Procurement, Suspension and Debarment (Repeat Finding 2023-009)
U.S. Department of Education/Passed Through Opportunity 180
Assistance Listing Number 84.282B – Charter Schools Program (CSP) – Grants for the
Opening of New Charter Schools
Award Number S282A200009-20A
Subgrantee Number CSP-2021-08655
Award Date – 4/1/21 to 8/31/23
Criteria – Management is responsible for implementing internal controls related to
Procurement, Suspension and Debarment, as required by the Uniform Guidance.
Condition – Evidence of review and approval of the bids/quotes obtained and of the verification
that the vendor was not suspended or debarred, prior to entering into a transaction with the
vendor, could not be provided for one vendor tested.
Questioned Costs – None
Context/Sampling – A non-statistical sample of one vendor out of four was selected for testing.
Cause – The School lacked sufficient internal controls to ensure that the review and approval
of bids/quotes and the verification that the vendor was not suspended or debarred occurred
and was documented prior to the expenditure.
Effect or Potential Effect – There is a risk that the School could enter into a transaction with a
vendor without proper approval, or with a vendor who is suspended or debarred.
Recommendation – We recommend the School thoroughly document the review and approval
process for all procurements to ensure compliance with Uniform Guidance. Additionally, we
recommend maintaining records that confirm vendors have been verified as not being
suspended or debarred prior to engaging in any transactions. The School can further include
a clause in vendor contracts or obtain a certification from vendors to this effect.
Views of Responsible Officials and Planned Corrective Actions – These findings were for
purchases prior to the new School principal coming on board. Upon hiring in April 2024, the new
principal was fully trained in School internal control policies. In addition, on July 1, 2024, a
process was put in place to maintain evidence of verification of suspension and debarment with
SAM.gov for all required vendors.
Allowable Costs/Cost Principles
U.S. Department of Agriculture/Passed Through State of Nevada Department of Agriculture
ALN 10.553, 10.555 – Child Nutrition Cluster
Award Date – 7/1/2023–6/30/2024
Criteria – Management is responsible for implementing internal controls related to Allowable
Costs and Cost Principles, as required by the Uniform Guidance.
Condition – Evidence of review and approval prior to the payment could not be provided for
one of the payroll expenditures tested.
Questioned Costs – None
Context/Sampling – A non-statistical sample of four payroll expenditures out of 24 payroll
expenditures was selected for testing.
Cause – The School lacked sufficient internal controls to ensure that the review and approval
of costs were documented prior to payment of the expenditure.
Effect or Potential Effect – There is a risk that unallowable costs may be charged to the
program without being detected by the School.
Recommendation – We recommend that the School document review and approval of all
expenditures prior to expenditure to ensure compliance with the Uniform Guidance.
Views of Responsible Officials and Planned Corrective Actions – A process was put in place
in January 2024 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.
Allowable Costs/Cost Principles
U.S. Department of Agriculture/Passed Through State of Nevada Department of Agriculture
ALN 10.553, 10.555 – Child Nutrition Cluster
Award Date – 7/1/2023–6/30/2024
Criteria – Management is responsible for implementing internal controls related to Allowable
Costs and Cost Principles, as required by the Uniform Guidance.
Condition – Evidence of review and approval prior to the payment could not be provided for
one of the payroll expenditures tested.
Questioned Costs – None
Context/Sampling – A non-statistical sample of four payroll expenditures out of 24 payroll
expenditures was selected for testing.
Cause – The School lacked sufficient internal controls to ensure that the review and approval
of costs were documented prior to payment of the expenditure.
Effect or Potential Effect – There is a risk that unallowable costs may be charged to the
program without being detected by the School.
Recommendation – We recommend that the School document review and approval of all
expenditures prior to expenditure to ensure compliance with the Uniform Guidance.
Views of Responsible Officials and Planned Corrective Actions – A process was put in place
in January 2024 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 Treasury/Passed Through State of Nevada Department of Education and
Nevada State Public Charter School Authority (SPCSA)
ALN 21.027 – Coronavirus State and Local Fiscal Recovery Funds – AB495 (COVID-19)
Award Date – 7/1/2022–12/31/2024
Criteria – Management is responsible for implementing internal controls related to Activities
Allowed or Unallowed and Allowable Costs and Cost Principles, as required by the Uniform
Guidance.
Condition – Evidence of review and approval prior to the payment could not be provided for
two of the nonpayroll expenditures tested.
Questioned Costs – None
Context/Sampling – A non-statistical sample of four nonpayroll expenditures out of 23
nonpayroll expenditures was selected for testing.
Cause – The School lacked sufficient internal controls to ensure that the review and approval
of costs were documented prior to payment of the expenditure.
Effect or Potential Effect – There is a risk that unallowable costs may be charged to the
program without being detected by the School.
Recommendation – We recommend that the School document review and approval of all
expenditures prior to expenditure to ensure compliance with the Uniform Guidance.
Views of Responsible Officials and Planned Corrective Actions – These findings were for
purchases prior to the School’s new principal coming on board. Upon hiring in April 2024, the
new principal was fully trained in the School’s internal control policies.
Procurement, Suspension and Debarment (Repeat Finding 2023-009)
U.S. Department of Education/Passed Through Opportunity 180
Assistance Listing Number 84.282B – Charter Schools Program (CSP) – Grants for the
Opening of New Charter Schools
Award Number S282A200009-20A
Subgrantee Number CSP-2021-08655
Award Date – 4/1/21 to 8/31/23
Criteria – Management is responsible for implementing internal controls related to
Procurement, Suspension and Debarment, as required by the Uniform Guidance.
Condition – Evidence of review and approval of the bids/quotes obtained and of the verification
that the vendor was not suspended or debarred, prior to entering into a transaction with the
vendor, could not be provided for one vendor tested.
Questioned Costs – None
Context/Sampling – A non-statistical sample of one vendor out of four was selected for testing.
Cause – The School lacked sufficient internal controls to ensure that the review and approval
of bids/quotes and the verification that the vendor was not suspended or debarred occurred
and was documented prior to the expenditure.
Effect or Potential Effect – There is a risk that the School could enter into a transaction with a
vendor without proper approval, or with a vendor who is suspended or debarred.
Recommendation – We recommend the School thoroughly document the review and approval
process for all procurements to ensure compliance with Uniform Guidance. Additionally, we
recommend maintaining records that confirm vendors have been verified as not being
suspended or debarred prior to engaging in any transactions. The School can further include
a clause in vendor contracts or obtain a certification from vendors to this effect.
Views of Responsible Officials and Planned Corrective Actions – These findings were for
purchases prior to the new School principal coming on board. Upon hiring in April 2024, the new
principal was fully trained in School internal control policies. In addition, on July 1, 2024, a
process was put in place to maintain evidence of verification of suspension and debarment with
SAM.gov for all required vendors.
Allowable Costs/Cost Principles
U.S. Department of Agriculture/Passed Through State of Nevada Department of Agriculture
ALN 10.553, 10.555 – Child Nutrition Cluster
Award Date – 7/1/2023–6/30/2024
Criteria – Management is responsible for implementing internal controls related to Allowable
Costs and Cost Principles, as required by the Uniform Guidance.
Condition – Evidence of review and approval prior to the payment could not be provided for
one of the payroll expenditures tested.
Questioned Costs – None
Context/Sampling – A non-statistical sample of four payroll expenditures out of 24 payroll
expenditures was selected for testing.
Cause – The School lacked sufficient internal controls to ensure that the review and approval
of costs were documented prior to payment of the expenditure.
Effect or Potential Effect – There is a risk that unallowable costs may be charged to the
program without being detected by the School.
Recommendation – We recommend that the School document review and approval of all
expenditures prior to expenditure to ensure compliance with the Uniform Guidance.
Views of Responsible Officials and Planned Corrective Actions – A process was put in place
in January 2024 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.
Allowable Costs/Cost Principles
U.S. Department of Agriculture/Passed Through State of Nevada Department of Agriculture
ALN 10.553, 10.555 – Child Nutrition Cluster
Award Date – 7/1/2023–6/30/2024
Criteria – Management is responsible for implementing internal controls related to Allowable
Costs and Cost Principles, as required by the Uniform Guidance.
Condition – Evidence of review and approval prior to the payment could not be provided for
one of the payroll expenditures tested.
Questioned Costs – None
Context/Sampling – A non-statistical sample of four payroll expenditures out of 24 payroll
expenditures was selected for testing.
Cause – The School lacked sufficient internal controls to ensure that the review and approval
of costs were documented prior to payment of the expenditure.
Effect or Potential Effect – There is a risk that unallowable costs may be charged to the
program without being detected by the School.
Recommendation – We recommend that the School document review and approval of all
expenditures prior to expenditure to ensure compliance with the Uniform Guidance.
Views of Responsible Officials and Planned Corrective Actions – A process was put in place
in January 2024 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 Treasury/Passed Through State of Nevada Department of Education and
Nevada State Public Charter School Authority (SPCSA)
ALN 21.027 – Coronavirus State and Local Fiscal Recovery Funds – AB495 (COVID-19)
Award Date – 7/1/2022–12/31/2024
Criteria – Management is responsible for implementing internal controls related to Activities
Allowed or Unallowed and Allowable Costs and Cost Principles, as required by the Uniform
Guidance.
Condition – Evidence of review and approval prior to the payment could not be provided for
two of the nonpayroll expenditures tested.
Questioned Costs – None
Context/Sampling – A non-statistical sample of four nonpayroll expenditures out of 23
nonpayroll expenditures was selected for testing.
Cause – The School lacked sufficient internal controls to ensure that the review and approval
of costs were documented prior to payment of the expenditure.
Effect or Potential Effect – There is a risk that unallowable costs may be charged to the
program without being detected by the School.
Recommendation – We recommend that the School document review and approval of all
expenditures prior to expenditure to ensure compliance with the Uniform Guidance.
Views of Responsible Officials and Planned Corrective Actions – These findings were for
purchases prior to the School’s new principal coming on board. Upon hiring in April 2024, the
new principal was fully trained in the School’s internal control policies.