs – None
Context/Sampling – A non-statistical sample of 40 expenditures out of 358
expenditures was selected for testing. We also tested the submission for reimbursement
related to 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 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.
Procurement, Suspension and Debarment (Repeat Finding 2022-012)
U.S. Department of Education/Passed-through Opportunity 180
Federal Assistance Listing Number 84.282B – Charter Schools
Award Number S282A200009-20A, Subgrantee Number CSP-2021-56278,
Award Date April 1, 2021–August 31, 2023
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 that make reference to state
regulation and law, but the policies have not been updated with sufficient clarity and
detail to ensure compliance with federal law and standards. Nine vendors tested did
not have evidence of review and approval of the bids/quotes obtained. Eight vendors
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 10 vendors was selected for testing.
Cause – The School did not have adequate internal controls to review its policy and
procedures to include federal procurement requirements.
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 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 the School document review
and approval of all approvals and quotes/bids to ensure compliance with the Uniform
Guidance. We recommend 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.
Reporting
U.S. Department of Education/Passed Through Nevada Department of Education
Federal Assistance Listing Number 84.425C and 84.425D – COVID-19 –
Education Stabilization Fund
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Reporting in accordance with the Uniform Guidance.
Condition – The School did report the correct amount of grant expenditures 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/Sampling – 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 of the report was performed prior to submission.
Effect or Potential Effect – Inaccurate data was provided 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
Maintenance of Effort 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 Number 84.425C and 84.425D – COVID-19 –
Education Stabilization Fund
Project Number 22-748-106000, Award Date May 25, 2022–September 30, 2023
Criteria – Management is responsible for internal controls over compliance with
Reporting in accordance with the Uniform Guidance.
Condition – The School did report the correct amount of grant expenditures 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/Sampling – 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 of the report was performed prior to submission.
Effect or Potential Effect – Inaccurate data was provided 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
Maintenance of Effort 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.