Audit 366218

U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 10.553, 10.555, 10.556, 10.559, and 10.582 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine out of a population of 61 applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 9 $1,772,633 Not Reported 9 $1,772,633 Not Timely 9 $1,772,633 Obligation Incorrect 9 $1,772,633 Missing Key Elements 9 $1,772,633 Repeat Finding from Prior Year: Yes – prior year finding 2022-019. Recommendation: We recommend NDA implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Department of Agriculture agrees with this finding.

U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 10.553, 10.555, 10.556, 10.559, and 10.582 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine out of a population of 61 applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 9 $1,772,633 Not Reported 9 $1,772,633 Not Timely 9 $1,772,633 Obligation Incorrect 9 $1,772,633 Missing Key Elements 9 $1,772,633 Repeat Finding from Prior Year: Yes – prior year finding 2022-019. Recommendation: We recommend NDA implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Department of Agriculture agrees with this finding.

U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 10.553, 10.555, 10.556, 10.559, and 10.582 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine out of a population of 61 applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 9 $1,772,633 Not Reported 9 $1,772,633 Not Timely 9 $1,772,633 Obligation Incorrect 9 $1,772,633 Missing Key Elements 9 $1,772,633 Repeat Finding from Prior Year: Yes – prior year finding 2022-019. Recommendation: We recommend NDA implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Department of Agriculture agrees with this finding.

U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 10.553, 10.555, 10.556, 10.559, and 10.582 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine out of a population of 61 applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 9 $1,772,633 Not Reported 9 $1,772,633 Not Timely 9 $1,772,633 Obligation Incorrect 9 $1,772,633 Missing Key Elements 9 $1,772,633 Repeat Finding from Prior Year: Yes – prior year finding 2022-019. Recommendation: We recommend NDA implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Department of Agriculture agrees with this finding.

U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 10.553, 10.555, 10.556, 10.559, and 10.582 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine out of a population of 61 applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 9 $1,772,633 Not Reported 9 $1,772,633 Not Timely 9 $1,772,633 Obligation Incorrect 9 $1,772,633 Missing Key Elements 9 $1,772,633 Repeat Finding from Prior Year: Yes – prior year finding 2022-019. Recommendation: We recommend NDA implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Department of Agriculture agrees with this finding.

U.S. Department of Labor Unemployment Insurance, 17.225 COVID-19 Unemployment Insurance, 17.225 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award 23A55UI039335-01 included under assistance listing 17.225 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 underlying accounting information or performance records, and are fairly presented in accordance with governing requirements. The Nevada Department of Employment, Training and Rehabilitation (DETR) must submit the ETA 9130 Financial Status Report, UI Programs. Condition: Amounts reported on the ETA 9130 did not agree to underlying financial records. Cause: DETR did not have adequate internal controls to ensure amounts reported agreed to underlying financial records. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of 12 out of a population of 70 ETA 9130 reports was selected for testing. An error was noted on one of the reports tested as follows: Quarter Ended March 31, 2023 (UI39335OB0) Amount Reported Amount per General Ledger Federal Share of Expenditures $11,551,039 $10,567,850 Repeat Finding from Prior Year: No Recommendation: We recommend DETR enhance the internal controls to ensure amounts reported agree to underlying records. Views of Responsible Officials: The Nevada Department of Employment, Training and Rehabilitation agrees with this finding.

U.S. Department of Labor Unemployment Insurance, 17.225 COVID-19 Unemployment Insurance, 17.225 Special Tests and Provisions – UI Benefit Payments Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards with benefit payments, which are UI EUC, UI Trust Fund, UI Extended Benefits, UI FPUC, UI PEUC, and UIPL 18-20, included under assistance listing 17.225 on the Schedule of Expenditures of Federal Awards. Criteria: State Workforce Agencies are required by 20 CFR section 602.11(d) to operate and maintain a quality control system. The Benefits Accuracy Measurement (BAM) program is the quality control system designed to assess the accuracy of UI benefit payments and denied claims. The State’s BAM unit is required to draw a weekly sample of payments and denied claims, complete prompt and indepth investigations to determine the degree of accuracy in the administration of the program. The requirements are promulgated in the ET Handbook No. 395 (Handbook). Department of Labor ET Handbook 395, Part VI, Section 11 Completion of Cases and Timely Data Entry states that a minimum of 70% of cases must be completed within 60 days of the week ending date of the batch, and 95% of cases must be completed within 90 days of the week ending batch; and a minimum of 98% of cases for the year must be completed within 120 days of the ending date of the calendar year. Condition: The minimum standards of BAM case completion were not met. Cause: The Nevada Department of Employment, Training and Rehabilitation (DETR) did not have adequate internal controls to ensure BAM timeliness requirements were met. Effect: A BAM investigation may not detect an error timely. Questioned Costs: None Context/Sampling: The following is a summary of the BAM case completion percentages that were not met for calendar year 2022: 90-day completion requirements Paid claims require 95% completion, actual was 85.19%. Denied separation claims require 85% completion, actual was 84.21%. 120-day completion requirements Paid claims require 98% completion, actual was 93.46%. Denied separation claims require 98%, actual was 92.76%. Denied non-separation claims require 98%, actual was 93.63%. Repeat Finding from Prior Year: Yes – prior year finding 2022-021. Recommendation: We recommend DETR enhance internal controls to ensure BAM timeliness requirements are met. Views of Responsible Officials: The Nevada Department of Employment, Training and Rehabilitation agrees with this finding.

U.S. Department of Labor Unemployment Insurance, 17.225 COVID-19 Unemployment Insurance, 17.225 Special Tests and Provisions – UI Benefit Payments Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards with benefit payments, which are UI EUC, UI Trust Fund, UI Extended Benefits, UI FPUC, UI PEUC, and UIPL 18-20, included under assistance listing 17.225 on the Schedule of Expenditures of Federal Awards. Criteria: State Workforce Agencies are required by 20 CFR section 602.11(d) to operate and maintain a quality control system. The Benefits Accuracy Measurement (BAM) program is the quality control system designed to assess the accuracy of UI benefit payments and denied claims. The State’s BAM unit is required to draw a weekly sample of payments and denied claims, complete prompt and indepth investigations to determine the degree of accuracy in the administration of the program. The requirements are promulgated in the ET Handbook No. 395 (Handbook). Department of Labor ET Handbook 395, Part VI, Section 11 Completion of Cases and Timely Data Entry states that a minimum of 70% of cases must be completed within 60 days of the week ending date of the batch, and 95% of cases must be completed within 90 days of the week ending batch; and a minimum of 98% of cases for the year must be completed within 120 days of the ending date of the calendar year. Condition: The minimum standards of BAM case completion were not met. Cause: The Nevada Department of Employment, Training and Rehabilitation (DETR) did not have adequate internal controls to ensure BAM timeliness requirements were met. Effect: A BAM investigation may not detect an error timely. Questioned Costs: None Context/Sampling: The following is a summary of the BAM case completion percentages that were not met for calendar year 2022: 90-day completion requirements Paid claims require 95% completion, actual was 85.19%. Denied separation claims require 85% completion, actual was 84.21%. 120-day completion requirements Paid claims require 98% completion, actual was 93.46%. Denied separation claims require 98%, actual was 92.76%. Denied non-separation claims require 98%, actual was 93.63%. Repeat Finding from Prior Year: Yes – prior year finding 2022-021. Recommendation: We recommend DETR enhance internal controls to ensure BAM timeliness requirements are met. Views of Responsible Officials: The Nevada Department of Employment, Training and Rehabilitation agrees with this finding.

U.S. Department of Transportation Highway Planning and Construction, 20.205 COVID-19 Highway Planning and Construction, 20.205 Special Tests and Provisions – Value Engineering Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 20.205 on the Schedule of Expenditures of Federal Awards. Criteria: The Nevada Department of Transportation (NDOT) is required to establish a value engineering (VE) program and ensure that a VE analysis is performed on all applicable projects. The program should include procedures to approve or reject recommendations and for monitoring to ensure that resulting, approved recommendations are incorporated into the plans, specifications, and estimate. Applicable projects are (a) projects located on the National Highway System (NHS) with an estimated total project cost of $50 million or more that utilize federal high program funding; (b) bridge projects located on the NHS with an estimated total cost of $40 million or more that utilize federal highway program funding; and (c) any other projects that the FHWA determines to be appropriate. Critical elements of VE programs include identification of a state VE coordinator; establishment of a VE policy, and documented VE procedures, including requirements to identify applicable projects, verify required VE analyses are completed on State DOT and subrecipient projects; and monitor, assess, and report on the performance of the VE program as required by 23 CFR part 627. NDOT’s VE policy states that NDOT will conduct VE analysis for all NHS projects costing at least $25 million, to consider VE for projects exceeding $10 million, and to consider VE for all projects, processes, procedures, and standards submitted by district or division heads. Emphasis on value analysis for projects exceeding $10 million does not eliminate consideration of smaller projects that may benefit from value analysis. Condition: A VE analysis was not performed when required by NDOT policy. Cause: The Nevada Department of Transportation (NDOT) did not have adequate internal controls to ensure their VE policy was followed. Effect: A project did not benefit from a value analysis. Questioned Costs: None Context/Sampling: A nonstatistical sample of two projects from a population of seven was selected for testing. One project had an estimated cost of $41 million to $49 million and a VE analysis was performed. The other project had an estimated cost of $34 million to $41 million and a VE analysis was not performed in accordance with NDOT policy. Repeat Finding from Prior Year: No Recommendation: We recommend NDOT enhance internal controls to ensure the VE policy is followed or, if necessary, the VE policy is updated as needed and provided that it complies with federal requirements. Views of Responsible Officials: The Nevada Department of Transportation agrees with this finding.

U.S. Department of Transportation Highway Planning and Construction, 20.205 COVID-19 Highway Planning and Construction, 20.205 Special Tests and Provisions – Value Engineering Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 20.205 on the Schedule of Expenditures of Federal Awards. Criteria: The Nevada Department of Transportation (NDOT) is required to establish a value engineering (VE) program and ensure that a VE analysis is performed on all applicable projects. The program should include procedures to approve or reject recommendations and for monitoring to ensure that resulting, approved recommendations are incorporated into the plans, specifications, and estimate. Applicable projects are (a) projects located on the National Highway System (NHS) with an estimated total project cost of $50 million or more that utilize federal high program funding; (b) bridge projects located on the NHS with an estimated total cost of $40 million or more that utilize federal highway program funding; and (c) any other projects that the FHWA determines to be appropriate. Critical elements of VE programs include identification of a state VE coordinator; establishment of a VE policy, and documented VE procedures, including requirements to identify applicable projects, verify required VE analyses are completed on State DOT and subrecipient projects; and monitor, assess, and report on the performance of the VE program as required by 23 CFR part 627. NDOT’s VE policy states that NDOT will conduct VE analysis for all NHS projects costing at least $25 million, to consider VE for projects exceeding $10 million, and to consider VE for all projects, processes, procedures, and standards submitted by district or division heads. Emphasis on value analysis for projects exceeding $10 million does not eliminate consideration of smaller projects that may benefit from value analysis. Condition: A VE analysis was not performed when required by NDOT policy. Cause: The Nevada Department of Transportation (NDOT) did not have adequate internal controls to ensure their VE policy was followed. Effect: A project did not benefit from a value analysis. Questioned Costs: None Context/Sampling: A nonstatistical sample of two projects from a population of seven was selected for testing. One project had an estimated cost of $41 million to $49 million and a VE analysis was performed. The other project had an estimated cost of $34 million to $41 million and a VE analysis was not performed in accordance with NDOT policy. Repeat Finding from Prior Year: No Recommendation: We recommend NDOT enhance internal controls to ensure the VE policy is followed or, if necessary, the VE policy is updated as needed and provided that it complies with federal requirements. Views of Responsible Officials: The Nevada Department of Transportation agrees with this finding.

U.S. Department of Treasury COVID-19 Emergency Rental Assistance Program, 21.023 Reporting Material Weakness in Internal Control over Compliance and Material 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 (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The OMB Compliance Supplement provides that states are required to submit Quarterly Reports for Emergency Rental Assistance as amended by the Consolidated Appropriations Act of 2021 (ERA1) and Emergency Rental Assistance from the American Rescue Plan Act (ERA2). Condition: Key information was not reported, supporting documentation for amounts that were reported was not maintained, and there was no segregation of duties in the preparation and review of the reports. Cause: The Nevada Housing Division (NHD) did not have internal controls to ensure reports were reviewed, support was maintained, and reports were complete and accurate prior to submission. Effect: Inaccurate and incomplete information was submitted to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of four Quarterly Reports out of a population of eight was selected for testing. The errors for submitted reports are noted as follows: ERA 1 report for the quarter ended September 30, 2022: • $18,096,873 was reported as amounts expended for administrative expenses and was not able to be traced to underlying supporting records. • Amounts expended and/or obligated for administrative expenses exceed 10% of the total allocation. • No amounts were reported for the total obligation and expenditures for housing stability services. As such the housing stability services ratio was not able to be determined. • No amounts were reported for number of households served at certain income levels. • There was no evidence of internal controls (segregation of duties). ERA 1 report for the quarter ended December 31, 2022: • No amounts were reported for administrative costs obligated and expended and award funds obligated or expended. As such the administrative costs ratio was not able to be determined. • No amounts were reported for the total obligation and expenditures for housing stability services. As such the housing stability services ratio was not able to be determined. • Number of households served at certain income levels was not able to be traced to underlying supporting records. • There was no evidence of internal controls (segregation of duties). ERA 2 report for the quarter ended September 30, 2022: • No amounts were reported for administrative costs obligated and expended and award funds obligated or expended. As such the administrative costs ratio was not able to be determined. • No amounts were reported for the total obligation and expenditures for housing stability services. As such the housing stability services ratio was not able to be determined. • No amounts were reported for number of households served at certain income levels. • There was no evidence of internal controls (segregation of duties). ERA 2 report for the quarter ended March 31, 2023: • No amounts were reported for administrative costs obligated and expended and award funds obligated or expended. As such the administrative costs ratio was not able to be determined. • No amounts were reported for the total obligation and expenditures for housing stability services. As such the housing stability services ratio was not able to be determined. • No amounts were reported for number of households served at certain income levels. • There was no evidence of internal controls (segregation of duties). Repeat Finding from Prior Year: Yes – prior year findings 2022-026 and 2022-027. Recommendation: We recommend NHD implement internal controls to ensure reports are reviewed, support is maintained, and reports are complete and accurate prior to submission. Views of Responsible Officials: The Nevada Housing Division agrees with this finding.

U.S. Department of Treasury COVID-19 Emergency Rental Assistance Program, 21.023 Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material 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, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: Pass-through entities ensure every subaward includes certain information at the time of the subaward and the assistance listing number is communicated at the time of disbursement to subrecipients. Pass-through entities evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the subrecipient monitoring must ensure that the subaward is used for authorized purposes. Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient takes timely corrective action on all audit findings, as applicable. Condition: Subawards did not contain all the required information, assistance listing numbers were not communicated at the time of disbursement, an evaluation of the subrecipients risk for noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed, adequate active monitoring procedures were not performed, and subrecipient audit reports were not reviewed. Cause: The Nevada Housing Division (NHD) did not have internal controls in place to ensure compliance with subrecipient monitoring requirements. Effect: Noncompliance at the subrecipient level may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of three subrecipients out of a population of four was selected for testing. All three subrecipients were not assessed for risk of noncompliance, award agreements were missing required terms and conditions for a subaward, and there was no evidence active monitoring or review of the audit reports was performed. A nonstatistical sample of four pass-through payments out of a population of 18 was selected for testing. All four pass-through payments tested did not have the assistance listing communicated at the time of disbursement. Repeat Finding from Prior Year: No Recommendation: We recommend NHD enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Nevada Housing Division agrees with this finding.

U.S. Department of Treasury COVID-19 Emergency Rental Assistance Program, 21.023 Special Tests and Provisions – ERA Funds Reallocation Material Weakness Internal Control over Compliance and Material 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 (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Pursuant to 15 USC 9058a(d), Treasury is required to reallocate “excess” ERA 1 award funds. Treasury’s objective in reallocations is to ensure ERA 1 award funds remain available to grantees in accordance with their jurisdictional needs and demonstrated capacity to deliver assistance while the ERA appropriations remain available. The Nevada Housing Division (NHD) was required to submit financial information to Treasury, which were used to calculate various reallocation expenditure ratios. Reallocation expenditure ratios determines whether the grantee is subject to involuntary reallocation due to an insufficient ratio and the amount of excess funds subject to recapture by Treasury. In addition, reallocation ratios were used to determine the eligibility to receive reallocated funds. Condition: NHD did not maintain documentation to support reallocation amounts submitted to Treasury in its application to receive reallocated funds. In addition, there was no segregation of duties in the preparation and review of amounts submitted. Cause: NHD did not have internal controls to ensure supporting documentation for amounts reported to the awarding agency was maintained. Effect: Amounts reported to the federal awarding agency for the reallocation expenditure ratios may be inaccurate, which may have impacted Treasury’s reallocation determination. Questioned Costs: None Context/Sampling: There was no sampling performed. All amounts reported with respect to reallocation were tested. No underlying documentation was available to review to validate any of the amounts reported. Repeat Finding from Prior Year: No Recommendation: We recommend NHD implement internal controls to ensure supporting documentation for amounts reported to the awarding agency is maintained. Views of Responsible Officials: The Nevada Housing Division disagrees with this finding.

U.S. Department of Treasury COVID-19 Homeowner Assistance Fund, 21.026 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 21.026 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) section 200.332 requires that: Pass-through entities ensure every subaward includes certain information at the time of the subaward and that the award’s assistance listing number is identified to the subrecipient at the time of disbursement. Pass-through entities evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Condition: Subawards and disbursements did not contain all the required information, an evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed. Cause: The Nevada Housing Division (NHD) did not have internal controls to ensure compliance with subrecipient monitoring requirements. Effect: Noncompliance at the subrecipient level may occur and not be detected. Questioned Costs: None Context/Sampling: The entire population of one subrecipient was selected for testing, which included one payment. The subaward was missing required information, a risk assessment was not performed, and the payment was missing the assistance listing number. Repeat Finding from Prior Year: Yes – prior year finding 2022-032. Recommendation: We recommend NHD implement internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Nevada Housing Division agrees with this finding.

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 Grant Award Number: Affects all grant awards included 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. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Certain applicable provisions described in Appendix II to Part 200 were not included in contracts as required. Procedures were not followed to verify if an entity was suspended or debarred before entering into a covered transaction. Cause: The Nevada State Purchasing Department (State Purchasing) did not have adequate internal controls to ensure contracts under federal awards contained all of the applicable provisions or to ensure procedures were followed to verify an entity was not suspended or debarred prior to entering into a covered transaction. Effect: Contractors may not be aware of required terms and conditions. A covered transaction may be entered into with an entity or subrecipient that is suspended or debarred. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 procurement transactions out of approximately 1,500 was selected for testing, including 19 contracts subject to Appendix II to Part 200 and to suspension and debarment requirements (transactions that are not within the revenue loss eligible use criteria). Ten out of 19 contracts subject to Appendix II to Part 200 were missing certain required contract provisions. One out of 19 vendors subject to suspension and debarment requirements were not verified for suspension and debarment prior to entering into a covered transaction. Repeat Finding from Prior Year: Yes – prior year finding 2022-034. Recommendation: We recommend State Purchasing enhance internal controls to ensure all contracts under federal awards contain the applicable provisions and procedures are followed to ensure entities are not suspended or debarred prior to entering into covered transactions. Views of Responsible Officials: The Nevada State Purchasing Department agrees with this finding.\

U.S. Department of Treasury COVID-19 Coronavirus State and Local Fiscal Recovery Fund, 21.027 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included 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. The Nevada Governor’s Finance Office (GFO) must submit quarterly Project and Expenditure Reports that contain COVID-19 related costs and obligations incurred during the covered period. Critical information includes: • Current period obligation • Cumulative obligation • Current period expenditure • Cumulative expenditure • Revenue Loss Calculation • Capital Expenditures Condition: Certain amounts included in the reports submitted did not agree to underlying support or underlying support for amounts reported were not maintained. Cause: GFO did not have adequate internal controls to ensure Project and Expenditure Reports were reconciled to underlying supporting documentation. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of two Project and Expenditure Reports from a population of four was selected for testing. Variances were noted as follows for cumulative impacts: Reporting Period Ended September 30, 2022: Amount Reported Amount Supported by Underlying Documentation Current Period Obligations $117,487,595 $96,899,741 Cumulative Obligations $693,688,130 $187,993,359 Reporting Period Ended March 31, 2023: Amount Reported Amount Supported by Underlying Documentation Current Period Obligations $28,208,617 $27,909,659 Cumulative Obligations $939,517,635 $443,459,939 Current Period Expenditures $25,911,692 $57,487,724 Cumulative Expenditures $540,583,461 $556,630,740 Repeat Finding from Prior Year: No Recommendation: We recommend the GFO enhance internal controls to ensure Project Expenditure Reports are reconciled to underlying supporting documentation. Views of Responsible Officials: The Nevada Governor’s Finance Office agrees with this finding.

U.S. Department of Treasury COVID-19 Coronavirus State and Local Fiscal Recovery Fund, 21.027 Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included 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) section 200.332 requires that: Pass-through entities ensure every subaward includes certain information at the time of the subaward and the assistance listing number is communicated at the time of disbursement to subrecipients. Pass-through entities evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient takes timely corrective action on all audit findings, as applicable. Condition: Subawards were not entered into, assistance listing numbers were not communicated at the time of disbursement, an evaluation of the subrecipients risk for noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed, and subrecipient audit reports were not reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following agencies: • Governor’s Finance Office • Department of Agriculture • Aging and Disability Services Division • Division of Public and Behavioral Health Effect: Noncompliance at the subrecipient level may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 30 subrecipients out of a population of 146 across all State agencies was selected for testing. A nonstatistical sample of 60 passthrough payments out of a population of approximately 2,200 was selected for testing. The following errors were noted by agency: Governor’s Finance Office We tested 7 subrecipients applicable to Governors Finance Office and noted a risk assessment was not performed for one of the subrecipients tested. Department of Agriculture We tested 13 pass-through payments applicable to the Department of Agriculture where the assistance listing was required to be communicated. The assistance listing was not communicated at the time of disbursement for seven pass-through payments tested. We tested 14 subrecipients applicable to the Department of Agriculture. A risk assessment was not performed for 12 subrecipients tested, a subaward agreement was not entered into for 11 subrecipients, and the subrecipient single audit report was not reviewed for one subrecipient. Aging and Disability Services Division We tested 2 pass-through payments applicable to the Nevada Aging and Disability Services Division. The assistance listing was not communicated at the time of disbursement for both pass-through payments tested. Division of Public and Behavioral Health We tested 2 pass-through payments applicable to the Division of Public and Behavioral Health. The assistance listing number was not communicated at the time of disbursement for both pass-through payments tested. Repeat Finding from Prior Year: Yes – prior year finding 2022-035. Recommendation: We recommend the State agencies listed above enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The State of Nevada agrees with this finding.

U.S. Department of Education Title I Grants to Local Educational Agencies, 84.010 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.010 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The U.S. Department of Education provides Local Educational Agency (LEA) allocation tables to the Nevada Department of Education (NDE) for basic grants, concentration grants, targeted grants, and education finance incentive grants based on LEA-level data from the Bureau of Census. NDE makes adjustments to those tables for specific items prescribed by 34 CFR section 200 such as: o LEAs not on the census o Hold harmless o Newly opened or significantly expanded charter schools o School improvement funds o State administration Condition: NDE did not maintain the original calculation of adjustments performed to the base LEA allocation tables. The amounts allocated to the LEAs were not supported by documentation maintained by NDE. As part of our audit procedures, we requested NDE reperform the allocation adjustments. NDE reperformed the allocation adjustments but was unable to agree to the original allocations to the LEAs. Cause: NDE did not have sufficient internal controls to ensure supporting documentation of the adjustments and allocations to LEAs was maintained. Effect: LEAs may not receive the appropriate funding allocation. Questioned Costs: None Context/Sampling: The original allocation workbook was not maintained and therefore could not be tested. However, NDE reperformed a new allocation after our request. We noted variances from the reperformed allocation to the original funding allocation across all 19 LEAs as follows: o Basic grants had variances ranging from $11 to $2,896,904. o Concentration grants had variances ranging from $0 to $110,980. o Targeted grants had variances ranging from $2 to $3,439,895. o Finance incentive grants had variances between $1 to $2,539,768. The total amounts allocated were the same in the reperformed allocation when compared to the original allocation. Therefore, the ranges noted above represent both under and over allocation variances to the LEAs. However, the census information (adjustments) used by NDE were not updated from the prior year in the reperformed allocation. Therefore, there is no information available to determine whether allocations to the LEAs were accurate in either the original allocation or reperformed allocation. Repeat Finding from Prior Year: No Recommendation: We recommend NDE enhance internal controls to ensure supporting documentation of the adjustments and allocations to LEAs is maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education Title I Grants to Local Educational Agencies, 84.010 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.010 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. A Local Educational Agency (LEA) may receive funds under Title I only if the State Educational Agency (SEA) finds that the combined fiscal effort per student or the aggregate expenditures of the LEA from State and local funds for free public education for the preceding year was not less than 90 percent of the combined fiscal effort or aggregate expenditures for the second preceding year, unless specifically waived by the U.S. Department of Education (34 CFR section 299.5). Condition: The Nevada Department of Education (NDE) did not maintain documentation, compiled from reports submitted by the LEAs, to monitor LEA compliance. As part of our audit procedures, we requested NDE compile the information to determine whether LEAs had met their fiscal effort requirements and whether NDE was required to take any necessary actions for failures to meet the fiscal effort requirements. Cause: NDE did not have sufficient internal controls to ensure maintenance of effort tracking was maintained and reviewed for accuracy and compliance. Effect: Noncompliance with maintenance of effort requirements may not be detected and NDE may not make required funding adjustments. If an LEA fails to maintain fiscal effort, NDE must reduce an LEA’s allocation under Title I if the LEA also failed to maintain effort in one or more of the five immediately preceding fiscal years in the exact proportion by which the LEA fails to maintain effort by falling below 90 percent of both the combined fiscal effort per student and aggregate expenditures. Questioned Costs: None Context/Sampling: NDE compiled expenditure data for 19 LEAs after our request. We reviewed overall compliance for all 19 LEAs and a non-statistical sample of 4 LEAs was selected for testing by tracing to original reports. Amounts included in the calculation for one LEA did not agree to underlying supporting documentation by $2,493. However, this variance did not change the overall conclusion on compliance for the one LEA with its fiscal effort. All 19 LEAs were found to have met their fiscal effort. Repeat Finding from Prior Year: Yes – prior year finding 2022-037. Recommendation: We recommend NDE enhance internal controls to ensure information used in the maintenance of effort monitoring document is maintained and reviewed for accuracy and compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance Grant Award Number: Affects grant award S425U210018 included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides the following requirements: • ESSER o A State Educational Agency (SEA) must allocate at least 90% of ESSER funds to Local Educational Agencies (LEA) using the statutorily prescribed formula. • ARP ESSER o Under section 2001(f) of the ARP act, each SEA must reserve: (1) at least 5% of ARP ESSER funds for evidence-based interventions that address the academic impact of lost instructional time; (2) at least 1% of ARP ESSER funds for evidence-based summer enrichment programs; (3) at least 1% of ARP ESSER funds for evidence-based comprehensive after school programs. • Allowances for Administrative Costs o Under section 18001(e) of the CARES act and section 313(e) of the CRRSA act, an SEA may reserve up to 0.5% of it’s total ESSER I and ESSER II allocations for administrative cost. o Under Section 2001(f)(4) of the ARP Act, an SEA may reserve not more than 0.5% of the state’s total ARP ESSER award for administrative costs. o Under section 312(d)(5) of the CRRSA Act, an SEA may reserve up to 0.5% of its total allocation or up to $200,000, whichever is greater, to administer the EANS program. Condition: The Nevada Department of Education (NDE) did not meet the earmarking set aside for evidence-based summer enrichment programs and evidence-based after school programs. In addition, there is no evidence that compliance with the earmarking requirements (i.e., actual amounts meeting the allocations or that there could be future changes to allocated amounts) is monitored. Cause: NDE did not have adequate internal controls to ensure earmarking requirements were initially met and to ensure on-going compliance was monitored. Effect: Earmarking requirements were not met and may not be met in the future. Questioned Costs: None Context/Sampling: We tested all earmarking computations required to be completed in State fiscal year 2023. There was no evidence of monitoring the earmarking requirements. Under section 2001(f) of the ARP act, each SEA must reserve: (2) at least 1% of ARP ESSER funds for evidence-based summer enrichment programs; (3) at least 1% of ARP ESSER funds for evidence-based comprehensive after school programs. • The minimum amount to allocate to evidence-based summer enrichment programs and evidence-based after school programs was $21,455,664 and the actual amount allocated was $20,040,662. The allocated amounts above were identified and reported in the prior year. However, there was no evidence of adjustments to these allocations in the current year. Repeat Finding from Prior Year: Yes – prior year finding 2022-042. Recommendation: We recommend NDE enhance internal controls to ensure earmarking requirements are initially met and implement internal controls to ensure ongoing compliance is monitored. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Reporting Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listings 93.575 and 93.596 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 underlying accounting information or performance records, and are fairly presented in accordance with governing requirements. The Division of Welfare and Supportive Services (DWSS) must submit the ACF-696, Child Care and Development Fund Financial Reports quarterly. Condition: Certain amounts reported on the ACF-696 did not agree to underlying documentation. Cause: DWSS did not have internal controls to ensure the amounts reported were adequately documented and supported. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of four reports out of a population of 14 submitted during the audit period was selected for testing. Variances were noted as follows: Quarter Ended September 30, 2022 (FFY2021 – 2101NVCCDF) Amount Reported Amount per General Ledger Line 1d – Direct Services (Col C) $17,839,132 $17,912,019 Quarter Ended March 31, 2023 (FFY2020 – 2001NVCCDF) Amount Reported Amount per General Ledger Line 1 – Total Expenditures (Col B) $16,920,153 $23,235,306 Line 1d – Direct Services (Col B) $15,304,717 $16,294,920 Line 2a – State Expenditures (Col B) $625,234 $6,940,386 Repeat Finding from Prior Year: Yes – prior year finding 2022-053. Recommendation: We recommend DWSS implement internal controls to ensure the amounts reported are adequately documented and supported. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 93.575 and 93.596 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Division of Welfare Supportive Services (DWSS) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS, and, therefore, not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of three out of a population of six applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 3 $135,360,827 Not Reported 3 $135,360,827 Not Timely 3 $135,360,827 Obligation Incorrect 3 $135,360,827 Missing Key Elements 3 $135,360,827 Repeat Finding from Prior Year: Yes – prior year finding 2022-054. Recommendation: We recommend DWSS implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Reporting Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listings 93.575 and 93.596 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 underlying accounting information or performance records, and are fairly presented in accordance with governing requirements. The Division of Welfare and Supportive Services (DWSS) must submit the ACF-696, Child Care and Development Fund Financial Reports quarterly. Condition: Certain amounts reported on the ACF-696 did not agree to underlying documentation. Cause: DWSS did not have internal controls to ensure the amounts reported were adequately documented and supported. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of four reports out of a population of 14 submitted during the audit period was selected for testing. Variances were noted as follows: Quarter Ended September 30, 2022 (FFY2021 – 2101NVCCDF) Amount Reported Amount per General Ledger Line 1d – Direct Services (Col C) $17,839,132 $17,912,019 Quarter Ended March 31, 2023 (FFY2020 – 2001NVCCDF) Amount Reported Amount per General Ledger Line 1 – Total Expenditures (Col B) $16,920,153 $23,235,306 Line 1d – Direct Services (Col B) $15,304,717 $16,294,920 Line 2a – State Expenditures (Col B) $625,234 $6,940,386 Repeat Finding from Prior Year: Yes – prior year finding 2022-053. Recommendation: We recommend DWSS implement internal controls to ensure the amounts reported are adequately documented and supported. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 93.575 and 93.596 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Division of Welfare Supportive Services (DWSS) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS, and, therefore, not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of three out of a population of six applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 3 $135,360,827 Not Reported 3 $135,360,827 Not Timely 3 $135,360,827 Obligation Incorrect 3 $135,360,827 Missing Key Elements 3 $135,360,827 Repeat Finding from Prior Year: Yes – prior year finding 2022-054. Recommendation: We recommend DWSS implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Matching, Level of Effort, and Earmarking Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.596 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Applicable to the matching fund (assistance listing 93.596), state expenditures will be matched at the Federal Medical Assistance Percentage (FMAP) rate for the applicable fiscal year. Private or public donated funds may be counted as state expenditures for this purpose subject to the limitations in 45 CFR section 98.53. Condition: The Division of Welfare and Supportive Services (DWSS) utilizes donated in-kind services from partner agencies and subrecipients to satisfy the match requirement for the matching fund. The in-kind services are cumulatively tracked and applied against the required match. During our audit procedures, we noted instances where the amount reported for matching expenditures did not agree to the in-kind cumulative tracker and instances where the underlying support (certified match letters received from partner agencies and subrecipients) did not agree to the tracker. Cause: DWSS did not have adequate internal controls to ensure the in-kind service match amounts are reconciled and reported accurately. Effect: Inaccurate amounts available for match may be maintained and may impact whether the matching requirement is met. Questioned Costs: None Context/Sampling: The matching fund was tested for the federal fiscal year 2020 matching grant, which had a period performance end of September 30, 2022. The match initially required was $6,252,334 (later adjusted in a final report to $7,233,384). The match reconciled in the cumulative balance tracker was $5,858,548. The match contributed from partner agencies and subrecipients was noted as $28,506,852; however, not all of the amounts tracked agreed to the underlying support. Although, $20,190,154 was agreed to the underlying support, which was sufficient to meet the matching requirement. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS enhance internal controls to ensure in-kind service match amounts are reconciled and reported accurately. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Reporting Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listings 93.575 and 93.596 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 underlying accounting information or performance records, and are fairly presented in accordance with governing requirements. The Division of Welfare and Supportive Services (DWSS) must submit the ACF-696, Child Care and Development Fund Financial Reports quarterly. Condition: Certain amounts reported on the ACF-696 did not agree to underlying documentation. Cause: DWSS did not have internal controls to ensure the amounts reported were adequately documented and supported. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of four reports out of a population of 14 submitted during the audit period was selected for testing. Variances were noted as follows: Quarter Ended September 30, 2022 (FFY2021 – 2101NVCCDF) Amount Reported Amount per General Ledger Line 1d – Direct Services (Col C) $17,839,132 $17,912,019 Quarter Ended March 31, 2023 (FFY2020 – 2001NVCCDF) Amount Reported Amount per General Ledger Line 1 – Total Expenditures (Col B) $16,920,153 $23,235,306 Line 1d – Direct Services (Col B) $15,304,717 $16,294,920 Line 2a – State Expenditures (Col B) $625,234 $6,940,386 Repeat Finding from Prior Year: Yes – prior year finding 2022-053. Recommendation: We recommend DWSS implement internal controls to ensure the amounts reported are adequately documented and supported. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 93.575 and 93.596 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Division of Welfare Supportive Services (DWSS) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS, and, therefore, not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of three out of a population of six applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 3 $135,360,827 Not Reported 3 $135,360,827 Not Timely 3 $135,360,827 Obligation Incorrect 3 $135,360,827 Missing Key Elements 3 $135,360,827 Repeat Finding from Prior Year: Yes – prior year finding 2022-054. Recommendation: We recommend DWSS implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Children’s Health Insurance Program (CHIP), 93.767 Medicaid Cluster: State Medicaid Fraud Control Units, 93.775 State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare, 93.777 Medical Assistance Program (Medicaid; Title XIX), 93.778 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.767 and 93.778 on the Schedule of Expenditures of Federal Awards. Criteria: Title 42 Public Health section 435.403 State Residence provides that the State must provide Medicaid to eligible residents of the State, including residents who are absent from the State, except in cases where another state has determined that the person is a resident there for purposes of Medicaid. The Medicaid State Plan provides that the State has an eligibility determination system for data matching through the Public Assistance Reporting Information System (PARIS). The information that is requested is to be exchanged with states and other entities legally entitled to verify Title XIX applications and individuals eligible for covered Title XIX services consistent with applicable PARIS agreements. The State will transmit and receive data quarterly (February, May, August, and November). The State enrolls beneficiaries on a mandatory basis into managed care entities (managed care organizations and/or primary care case managers) in the absence of certain allowable waivers. The State contracts with managed care organizations and reimburses them for capitation payments. Condition: PARIS data was not utilized by the Division of Health Care Financing and Policy (DHCFP) or the Division of Welfare and Supportive Services (DWSS) to monitor residency changes to determine when managed care benefits needed to be terminated because the beneficiary was a resident of another state for Medicaid purposes. Cause: DHCFP and DWSS did not have internal controls in place to effectively communicate the PARIS data between the two agencies to ensure managed care benefits were terminated when appropriate. Effect: Individuals are enrolled in Medicaid (and CHIP) plans in multiple states and benefits are not being terminated timely. Therefore, the State of Nevada is paying capitation payments to managed care organizations, when the benefits should have been terminated. Questioned Costs: Projected questioned costs are $11,108,851 for Medicaid and $139,223 for CHIP. Context/Sampling: No sampling was used. The PARIS data was obtained and examined in total. The PARIS data included 55,251 participants with dual enrollment. Of those 55,251 participants, 8,439 participants were enrolled in another state after the State of Nevada. The projected questioned costs were estimated by performing the following: • Identifying individuals who enrolled in another state after they had enrolled in Nevada (termination date for Nevada). • Estimating a weighted average capitation payment based on demographics that determine the payment amount. • Applying the weighted average capitation payments from the termination date through June 30, 2023 to determine the total projected questioned costs. • The total projected questioned costs were then allocated between Medicaid and CHIP using participant counts in each plan between the ages of 0-18. Participants older than 18 were allocated to Medicaid. The allocated projected questioned costs were then multiplied by a weighted average Federal Medical Assistance Percentage (FMAP) to determine the final projected federal questioned costs. Repeat Finding from Prior Year: Yes – prior year finding 2022-061. Recommendation: We recommend DHCFP and DWSS implement internal controls to effectively communicate the PARIS data between each other and to ensure managed care benefits are terminated when appropriate. Views of Responsible Officials: The Division of Health Care Financing and Policy and the Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Medicaid Cluster: State Medicaid Fraud Control Units, 93.775 State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare, 93.777 Medical Assistance Program (Medicaid; Title XIX), 93.778 Allowable Activities and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.778 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.403 provides that costs must be adequately documented to support the allowability of the cost. Condition: Underlying supporting documentation for certain administrative costs was not maintained by the Division of Health Care Financing and Policy (DHCFP). Cause: DHCFP did not have adequate internal controls to ensure supporting documentation for administrative expenditures was maintained. Effect: Administrative costs were charged to the federal program without appropriate supporting documentation. Questioned Costs: $5,459 Context/Sampling: A nonstatistical sample of 60 transactions ($634,037) out of a population of 4,335 transactions ($134,939,132) was selected for testing. No documentation was available to support seven transactions, totaling $5,459, that were charged to the federal program. These charges included general ledger descriptions of: • Per diem in-state • Annual leave • Building and grounds lease assessment • IT virtual server hosting • IT security assessment Of the seven transactions, five were journal vouchers that did not contain the underlying support for the journal voucher. One transaction was coded as a direct payment voucher and one transaction was coded as an expenditure to a cash receipt (rather than payment voucher). Repeat Finding from Prior Year: No Recommendation: We recommend DHCFP enhance internal controls to ensure supporting documentation for administrative expenditures is maintained. Views of Responsible Officials: The Division of Health Care Financing and Policy agrees with this finding.

U.S. Department of Health and Human Services Medicaid Cluster: State Medicaid Fraud Control Units, 93.775 State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare, 93.777 Medical Assistance Program (Medicaid; Title XIX), 93.778 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.778 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. States are required to determine eligibility in accordance with the eligibility requirements defined in the approved State plan (42 CFR 457). The State plan describes certain aid categories, including the eligibility criteria and potential benefits allowed under the aid categories for eligible individuals. Condition: To enroll in Medicaid, a beneficiary must apply for benefits to the Nevada Division of Welfare and Supportive Services (DWSS). An intake employee will review, timestamp, and input the application or redetermination into a casefile to provide for a second review of the application or redetermination by a supervisor. In certain instances, the application or redetermination was either not properly filed or not maintained to allow for review by a supervisor. Cause: DWSS did not have adequate internal controls to ensure applications and redeterminations were properly documented and maintained. Effect: Individuals may receive benefits that they are not entitled to or not receive benefits for which they are entitled to. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 out of a population of 74,760 Modified Adjusted Gross Income (MAGI) based determinations was selected for testing. Two applications were not properly indexed or maintained in the casefile to allow for review by a supervisor. However, the other supporting documentation was maintained that ultimately supported the eligibility determination and conclusion. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS enhance internal controls to ensure applications and redeterminations are properly documented and maintained. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Medicaid Cluster: State Medicaid Fraud Control Units, 93.775 State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare, 93.777 Medical Assistance Program (Medicaid; Title XIX), 93.778 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 93.778 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 underlying accounting information, and are presented in accordance with program requirements. The Nevada Division of Health Care Financing and Policy (DHCFP) is required to submit Quarterly Medicaid Statement of Expenditures for the Medical Assistance Program (CMS-64) reports based on actual recorded expenditures (42 CFR 430.30). Condition: Amounts reported on the CMS-64 were not supported by the underlying accounting information. Cause: DHCFP did not have adequate internal controls to ensure CMS-64 reports were accurate or supporting documentation for reconciling items was maintained. Effect: Inaccurate information may be reported to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of two CMS-64 reports out of a population of four was selected for testing. DHCFP has manual adjustments to key line items within the CMS-64 from the general ledger. DHCFP did not maintain a record of any of the manual adjustments and we were unable to verify whether the manual adjustment was appropriate. In total, there were $36,128,957 in manual adjustments in the December 31, 2022 CMS-64 report and $5,364,337 in the March 31, 2023 CMS-64 report that we were unable to verify. Repeat Finding from Prior Year: Yes – prior year finding 2022-062. Recommendation: We recommend DHCFP enhance internal controls to ensure CMS-64 reports are accurate and supporting documentation is maintained. Views of Responsible Officials: The Nevada Division of Health Care Financing and Policy agrees with this finding.

U.S. Department of Health and Human Services Temporary Assistance for Needy Families, 93.558 COVID-19 Temporary Assistance for Needy Families, 93.558 Matching, Level of Effort, and Earmarking Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.558 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. As provided by 45 CFR section 264.1, the average monthly number of families that include an adult or minor child head of household, or the spouse of the head of household, who has received assistance under any state program funded by federal TANF funds for more than 60 countable months (whether or not consecutive) may not exceed 20 percent of the average monthly number of all families to which the state provided assistance during the fiscal year or the immediately preceding fiscal year (but not both), as the state may elect. Condition: The Division of Welfare and Supportive Services (DWSS) compiles the caseload criteria above in a TANF NEON Cash Cases Hardship Report. There was no evidence that this report was approved, reviewed, or otherwise monitored. Cause: DWSS did not have internal controls to ensure caseload earmarking requirements are monitored. Effect: Noncompliance with earmarking requirements may not be detected. Questioned Costs: None Context/Sampling: The caseload report was generated for the entire state fiscal year. The average cases with more than 60 countable months were 0.19% of the total cases for the state fiscal year, which is below the 20% maximum allowed. However, this report is generated internally by DWSS on a quarterly basis (and aggregated to be summarized annually), and there was no evidence of a review being performed. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS enhance internal controls to ensure caseload earmarking requirements are monitored. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Temporary Assistance for Needy Families, 93.558 COVID-19 Temporary Assistance for Needy Families, 93.558 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 93.558 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Division of Welfare and Supportive Services (DWSS) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS, and, therefore, not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of three out of a population of nine applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 3 $1,381,291 Not Reported 3 $1,381,291 Not Timely 3 $1,381,291 Obligation Incorrect 3 $1,381,291 Missing Key Elements 3 $1,381,291 Repeat Finding from Prior Year: No Recommendation: We recommend DWSS implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Temporary Assistance for Needy Families, 93.558 COVID-19 Temporary Assistance for Needy Families, 93.558 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.558 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) section 200.332 requires that: Pass-through entities monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. The Division of Welfare and Supportive Services (DWSS) has developed risk based subrecipient monitoring policies and procedures to provide for reasonable assurance that subrecipients are complying with federal requirements. These policies indicate that DWSS will perform an onsite review at least every three years, with higher risk subrecipients being subjected to increased frequency of review and oversight. Condition: Certain subrecipients were identified as high risk by DWSS and were not subjected to higher frequency monitoring procedures as described by the DWSS policy, such as a desk review or on-site visit. Cause: DWSS did not have adequate internal controls to ensure program staff had adequate capacity to perform monitoring procedures for subrecipients in accordance with DWSS policy. Effect: Noncompliance at the subrecipient level may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of three subrecipients out of a population of nine was selected for testing. Of the three subrecipients selected, two were deemed high risk by DWSS and neither were monitored through desk review or on-site review during the year. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS implement internal controls to ensure program staff have adequate capacity to perform monitoring procedures for subrecipients in accordance with DWSS policy. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Temporary Assistance for Needy Families, 93.558 COVID-19 Temporary Assistance for Needy Families, 93.558 Matching, Level of Effort, and Earmarking Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.558 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. As provided by 45 CFR section 264.1, the average monthly number of families that include an adult or minor child head of household, or the spouse of the head of household, who has received assistance under any state program funded by federal TANF funds for more than 60 countable months (whether or not consecutive) may not exceed 20 percent of the average monthly number of all families to which the state provided assistance during the fiscal year or the immediately preceding fiscal year (but not both), as the state may elect. Condition: The Division of Welfare and Supportive Services (DWSS) compiles the caseload criteria above in a TANF NEON Cash Cases Hardship Report. There was no evidence that this report was approved, reviewed, or otherwise monitored. Cause: DWSS did not have internal controls to ensure caseload earmarking requirements are monitored. Effect: Noncompliance with earmarking requirements may not be detected. Questioned Costs: None Context/Sampling: The caseload report was generated for the entire state fiscal year. The average cases with more than 60 countable months were 0.19% of the total cases for the state fiscal year, which is below the 20% maximum allowed. However, this report is generated internally by DWSS on a quarterly basis (and aggregated to be summarized annually), and there was no evidence of a review being performed. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS enhance internal controls to ensure caseload earmarking requirements are monitored. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Temporary Assistance for Needy Families, 93.558 COVID-19 Temporary Assistance for Needy Families, 93.558 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 93.558 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Division of Welfare and Supportive Services (DWSS) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS, and, therefore, not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of three out of a population of nine applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 3 $1,381,291 Not Reported 3 $1,381,291 Not Timely 3 $1,381,291 Obligation Incorrect 3 $1,381,291 Missing Key Elements 3 $1,381,291 Repeat Finding from Prior Year: No Recommendation: We recommend DWSS implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Temporary Assistance for Needy Families, 93.558 COVID-19 Temporary Assistance for Needy Families, 93.558 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.558 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) section 200.332 requires that: Pass-through entities monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. The Division of Welfare and Supportive Services (DWSS) has developed risk based subrecipient monitoring policies and procedures to provide for reasonable assurance that subrecipients are complying with federal requirements. These policies indicate that DWSS will perform an onsite review at least every three years, with higher risk subrecipients being subjected to increased frequency of review and oversight. Condition: Certain subrecipients were identified as high risk by DWSS and were not subjected to higher frequency monitoring procedures as described by the DWSS policy, such as a desk review or on-site visit. Cause: DWSS did not have adequate internal controls to ensure program staff had adequate capacity to perform monitoring procedures for subrecipients in accordance with DWSS policy. Effect: Noncompliance at the subrecipient level may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of three subrecipients out of a population of nine was selected for testing. Of the three subrecipients selected, two were deemed high risk by DWSS and neither were monitored through desk review or on-site review during the year. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS implement internal controls to ensure program staff have adequate capacity to perform monitoring procedures for subrecipients in accordance with DWSS policy. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Child Support Enforcement, 93.563 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.563 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) section 200.332 requires that: Pass-through entities ensure every subaward includes certain information at the time of the subaward. Condition: Subawards did not contain all the required information. Cause: The Division of Welfare and Supportive Services (DWSS) did not have internal controls to ensure subawards contained all required information. Effect: The subrecipient may not be aware of all requirements and noncompliance could occur. Questioned Costs: None Context/Sampling: A nonstatistical sample of three subrecipients out of a population of 15 was selected for testing. All three subrecipient agreements were missing required elements per 2 CFR 200.332. The items missing from the agreements were: •Federal Award Identification Number •Subrecipient Unique Entity Identifier •Indirect Cost Rate •Federal Award Date Repeat Finding from Prior Year: No Recommendation: We recommend DWSS implement internal controls to ensure subawards contain all required information. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.568 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain reimbursement requests were not reviewed and approved by an individual independent of the preparation of the request. Cause: The Nevada Division of Welfare and Supportive Services (DWSS) did not have adequate internal controls to ensure all reimbursement requests were reviewed and approved. Effect: Inaccurate reimbursement requests may occur and not detected by DWSS timely. Questioned Costs: None Context/Sampling: A nonstatistical sample of 29 reimbursement requests out of a population of 141 was selected for testing. Six reimbursement requests did not have the evidence of review and approval by an individual independent of the preparation (segregation of duties). Repeat Finding from Prior Year: Yes – prior year finding 2022-047. Recommendation: We recommend DWSS enhance internal controls to ensure all reimbursement requests are reviewed and approved in accordance with the Division’s internal control policy. Views of Responsible Officials: The Nevada Division of Welfare and Supportive agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Eligibility Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.568 on the Schedule of Expenditures of Federal Awards. Criteria: As provided by 42 USC 8624(b)(2), assistance may be provided to: • Households in which one or more individuals are receiving Temporary Assistance for Needy Families (TANF), Supplemental Security Income (SSI), Supplemental Nutrition Assistance Program (SNAP) benefits, or certain needs-tested veterans’ benefits or; • Households with incomes which do not exceed the greater of 150% of the State’s established poverty level, or 60% of the State’s median income. Lower income eligibility criteria may be established, but no household may be excluded solely on the basis of income if the household income is less than 110% of the State’s poverty level. The Low-Income Home Energy Assistance State Plan (State Plan) establishes and describes assistance benefit levels, which provides for the calculation of a Fixed Annual Credit (FAC) and ultimately, the amount of assistance provided. Condition: The amount of assistance to provide was not calculated correctly. Cause: The Nevada Division of Welfare and Supportive Services (DWSS) did not have adequate internal controls to ensure annual and eligible income were correctly reflected. Effect: Benefits were not computed accurately and over disbursed. Questioned Costs: $307 Context/Sampling: A nonstatistical sample of 60 recipients ($66,234 benefits paid) out of a population of 12,285 ($16,985,706 benefits paid) was selected for testing. For one recipient, the annual and eligible income was reflected as $0. However, the annual and eligible income should have been $13,404 as supported by the case file, which impacted the benefit calculation and resulted in the over payment. Repeat Finding from Prior Year: Yes – prior year finding 2022-049. Recommendation: We recommend DWSS enhance internal controls to ensure annual and eligible income is correctly reflected. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 93.568 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 underlying accounting information, and are presented in accordance with program requirements. The Nevada Division of Welfare and Supportive Services (DWSS) is required to submit the LIHEAP Performance Data Form each year, which indicates the amount expected to be carried forward for obligation in the following fiscal year and the planned use of those funds and the sources and uses of LIHEAP funds, respectively. Condition: Amounts reported for weatherization assistance benefits, unobligated funds, and administration costs did not have underlying documentation to support the amount reported. Cause: DWSS did not have adequate internal controls to ensure amounts reported on the LIHEAP Performance DATA Form were appropriately supported. Effect: Inaccurate information may have been reported to the federal awarding agency. Questioned Costs: None Context/Sampling: The one annual report submitted during the audit period was selected for testing. Weatherization Assistance Benefits of $617,842, Unobligated Funds of $286,708, and Administration Costs of $995,181 had no supporting documentation available to show how amounts were determined. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS enhance internal controls to ensure amounts reported on the LIHEAP Performance Data Form are appropriately supported. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects grant awards 2101NVLIEA and 2201NVLIEA 2022G992201 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 underlying accounting information, and are presented in accordance with program requirements. The Nevada Division of Welfare and Supportive Services (DWSS) is required to submit the LIHEAP Carryover and Reallotment Report each year, which indicates the amount expected to be carried forward for obligation in the following fiscal year and the planned use of those funds and the sources and uses of LIHEAP funds, respectively. Condition: The projected unobligated balance (carryover amount) had no underlying documentation or support the amount. Cause: DWSS did not have internal controls to ensure amounts reported on the LIHEAP Carryover and Reallotment Report were adequately documented and supported. Effect: Inaccurate information may have been reported to the federal awarding agency. Questioned Costs: None Context/Sampling: The one annual report submitted during the audit period was selected for testing. The following variances were noted on the report: Amount Reported Amount per Reconciliation Line 1.1 – Current Year payable $15,545,877 $15,012,533 Line 1.3 – Projected unobligated balance $286,709 $999,808 No explanation for the reconciling items between the reconciliation amounts and the amounts ultimately reported were provided. Repeat Finding from Prior Year: Yes – prior year finding 2022-050. Recommendation: We recommend DWSS implement internal controls to ensure amounts reported on the LIHEAP Carryover and Reallotment Report are adequately documented and supported. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects grant awards 2101NVLIEA, 2201NVLIEA 2022G992201, 2301NVLIEA, 2301NVLIEE, and 2101NVE5C6 included under assistance listing 93.568 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Housing Division (NHD) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not include on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: We tested the entire population of 4 subawards obligated during the year. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 4 $1,398,599 Not Reported 4 $1,398,599 Not Timely 4 $1,398,599 Obligation Incorrect 4 $1,398,599 Missing Key Elements 4 $1,398,599 Repeat Finding from Prior Year: Yes – prior year finding 2022-051. Recommendation: We recommend NHD implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Housing Division agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.568 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain reimbursement requests were not reviewed and approved by an individual independent of the preparation of the request. Cause: The Nevada Division of Welfare and Supportive Services (DWSS) did not have adequate internal controls to ensure all reimbursement requests were reviewed and approved. Effect: Inaccurate reimbursement requests may occur and not detected by DWSS timely. Questioned Costs: None Context/Sampling: A nonstatistical sample of 29 reimbursement requests out of a population of 141 was selected for testing. Six reimbursement requests did not have the evidence of review and approval by an individual independent of the preparation (segregation of duties). Repeat Finding from Prior Year: Yes – prior year finding 2022-047. Recommendation: We recommend DWSS enhance internal controls to ensure all reimbursement requests are reviewed and approved in accordance with the Division’s internal control policy. Views of Responsible Officials: The Nevada Division of Welfare and Supportive agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Eligibility Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.568 on the Schedule of Expenditures of Federal Awards. Criteria: As provided by 42 USC 8624(b)(2), assistance may be provided to: • Households in which one or more individuals are receiving Temporary Assistance for Needy Families (TANF), Supplemental Security Income (SSI), Supplemental Nutrition Assistance Program (SNAP) benefits, or certain needs-tested veterans’ benefits or; • Households with incomes which do not exceed the greater of 150% of the State’s established poverty level, or 60% of the State’s median income. Lower income eligibility criteria may be established, but no household may be excluded solely on the basis of income if the household income is less than 110% of the State’s poverty level. The Low-Income Home Energy Assistance State Plan (State Plan) establishes and describes assistance benefit levels, which provides for the calculation of a Fixed Annual Credit (FAC) and ultimately, the amount of assistance provided. Condition: The amount of assistance to provide was not calculated correctly. Cause: The Nevada Division of Welfare and Supportive Services (DWSS) did not have adequate internal controls to ensure annual and eligible income were correctly reflected. Effect: Benefits were not computed accurately and over disbursed. Questioned Costs: $307 Context/Sampling: A nonstatistical sample of 60 recipients ($66,234 benefits paid) out of a population of 12,285 ($16,985,706 benefits paid) was selected for testing. For one recipient, the annual and eligible income was reflected as $0. However, the annual and eligible income should have been $13,404 as supported by the case file, which impacted the benefit calculation and resulted in the over payment. Repeat Finding from Prior Year: Yes – prior year finding 2022-049. Recommendation: We recommend DWSS enhance internal controls to ensure annual and eligible income is correctly reflected. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 93.568 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 underlying accounting information, and are presented in accordance with program requirements. The Nevada Division of Welfare and Supportive Services (DWSS) is required to submit the LIHEAP Performance Data Form each year, which indicates the amount expected to be carried forward for obligation in the following fiscal year and the planned use of those funds and the sources and uses of LIHEAP funds, respectively. Condition: Amounts reported for weatherization assistance benefits, unobligated funds, and administration costs did not have underlying documentation to support the amount reported. Cause: DWSS did not have adequate internal controls to ensure amounts reported on the LIHEAP Performance DATA Form were appropriately supported. Effect: Inaccurate information may have been reported to the federal awarding agency. Questioned Costs: None Context/Sampling: The one annual report submitted during the audit period was selected for testing. Weatherization Assistance Benefits of $617,842, Unobligated Funds of $286,708, and Administration Costs of $995,181 had no supporting documentation available to show how amounts were determined. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS enhance internal controls to ensure amounts reported on the LIHEAP Performance Data Form are appropriately supported. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects grant awards 2101NVLIEA, 2201NVLIEA 2022G992201, 2301NVLIEA, 2301NVLIEE, and 2101NVE5C6 included under assistance listing 93.568 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Housing Division (NHD) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not include on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: We tested the entire population of 4 subawards obligated during the year. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 4 $1,398,599 Not Reported 4 $1,398,599 Not Timely 4 $1,398,599 Obligation Incorrect 4 $1,398,599 Missing Key Elements 4 $1,398,599 Repeat Finding from Prior Year: Yes – prior year finding 2022-051. Recommendation: We recommend NHD implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Housing Division agrees with this finding.

U.S. Department of Health and Human Services Foster Care – Title IV-E, 93.658 Adoption Assistance, 93.659 Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.658 and 93.659 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that a State must claim federal financial participation for costs associated with a program only in accordance with its approved cost allocation plan. Since cost allocation plans are of a narrative nature, the Federal government needs assurance that the cost allocation plan has been implemented as approved. Condition: Allocation methods used in cost allocation did not agree to the approved cost allocation plan, amounts allocated did not agree to the general ledger, and allocation statistics did not agree to underlying support. Cause: The Nevada Division of Child and Family Services (DCFS) did not have adequate internal controls to ensure costs were allocated accurately and in accordance with the cost allocation plan. Effect: Costs may be charged to the federal programs that do not agree to the cost allocation plan. Questioned Costs: Foster Care - $24,025 Adoption Assistance - $30,475 Context/Sampling: A nonstatistical sample of two out of four quarters was selected for testing (the September 30, 2022 and March 31, 2023 quarters). In summary, errors were noted as follows: • Two allocation methods did not agree to the submitted cost allocation plan. Rural Case Management Contracts are not included within the cost allocation plan and Temporary Staffing Contracts are direct to a different grant per the cost allocation plan, but were actually allocated as a result of RMS. • Total costs allocated (across all programs) in budget account 3145 were overstated by $69,615 in the September 30, 2022 quarter and were understated by $2,297 in the March 31, 2023 quarter when agreeing amounts to the general ledger. • Two allocation statistics did not agree to the underlying supporting documentation that impacted the allocation percentages by 0.32% and .02% for two allocation methods in the March 31, 2023 cost allocation. These ultimately represented an under allocation to federal programs. Repeat Finding from Prior Year: Yes – prior year finding 2022-056. Recommendation: We recommend DCFS enhance internal controls to ensure costs are allocated accurately and in accordance with the cost allocation plan. Views of Responsible Officials: The Nevada Division of Child and Family Services agrees with this finding.

U.S. Department of Health and Human Services Foster Care – Title IV-E, 93.658 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant awards 2301NVFOST and G-2201NVFOST included under assistance listing 93.658 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported timely in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Division of Child and Family Services (DCFS) did not have internal controls to ensure subaward information was submitted timely in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS timely and therefore delayed on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: We tested the entire population of three subawards greater than $30,000 obligated during the year. The timeliness errors were noted as follows: Subawards Obligations Total Tested 3 $41,017,389 Not Reported - - Not Timely 2 $36,980,730 Obligation Incorrect - - Missing Key Elements - - The obligation date for the non-timely subawards was September 2022 and they were reported in January 2023. Repeat Finding from Prior Year: Yes – prior year finding 2022-057. Recommendation: We recommend DCFS implement internal controls to ensure subaward information is submitted timely in accordance with the FFATA. Views of Responsible Officials: The Nevada Division of Child and Family Services agrees with this finding.

U.S. Department of Health and Human Services Foster Care – Title IV-E, 93.658 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listings 93.658 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) section 200.332 requires that pass-through entities ensure that every subaward includes certain information at the time of the subaward and that the award’s assistance listing number is identified to the subrecipient at the time of disbursement. Condition: The assistance listing number was not identified at the time of disbursement. Cause: The Division of Child and Family Services (DCFS) did not have adequate internal controls to ensure the assistance listing number was communicated on each disbursement to a subrecipient. Effect: The subrecipient may not identify program receipts appropriately. Questioned Costs: None Context/Sampling: A nonstatistical sample of six subrecipient payments out of a population of 24 was selected for testing. The assistance listing number was not communicated on any of the payments. Repeat Finding from Prior Year: Yes – prior year finding 2022-058. Recommendation: We recommend DCFS enhance internal controls to ensure the assistance listing number is communicated on each disbursement to a subrecipient. Views of Responsible Officials: The Nevada Division of Child and Family Services agrees with this finding.

U.S. Department of Health and Human Services Foster Care – Title IV-E, 93.658 Adoption Assistance, 93.659 Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.658 and 93.659 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that a State must claim federal financial participation for costs associated with a program only in accordance with its approved cost allocation plan. Since cost allocation plans are of a narrative nature, the Federal government needs assurance that the cost allocation plan has been implemented as approved. Condition: Allocation methods used in cost allocation did not agree to the approved cost allocation plan, amounts allocated did not agree to the general ledger, and allocation statistics did not agree to underlying support. Cause: The Nevada Division of Child and Family Services (DCFS) did not have adequate internal controls to ensure costs were allocated accurately and in accordance with the cost allocation plan. Effect: Costs may be charged to the federal programs that do not agree to the cost allocation plan. Questioned Costs: Foster Care - $24,025 Adoption Assistance - $30,475 Context/Sampling: A nonstatistical sample of two out of four quarters was selected for testing (the September 30, 2022 and March 31, 2023 quarters). In summary, errors were noted as follows: • Two allocation methods did not agree to the submitted cost allocation plan. Rural Case Management Contracts are not included within the cost allocation plan and Temporary Staffing Contracts are direct to a different grant per the cost allocation plan, but were actually allocated as a result of RMS. • Total costs allocated (across all programs) in budget account 3145 were overstated by $69,615 in the September 30, 2022 quarter and were understated by $2,297 in the March 31, 2023 quarter when agreeing amounts to the general ledger. • Two allocation statistics did not agree to the underlying supporting documentation that impacted the allocation percentages by 0.32% and .02% for two allocation methods in the March 31, 2023 cost allocation. These ultimately represented an under allocation to federal programs. Repeat Finding from Prior Year: Yes – prior year finding 2022-056. Recommendation: We recommend DCFS enhance internal controls to ensure costs are allocated accurately and in accordance with the cost allocation plan. Views of Responsible Officials: The Nevada Division of Child and Family Services agrees with this finding.

U.S. Department of Health and Human Services Children’s Health Insurance Program (CHIP), 93.767 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.767 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. States are required to determine eligibility in accordance with the eligibility requirements defined in the approved State plan (42 CFR 457). The State plan describes certain aid categories, including the eligibility criteria and potential benefits allowed under the aid categories for eligible individuals. Condition: To enroll in CHIP, a beneficiary must apply for benefits to the Nevada Division of Welfare and Supportive Services (DWSS). An intake employee will review, timestamp, and input the application or redetermination into a casefile to provide for a second review of the application or redetermination by a supervisor. A redetermination was not always maintained to allow for the review by a supervisor. Cause: DWSS did not have adequate internal controls to ensure applications and redeterminations were properly documented and maintained. Effect: Individuals may receive benefits that they are not entitled to or not receive benefits for which they are entitled to. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 out of a population of 32,339 eligible participants was selected for testing. One individual did not have an application or redetermination available for review. However, other supporting documentation was maintained that ultimately supported the eligibility determination and conclusion. Repeat Finding from Prior Year: Yes – prior year finding 2022-059. Recommendation: We recommend DWSS enhance internal controls to ensure applications and redeterminations are properly documented and maintained. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Children’s Health Insurance Program (CHIP), 93.767 Medicaid Cluster: State Medicaid Fraud Control Units, 93.775 State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare, 93.777 Medical Assistance Program (Medicaid; Title XIX), 93.778 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.767 and 93.778 on the Schedule of Expenditures of Federal Awards. Criteria: Title 42 Public Health section 435.403 State Residence provides that the State must provide Medicaid to eligible residents of the State, including residents who are absent from the State, except in cases where another state has determined that the person is a resident there for purposes of Medicaid. The Medicaid State Plan provides that the State has an eligibility determination system for data matching through the Public Assistance Reporting Information System (PARIS). The information that is requested is to be exchanged with states and other entities legally entitled to verify Title XIX applications and individuals eligible for covered Title XIX services consistent with applicable PARIS agreements. The State will transmit and receive data quarterly (February, May, August, and November). The State enrolls beneficiaries on a mandatory basis into managed care entities (managed care organizations and/or primary care case managers) in the absence of certain allowable waivers. The State contracts with managed care organizations and reimburses them for capitation payments. Condition: PARIS data was not utilized by the Division of Health Care Financing and Policy (DHCFP) or the Division of Welfare and Supportive Services (DWSS) to monitor residency changes to determine when managed care benefits needed to be terminated because the beneficiary was a resident of another state for Medicaid purposes. Cause: DHCFP and DWSS did not have internal controls in place to effectively communicate the PARIS data between the two agencies to ensure managed care benefits were terminated when appropriate. Effect: Individuals are enrolled in Medicaid (and CHIP) plans in multiple states and benefits are not being terminated timely. Therefore, the State of Nevada is paying capitation payments to managed care organizations, when the benefits should have been terminated. Questioned Costs: Projected questioned costs are $11,108,851 for Medicaid and $139,223 for CHIP. Context/Sampling: No sampling was used. The PARIS data was obtained and examined in total. The PARIS data included 55,251 participants with dual enrollment. Of those 55,251 participants, 8,439 participants were enrolled in another state after the State of Nevada. The projected questioned costs were estimated by performing the following: • Identifying individuals who enrolled in another state after they had enrolled in Nevada (termination date for Nevada). • Estimating a weighted average capitation payment based on demographics that determine the payment amount. • Applying the weighted average capitation payments from the termination date through June 30, 2023 to determine the total projected questioned costs. • The total projected questioned costs were then allocated between Medicaid and CHIP using participant counts in each plan between the ages of 0-18. Participants older than 18 were allocated to Medicaid. The allocated projected questioned costs were then multiplied by a weighted average Federal Medical Assistance Percentage (FMAP) to determine the final projected federal questioned costs. Repeat Finding from Prior Year: Yes – prior year finding 2022-061. Recommendation: We recommend DHCFP and DWSS implement internal controls to effectively communicate the PARIS data between each other and to ensure managed care benefits are terminated when appropriate. Views of Responsible Officials: The Division of Health Care Financing and Policy and the Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 10.553, 10.555, 10.556, 10.559, and 10.582 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine out of a population of 61 applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 9 $1,772,633 Not Reported 9 $1,772,633 Not Timely 9 $1,772,633 Obligation Incorrect 9 $1,772,633 Missing Key Elements 9 $1,772,633 Repeat Finding from Prior Year: Yes – prior year finding 2022-019. Recommendation: We recommend NDA implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Department of Agriculture agrees with this finding.

U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 10.553, 10.555, 10.556, 10.559, and 10.582 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine out of a population of 61 applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 9 $1,772,633 Not Reported 9 $1,772,633 Not Timely 9 $1,772,633 Obligation Incorrect 9 $1,772,633 Missing Key Elements 9 $1,772,633 Repeat Finding from Prior Year: Yes – prior year finding 2022-019. Recommendation: We recommend NDA implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Department of Agriculture agrees with this finding.

U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 10.553, 10.555, 10.556, 10.559, and 10.582 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine out of a population of 61 applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 9 $1,772,633 Not Reported 9 $1,772,633 Not Timely 9 $1,772,633 Obligation Incorrect 9 $1,772,633 Missing Key Elements 9 $1,772,633 Repeat Finding from Prior Year: Yes – prior year finding 2022-019. Recommendation: We recommend NDA implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Department of Agriculture agrees with this finding.

U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 10.553, 10.555, 10.556, 10.559, and 10.582 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine out of a population of 61 applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 9 $1,772,633 Not Reported 9 $1,772,633 Not Timely 9 $1,772,633 Obligation Incorrect 9 $1,772,633 Missing Key Elements 9 $1,772,633 Repeat Finding from Prior Year: Yes – prior year finding 2022-019. Recommendation: We recommend NDA implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Department of Agriculture agrees with this finding.

U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 10.553, 10.555, 10.556, 10.559, and 10.582 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine out of a population of 61 applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 9 $1,772,633 Not Reported 9 $1,772,633 Not Timely 9 $1,772,633 Obligation Incorrect 9 $1,772,633 Missing Key Elements 9 $1,772,633 Repeat Finding from Prior Year: Yes – prior year finding 2022-019. Recommendation: We recommend NDA implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Department of Agriculture agrees with this finding.

U.S. Department of Labor Unemployment Insurance, 17.225 COVID-19 Unemployment Insurance, 17.225 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award 23A55UI039335-01 included under assistance listing 17.225 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 underlying accounting information or performance records, and are fairly presented in accordance with governing requirements. The Nevada Department of Employment, Training and Rehabilitation (DETR) must submit the ETA 9130 Financial Status Report, UI Programs. Condition: Amounts reported on the ETA 9130 did not agree to underlying financial records. Cause: DETR did not have adequate internal controls to ensure amounts reported agreed to underlying financial records. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of 12 out of a population of 70 ETA 9130 reports was selected for testing. An error was noted on one of the reports tested as follows: Quarter Ended March 31, 2023 (UI39335OB0) Amount Reported Amount per General Ledger Federal Share of Expenditures $11,551,039 $10,567,850 Repeat Finding from Prior Year: No Recommendation: We recommend DETR enhance the internal controls to ensure amounts reported agree to underlying records. Views of Responsible Officials: The Nevada Department of Employment, Training and Rehabilitation agrees with this finding.

U.S. Department of Labor Unemployment Insurance, 17.225 COVID-19 Unemployment Insurance, 17.225 Special Tests and Provisions – UI Benefit Payments Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards with benefit payments, which are UI EUC, UI Trust Fund, UI Extended Benefits, UI FPUC, UI PEUC, and UIPL 18-20, included under assistance listing 17.225 on the Schedule of Expenditures of Federal Awards. Criteria: State Workforce Agencies are required by 20 CFR section 602.11(d) to operate and maintain a quality control system. The Benefits Accuracy Measurement (BAM) program is the quality control system designed to assess the accuracy of UI benefit payments and denied claims. The State’s BAM unit is required to draw a weekly sample of payments and denied claims, complete prompt and indepth investigations to determine the degree of accuracy in the administration of the program. The requirements are promulgated in the ET Handbook No. 395 (Handbook). Department of Labor ET Handbook 395, Part VI, Section 11 Completion of Cases and Timely Data Entry states that a minimum of 70% of cases must be completed within 60 days of the week ending date of the batch, and 95% of cases must be completed within 90 days of the week ending batch; and a minimum of 98% of cases for the year must be completed within 120 days of the ending date of the calendar year. Condition: The minimum standards of BAM case completion were not met. Cause: The Nevada Department of Employment, Training and Rehabilitation (DETR) did not have adequate internal controls to ensure BAM timeliness requirements were met. Effect: A BAM investigation may not detect an error timely. Questioned Costs: None Context/Sampling: The following is a summary of the BAM case completion percentages that were not met for calendar year 2022: 90-day completion requirements Paid claims require 95% completion, actual was 85.19%. Denied separation claims require 85% completion, actual was 84.21%. 120-day completion requirements Paid claims require 98% completion, actual was 93.46%. Denied separation claims require 98%, actual was 92.76%. Denied non-separation claims require 98%, actual was 93.63%. Repeat Finding from Prior Year: Yes – prior year finding 2022-021. Recommendation: We recommend DETR enhance internal controls to ensure BAM timeliness requirements are met. Views of Responsible Officials: The Nevada Department of Employment, Training and Rehabilitation agrees with this finding.

U.S. Department of Labor Unemployment Insurance, 17.225 COVID-19 Unemployment Insurance, 17.225 Special Tests and Provisions – UI Benefit Payments Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards with benefit payments, which are UI EUC, UI Trust Fund, UI Extended Benefits, UI FPUC, UI PEUC, and UIPL 18-20, included under assistance listing 17.225 on the Schedule of Expenditures of Federal Awards. Criteria: State Workforce Agencies are required by 20 CFR section 602.11(d) to operate and maintain a quality control system. The Benefits Accuracy Measurement (BAM) program is the quality control system designed to assess the accuracy of UI benefit payments and denied claims. The State’s BAM unit is required to draw a weekly sample of payments and denied claims, complete prompt and indepth investigations to determine the degree of accuracy in the administration of the program. The requirements are promulgated in the ET Handbook No. 395 (Handbook). Department of Labor ET Handbook 395, Part VI, Section 11 Completion of Cases and Timely Data Entry states that a minimum of 70% of cases must be completed within 60 days of the week ending date of the batch, and 95% of cases must be completed within 90 days of the week ending batch; and a minimum of 98% of cases for the year must be completed within 120 days of the ending date of the calendar year. Condition: The minimum standards of BAM case completion were not met. Cause: The Nevada Department of Employment, Training and Rehabilitation (DETR) did not have adequate internal controls to ensure BAM timeliness requirements were met. Effect: A BAM investigation may not detect an error timely. Questioned Costs: None Context/Sampling: The following is a summary of the BAM case completion percentages that were not met for calendar year 2022: 90-day completion requirements Paid claims require 95% completion, actual was 85.19%. Denied separation claims require 85% completion, actual was 84.21%. 120-day completion requirements Paid claims require 98% completion, actual was 93.46%. Denied separation claims require 98%, actual was 92.76%. Denied non-separation claims require 98%, actual was 93.63%. Repeat Finding from Prior Year: Yes – prior year finding 2022-021. Recommendation: We recommend DETR enhance internal controls to ensure BAM timeliness requirements are met. Views of Responsible Officials: The Nevada Department of Employment, Training and Rehabilitation agrees with this finding.

U.S. Department of Transportation Highway Planning and Construction, 20.205 COVID-19 Highway Planning and Construction, 20.205 Special Tests and Provisions – Value Engineering Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 20.205 on the Schedule of Expenditures of Federal Awards. Criteria: The Nevada Department of Transportation (NDOT) is required to establish a value engineering (VE) program and ensure that a VE analysis is performed on all applicable projects. The program should include procedures to approve or reject recommendations and for monitoring to ensure that resulting, approved recommendations are incorporated into the plans, specifications, and estimate. Applicable projects are (a) projects located on the National Highway System (NHS) with an estimated total project cost of $50 million or more that utilize federal high program funding; (b) bridge projects located on the NHS with an estimated total cost of $40 million or more that utilize federal highway program funding; and (c) any other projects that the FHWA determines to be appropriate. Critical elements of VE programs include identification of a state VE coordinator; establishment of a VE policy, and documented VE procedures, including requirements to identify applicable projects, verify required VE analyses are completed on State DOT and subrecipient projects; and monitor, assess, and report on the performance of the VE program as required by 23 CFR part 627. NDOT’s VE policy states that NDOT will conduct VE analysis for all NHS projects costing at least $25 million, to consider VE for projects exceeding $10 million, and to consider VE for all projects, processes, procedures, and standards submitted by district or division heads. Emphasis on value analysis for projects exceeding $10 million does not eliminate consideration of smaller projects that may benefit from value analysis. Condition: A VE analysis was not performed when required by NDOT policy. Cause: The Nevada Department of Transportation (NDOT) did not have adequate internal controls to ensure their VE policy was followed. Effect: A project did not benefit from a value analysis. Questioned Costs: None Context/Sampling: A nonstatistical sample of two projects from a population of seven was selected for testing. One project had an estimated cost of $41 million to $49 million and a VE analysis was performed. The other project had an estimated cost of $34 million to $41 million and a VE analysis was not performed in accordance with NDOT policy. Repeat Finding from Prior Year: No Recommendation: We recommend NDOT enhance internal controls to ensure the VE policy is followed or, if necessary, the VE policy is updated as needed and provided that it complies with federal requirements. Views of Responsible Officials: The Nevada Department of Transportation agrees with this finding.

U.S. Department of Transportation Highway Planning and Construction, 20.205 COVID-19 Highway Planning and Construction, 20.205 Special Tests and Provisions – Value Engineering Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 20.205 on the Schedule of Expenditures of Federal Awards. Criteria: The Nevada Department of Transportation (NDOT) is required to establish a value engineering (VE) program and ensure that a VE analysis is performed on all applicable projects. The program should include procedures to approve or reject recommendations and for monitoring to ensure that resulting, approved recommendations are incorporated into the plans, specifications, and estimate. Applicable projects are (a) projects located on the National Highway System (NHS) with an estimated total project cost of $50 million or more that utilize federal high program funding; (b) bridge projects located on the NHS with an estimated total cost of $40 million or more that utilize federal highway program funding; and (c) any other projects that the FHWA determines to be appropriate. Critical elements of VE programs include identification of a state VE coordinator; establishment of a VE policy, and documented VE procedures, including requirements to identify applicable projects, verify required VE analyses are completed on State DOT and subrecipient projects; and monitor, assess, and report on the performance of the VE program as required by 23 CFR part 627. NDOT’s VE policy states that NDOT will conduct VE analysis for all NHS projects costing at least $25 million, to consider VE for projects exceeding $10 million, and to consider VE for all projects, processes, procedures, and standards submitted by district or division heads. Emphasis on value analysis for projects exceeding $10 million does not eliminate consideration of smaller projects that may benefit from value analysis. Condition: A VE analysis was not performed when required by NDOT policy. Cause: The Nevada Department of Transportation (NDOT) did not have adequate internal controls to ensure their VE policy was followed. Effect: A project did not benefit from a value analysis. Questioned Costs: None Context/Sampling: A nonstatistical sample of two projects from a population of seven was selected for testing. One project had an estimated cost of $41 million to $49 million and a VE analysis was performed. The other project had an estimated cost of $34 million to $41 million and a VE analysis was not performed in accordance with NDOT policy. Repeat Finding from Prior Year: No Recommendation: We recommend NDOT enhance internal controls to ensure the VE policy is followed or, if necessary, the VE policy is updated as needed and provided that it complies with federal requirements. Views of Responsible Officials: The Nevada Department of Transportation agrees with this finding.

U.S. Department of Treasury COVID-19 Emergency Rental Assistance Program, 21.023 Reporting Material Weakness in Internal Control over Compliance and Material 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 (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The OMB Compliance Supplement provides that states are required to submit Quarterly Reports for Emergency Rental Assistance as amended by the Consolidated Appropriations Act of 2021 (ERA1) and Emergency Rental Assistance from the American Rescue Plan Act (ERA2). Condition: Key information was not reported, supporting documentation for amounts that were reported was not maintained, and there was no segregation of duties in the preparation and review of the reports. Cause: The Nevada Housing Division (NHD) did not have internal controls to ensure reports were reviewed, support was maintained, and reports were complete and accurate prior to submission. Effect: Inaccurate and incomplete information was submitted to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of four Quarterly Reports out of a population of eight was selected for testing. The errors for submitted reports are noted as follows: ERA 1 report for the quarter ended September 30, 2022: • $18,096,873 was reported as amounts expended for administrative expenses and was not able to be traced to underlying supporting records. • Amounts expended and/or obligated for administrative expenses exceed 10% of the total allocation. • No amounts were reported for the total obligation and expenditures for housing stability services. As such the housing stability services ratio was not able to be determined. • No amounts were reported for number of households served at certain income levels. • There was no evidence of internal controls (segregation of duties). ERA 1 report for the quarter ended December 31, 2022: • No amounts were reported for administrative costs obligated and expended and award funds obligated or expended. As such the administrative costs ratio was not able to be determined. • No amounts were reported for the total obligation and expenditures for housing stability services. As such the housing stability services ratio was not able to be determined. • Number of households served at certain income levels was not able to be traced to underlying supporting records. • There was no evidence of internal controls (segregation of duties). ERA 2 report for the quarter ended September 30, 2022: • No amounts were reported for administrative costs obligated and expended and award funds obligated or expended. As such the administrative costs ratio was not able to be determined. • No amounts were reported for the total obligation and expenditures for housing stability services. As such the housing stability services ratio was not able to be determined. • No amounts were reported for number of households served at certain income levels. • There was no evidence of internal controls (segregation of duties). ERA 2 report for the quarter ended March 31, 2023: • No amounts were reported for administrative costs obligated and expended and award funds obligated or expended. As such the administrative costs ratio was not able to be determined. • No amounts were reported for the total obligation and expenditures for housing stability services. As such the housing stability services ratio was not able to be determined. • No amounts were reported for number of households served at certain income levels. • There was no evidence of internal controls (segregation of duties). Repeat Finding from Prior Year: Yes – prior year findings 2022-026 and 2022-027. Recommendation: We recommend NHD implement internal controls to ensure reports are reviewed, support is maintained, and reports are complete and accurate prior to submission. Views of Responsible Officials: The Nevada Housing Division agrees with this finding.

U.S. Department of Treasury COVID-19 Emergency Rental Assistance Program, 21.023 Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material 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, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: Pass-through entities ensure every subaward includes certain information at the time of the subaward and the assistance listing number is communicated at the time of disbursement to subrecipients. Pass-through entities evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. In addition, the subrecipient monitoring must ensure that the subaward is used for authorized purposes. Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient takes timely corrective action on all audit findings, as applicable. Condition: Subawards did not contain all the required information, assistance listing numbers were not communicated at the time of disbursement, an evaluation of the subrecipients risk for noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed, adequate active monitoring procedures were not performed, and subrecipient audit reports were not reviewed. Cause: The Nevada Housing Division (NHD) did not have internal controls in place to ensure compliance with subrecipient monitoring requirements. Effect: Noncompliance at the subrecipient level may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of three subrecipients out of a population of four was selected for testing. All three subrecipients were not assessed for risk of noncompliance, award agreements were missing required terms and conditions for a subaward, and there was no evidence active monitoring or review of the audit reports was performed. A nonstatistical sample of four pass-through payments out of a population of 18 was selected for testing. All four pass-through payments tested did not have the assistance listing communicated at the time of disbursement. Repeat Finding from Prior Year: No Recommendation: We recommend NHD enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Nevada Housing Division agrees with this finding.

U.S. Department of Treasury COVID-19 Emergency Rental Assistance Program, 21.023 Special Tests and Provisions – ERA Funds Reallocation Material Weakness Internal Control over Compliance and Material 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 (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Pursuant to 15 USC 9058a(d), Treasury is required to reallocate “excess” ERA 1 award funds. Treasury’s objective in reallocations is to ensure ERA 1 award funds remain available to grantees in accordance with their jurisdictional needs and demonstrated capacity to deliver assistance while the ERA appropriations remain available. The Nevada Housing Division (NHD) was required to submit financial information to Treasury, which were used to calculate various reallocation expenditure ratios. Reallocation expenditure ratios determines whether the grantee is subject to involuntary reallocation due to an insufficient ratio and the amount of excess funds subject to recapture by Treasury. In addition, reallocation ratios were used to determine the eligibility to receive reallocated funds. Condition: NHD did not maintain documentation to support reallocation amounts submitted to Treasury in its application to receive reallocated funds. In addition, there was no segregation of duties in the preparation and review of amounts submitted. Cause: NHD did not have internal controls to ensure supporting documentation for amounts reported to the awarding agency was maintained. Effect: Amounts reported to the federal awarding agency for the reallocation expenditure ratios may be inaccurate, which may have impacted Treasury’s reallocation determination. Questioned Costs: None Context/Sampling: There was no sampling performed. All amounts reported with respect to reallocation were tested. No underlying documentation was available to review to validate any of the amounts reported. Repeat Finding from Prior Year: No Recommendation: We recommend NHD implement internal controls to ensure supporting documentation for amounts reported to the awarding agency is maintained. Views of Responsible Officials: The Nevada Housing Division disagrees with this finding.

U.S. Department of Treasury COVID-19 Homeowner Assistance Fund, 21.026 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 21.026 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) section 200.332 requires that: Pass-through entities ensure every subaward includes certain information at the time of the subaward and that the award’s assistance listing number is identified to the subrecipient at the time of disbursement. Pass-through entities evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Condition: Subawards and disbursements did not contain all the required information, an evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed. Cause: The Nevada Housing Division (NHD) did not have internal controls to ensure compliance with subrecipient monitoring requirements. Effect: Noncompliance at the subrecipient level may occur and not be detected. Questioned Costs: None Context/Sampling: The entire population of one subrecipient was selected for testing, which included one payment. The subaward was missing required information, a risk assessment was not performed, and the payment was missing the assistance listing number. Repeat Finding from Prior Year: Yes – prior year finding 2022-032. Recommendation: We recommend NHD implement internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Nevada Housing Division agrees with this finding.

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 Grant Award Number: Affects all grant awards included 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. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Certain applicable provisions described in Appendix II to Part 200 were not included in contracts as required. Procedures were not followed to verify if an entity was suspended or debarred before entering into a covered transaction. Cause: The Nevada State Purchasing Department (State Purchasing) did not have adequate internal controls to ensure contracts under federal awards contained all of the applicable provisions or to ensure procedures were followed to verify an entity was not suspended or debarred prior to entering into a covered transaction. Effect: Contractors may not be aware of required terms and conditions. A covered transaction may be entered into with an entity or subrecipient that is suspended or debarred. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 procurement transactions out of approximately 1,500 was selected for testing, including 19 contracts subject to Appendix II to Part 200 and to suspension and debarment requirements (transactions that are not within the revenue loss eligible use criteria). Ten out of 19 contracts subject to Appendix II to Part 200 were missing certain required contract provisions. One out of 19 vendors subject to suspension and debarment requirements were not verified for suspension and debarment prior to entering into a covered transaction. Repeat Finding from Prior Year: Yes – prior year finding 2022-034. Recommendation: We recommend State Purchasing enhance internal controls to ensure all contracts under federal awards contain the applicable provisions and procedures are followed to ensure entities are not suspended or debarred prior to entering into covered transactions. Views of Responsible Officials: The Nevada State Purchasing Department agrees with this finding.\

U.S. Department of Treasury COVID-19 Coronavirus State and Local Fiscal Recovery Fund, 21.027 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included 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. The Nevada Governor’s Finance Office (GFO) must submit quarterly Project and Expenditure Reports that contain COVID-19 related costs and obligations incurred during the covered period. Critical information includes: • Current period obligation • Cumulative obligation • Current period expenditure • Cumulative expenditure • Revenue Loss Calculation • Capital Expenditures Condition: Certain amounts included in the reports submitted did not agree to underlying support or underlying support for amounts reported were not maintained. Cause: GFO did not have adequate internal controls to ensure Project and Expenditure Reports were reconciled to underlying supporting documentation. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of two Project and Expenditure Reports from a population of four was selected for testing. Variances were noted as follows for cumulative impacts: Reporting Period Ended September 30, 2022: Amount Reported Amount Supported by Underlying Documentation Current Period Obligations $117,487,595 $96,899,741 Cumulative Obligations $693,688,130 $187,993,359 Reporting Period Ended March 31, 2023: Amount Reported Amount Supported by Underlying Documentation Current Period Obligations $28,208,617 $27,909,659 Cumulative Obligations $939,517,635 $443,459,939 Current Period Expenditures $25,911,692 $57,487,724 Cumulative Expenditures $540,583,461 $556,630,740 Repeat Finding from Prior Year: No Recommendation: We recommend the GFO enhance internal controls to ensure Project Expenditure Reports are reconciled to underlying supporting documentation. Views of Responsible Officials: The Nevada Governor’s Finance Office agrees with this finding.

U.S. Department of Treasury COVID-19 Coronavirus State and Local Fiscal Recovery Fund, 21.027 Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included 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) section 200.332 requires that: Pass-through entities ensure every subaward includes certain information at the time of the subaward and the assistance listing number is communicated at the time of disbursement to subrecipients. Pass-through entities evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient takes timely corrective action on all audit findings, as applicable. Condition: Subawards were not entered into, assistance listing numbers were not communicated at the time of disbursement, an evaluation of the subrecipients risk for noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed, and subrecipient audit reports were not reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following agencies: • Governor’s Finance Office • Department of Agriculture • Aging and Disability Services Division • Division of Public and Behavioral Health Effect: Noncompliance at the subrecipient level may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 30 subrecipients out of a population of 146 across all State agencies was selected for testing. A nonstatistical sample of 60 passthrough payments out of a population of approximately 2,200 was selected for testing. The following errors were noted by agency: Governor’s Finance Office We tested 7 subrecipients applicable to Governors Finance Office and noted a risk assessment was not performed for one of the subrecipients tested. Department of Agriculture We tested 13 pass-through payments applicable to the Department of Agriculture where the assistance listing was required to be communicated. The assistance listing was not communicated at the time of disbursement for seven pass-through payments tested. We tested 14 subrecipients applicable to the Department of Agriculture. A risk assessment was not performed for 12 subrecipients tested, a subaward agreement was not entered into for 11 subrecipients, and the subrecipient single audit report was not reviewed for one subrecipient. Aging and Disability Services Division We tested 2 pass-through payments applicable to the Nevada Aging and Disability Services Division. The assistance listing was not communicated at the time of disbursement for both pass-through payments tested. Division of Public and Behavioral Health We tested 2 pass-through payments applicable to the Division of Public and Behavioral Health. The assistance listing number was not communicated at the time of disbursement for both pass-through payments tested. Repeat Finding from Prior Year: Yes – prior year finding 2022-035. Recommendation: We recommend the State agencies listed above enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The State of Nevada agrees with this finding.

U.S. Department of Education Title I Grants to Local Educational Agencies, 84.010 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.010 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The U.S. Department of Education provides Local Educational Agency (LEA) allocation tables to the Nevada Department of Education (NDE) for basic grants, concentration grants, targeted grants, and education finance incentive grants based on LEA-level data from the Bureau of Census. NDE makes adjustments to those tables for specific items prescribed by 34 CFR section 200 such as: o LEAs not on the census o Hold harmless o Newly opened or significantly expanded charter schools o School improvement funds o State administration Condition: NDE did not maintain the original calculation of adjustments performed to the base LEA allocation tables. The amounts allocated to the LEAs were not supported by documentation maintained by NDE. As part of our audit procedures, we requested NDE reperform the allocation adjustments. NDE reperformed the allocation adjustments but was unable to agree to the original allocations to the LEAs. Cause: NDE did not have sufficient internal controls to ensure supporting documentation of the adjustments and allocations to LEAs was maintained. Effect: LEAs may not receive the appropriate funding allocation. Questioned Costs: None Context/Sampling: The original allocation workbook was not maintained and therefore could not be tested. However, NDE reperformed a new allocation after our request. We noted variances from the reperformed allocation to the original funding allocation across all 19 LEAs as follows: o Basic grants had variances ranging from $11 to $2,896,904. o Concentration grants had variances ranging from $0 to $110,980. o Targeted grants had variances ranging from $2 to $3,439,895. o Finance incentive grants had variances between $1 to $2,539,768. The total amounts allocated were the same in the reperformed allocation when compared to the original allocation. Therefore, the ranges noted above represent both under and over allocation variances to the LEAs. However, the census information (adjustments) used by NDE were not updated from the prior year in the reperformed allocation. Therefore, there is no information available to determine whether allocations to the LEAs were accurate in either the original allocation or reperformed allocation. Repeat Finding from Prior Year: No Recommendation: We recommend NDE enhance internal controls to ensure supporting documentation of the adjustments and allocations to LEAs is maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education Title I Grants to Local Educational Agencies, 84.010 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 84.010 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. A Local Educational Agency (LEA) may receive funds under Title I only if the State Educational Agency (SEA) finds that the combined fiscal effort per student or the aggregate expenditures of the LEA from State and local funds for free public education for the preceding year was not less than 90 percent of the combined fiscal effort or aggregate expenditures for the second preceding year, unless specifically waived by the U.S. Department of Education (34 CFR section 299.5). Condition: The Nevada Department of Education (NDE) did not maintain documentation, compiled from reports submitted by the LEAs, to monitor LEA compliance. As part of our audit procedures, we requested NDE compile the information to determine whether LEAs had met their fiscal effort requirements and whether NDE was required to take any necessary actions for failures to meet the fiscal effort requirements. Cause: NDE did not have sufficient internal controls to ensure maintenance of effort tracking was maintained and reviewed for accuracy and compliance. Effect: Noncompliance with maintenance of effort requirements may not be detected and NDE may not make required funding adjustments. If an LEA fails to maintain fiscal effort, NDE must reduce an LEA’s allocation under Title I if the LEA also failed to maintain effort in one or more of the five immediately preceding fiscal years in the exact proportion by which the LEA fails to maintain effort by falling below 90 percent of both the combined fiscal effort per student and aggregate expenditures. Questioned Costs: None Context/Sampling: NDE compiled expenditure data for 19 LEAs after our request. We reviewed overall compliance for all 19 LEAs and a non-statistical sample of 4 LEAs was selected for testing by tracing to original reports. Amounts included in the calculation for one LEA did not agree to underlying supporting documentation by $2,493. However, this variance did not change the overall conclusion on compliance for the one LEA with its fiscal effort. All 19 LEAs were found to have met their fiscal effort. Repeat Finding from Prior Year: Yes – prior year finding 2022-037. Recommendation: We recommend NDE enhance internal controls to ensure information used in the maintenance of effort monitoring document is maintained and reviewed for accuracy and compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance Grant Award Number: Affects grant award S425U210018 included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides the following requirements: • ESSER o A State Educational Agency (SEA) must allocate at least 90% of ESSER funds to Local Educational Agencies (LEA) using the statutorily prescribed formula. • ARP ESSER o Under section 2001(f) of the ARP act, each SEA must reserve: (1) at least 5% of ARP ESSER funds for evidence-based interventions that address the academic impact of lost instructional time; (2) at least 1% of ARP ESSER funds for evidence-based summer enrichment programs; (3) at least 1% of ARP ESSER funds for evidence-based comprehensive after school programs. • Allowances for Administrative Costs o Under section 18001(e) of the CARES act and section 313(e) of the CRRSA act, an SEA may reserve up to 0.5% of it’s total ESSER I and ESSER II allocations for administrative cost. o Under Section 2001(f)(4) of the ARP Act, an SEA may reserve not more than 0.5% of the state’s total ARP ESSER award for administrative costs. o Under section 312(d)(5) of the CRRSA Act, an SEA may reserve up to 0.5% of its total allocation or up to $200,000, whichever is greater, to administer the EANS program. Condition: The Nevada Department of Education (NDE) did not meet the earmarking set aside for evidence-based summer enrichment programs and evidence-based after school programs. In addition, there is no evidence that compliance with the earmarking requirements (i.e., actual amounts meeting the allocations or that there could be future changes to allocated amounts) is monitored. Cause: NDE did not have adequate internal controls to ensure earmarking requirements were initially met and to ensure on-going compliance was monitored. Effect: Earmarking requirements were not met and may not be met in the future. Questioned Costs: None Context/Sampling: We tested all earmarking computations required to be completed in State fiscal year 2023. There was no evidence of monitoring the earmarking requirements. Under section 2001(f) of the ARP act, each SEA must reserve: (2) at least 1% of ARP ESSER funds for evidence-based summer enrichment programs; (3) at least 1% of ARP ESSER funds for evidence-based comprehensive after school programs. • The minimum amount to allocate to evidence-based summer enrichment programs and evidence-based after school programs was $21,455,664 and the actual amount allocated was $20,040,662. The allocated amounts above were identified and reported in the prior year. However, there was no evidence of adjustments to these allocations in the current year. Repeat Finding from Prior Year: Yes – prior year finding 2022-042. Recommendation: We recommend NDE enhance internal controls to ensure earmarking requirements are initially met and implement internal controls to ensure ongoing compliance is monitored. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: Under section 317 of the CRRSA Act, a state that receives ESSER II, GEER II, or EANS funds under CRRSA Act must: • Maintain state support for elementary and secondary education in fiscal year (FY) 2022 at least at the proportional level of the state’s overall spending, averaged over FYs 2017, 2018, and 2019; and • Maintain state support for higher education in FY 2022 at least at the proportional level of the state’s support for higher education relative to the state’s overall spending, averaged over FYs 2017, 2018, and 2019. Under section 2004(a) of the ARP Act, a state that receives ARP ESSER funds must meet the above maintenance of effort (MOE) requirement in each of FYs 2022 and 2023. The CRRSA and ARP Acts have two MOE baselines: • Elementary and secondary education baseline, which averages the percentages of total spending that are used to support elementary and secondary education over the three baseline years (FYs 2017, 2018, and 2019). • Higher education baseline, which averages percentages of total state spending that are used to support higher education over the three baseline years (FYs 2017, 2018, and 2019). Condition: The Nevada Department of Education (NDE) did not maintain the underlying supporting documentation or reconciliations to support amounts reported for the maintenance of effort requirements. NDE reported state expenditure amounts for elementary and secondary education as well as higher education, with a failure to meet the higher education maintenance of effort. However, as noted above, the amounts reported for state support for elementary and secondary education as well as higher education could not be verified. Lastly, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer of the maintenance of effort calculations. Cause: NDE did not have internal controls to ensure maintenance of effort was tracked, complied with, and supporting documents maintained. Effect: Maintenance of effort requirements may not be met. Questioned Costs: None Context/Sampling: We tested all maintenance of effort computations required to be completed in State fiscal year 2023 (fiscal year 2022 amounts reported in fiscal year 2023). As noted above, the amounts reported could not be verified. However, NDE’s reported amounts indicated that the higher education requirement was not met as follows: State support for higher education • Baseline percentage reported as 15.47% and actual percentage for state fiscal year 2022 was reported as 15.14%. Repeat Finding from Prior Year: Yes – prior year finding 2022-041. Recommendation: We recommend NDE implement internal controls to ensure maintenance of effort is tracked, complied with, and supporting documents maintained. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Education COVID-19 Education Stabilization Fund, 84.425 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 84.425 on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that State Educational Agencies submit annual reports over Governor’s Emergency Education Relief (GEER), Elementary and Secondary School Emergency Relief (ESSER) Grants and Emergency Assistance to Non-Public Schools (EANS). Each report contains data on expenditures, planned expenditures, subrecipients, and use of funds, including for mandatory reservations. Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain amounts included in the annual reports submitted for ESSER and EANS did not agree to underlying support or underlying support for amounts reported were not maintained. In addition, there was no evidence of review and approval (segregation of duties) between the preparer and reviewer of the reports for ESSER, EANS, and GEER. Cause: The Nevada Department of Education (NDE) did not have internal controls to identify required information to be reported, ensure accuracy, or maintain adequate document retention to support compliance. Effect: Inaccurate or incomplete information was reported to the federal awarding agency or was not reported timely. Questioned Costs: None Context/Sampling: All four annual reports required to be filed in the State fiscal year were selected for testing; two reports for ESSER, one for GEER and one for EANS. The errors for the submitted reports were noted as follows: ESSER I Year 3 Annual Report • Amounts reported for key line 5a – full time equivalent positions for Southern Nevada Public Television did not agree to underlying support submitted by the subrecipient. Positions were reported as 75.52 on September 30, 2021 rather than 71.52 as supported by the underlying information provided by the subrecipient (1 of 56 entities reported). ESSER II Year 2 Annual Report • Information reported for key line 3c – Criteria used to Allocate Funds to Schools within LEA for Pershing County School District did not agree to support submitted by the subrecipient (1 of 35 entities reported). • Amounts reported were not supported by underlying documentation (not maintained or unusual variances not reconciled) for key line 5a – full time equivalent positions for White Pine County School District, College of Southern Nevada, Boys Town Nevada, Inc., The Achievement Network, Clark County Public Education Foundation, and Jobs for Nevada’s Graduates (6 of the 35 entities reported). EANS Year 2 Annual Report • There was no underlying documentation or support maintained for any obligation amounts reported in Lines 13a, 13c, 13f, 13h, 13k, and 13l. The aggregate obligations reported were $3,302,124. • Amounts reported for key line 15 – reporting on non-public schools receiving services or assistance under CCRSA EANS for Excel Christian School did not agree to support submitted by the subrecipient. Enrollment for the 19-20 school year was reported as 198 rather than the 191 as supported by the underlying information provided by the subrecipient (1 of 23 entities reported). Lastly, there was no evidence of review and approval (segregation of duties) for the ESSER I Year 3 Annual Report, EANS Year 2 Annual Report, or the GEER Year 2 Annual Report. Repeat Finding from Prior Year: Yes – prior year finding 2022-043. Recommendation: We recommend NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. Views of Responsible Officials: The Nevada Department of Education agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Reporting Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listings 93.575 and 93.596 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 underlying accounting information or performance records, and are fairly presented in accordance with governing requirements. The Division of Welfare and Supportive Services (DWSS) must submit the ACF-696, Child Care and Development Fund Financial Reports quarterly. Condition: Certain amounts reported on the ACF-696 did not agree to underlying documentation. Cause: DWSS did not have internal controls to ensure the amounts reported were adequately documented and supported. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of four reports out of a population of 14 submitted during the audit period was selected for testing. Variances were noted as follows: Quarter Ended September 30, 2022 (FFY2021 – 2101NVCCDF) Amount Reported Amount per General Ledger Line 1d – Direct Services (Col C) $17,839,132 $17,912,019 Quarter Ended March 31, 2023 (FFY2020 – 2001NVCCDF) Amount Reported Amount per General Ledger Line 1 – Total Expenditures (Col B) $16,920,153 $23,235,306 Line 1d – Direct Services (Col B) $15,304,717 $16,294,920 Line 2a – State Expenditures (Col B) $625,234 $6,940,386 Repeat Finding from Prior Year: Yes – prior year finding 2022-053. Recommendation: We recommend DWSS implement internal controls to ensure the amounts reported are adequately documented and supported. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 93.575 and 93.596 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Division of Welfare Supportive Services (DWSS) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS, and, therefore, not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of three out of a population of six applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 3 $135,360,827 Not Reported 3 $135,360,827 Not Timely 3 $135,360,827 Obligation Incorrect 3 $135,360,827 Missing Key Elements 3 $135,360,827 Repeat Finding from Prior Year: Yes – prior year finding 2022-054. Recommendation: We recommend DWSS implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Reporting Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listings 93.575 and 93.596 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 underlying accounting information or performance records, and are fairly presented in accordance with governing requirements. The Division of Welfare and Supportive Services (DWSS) must submit the ACF-696, Child Care and Development Fund Financial Reports quarterly. Condition: Certain amounts reported on the ACF-696 did not agree to underlying documentation. Cause: DWSS did not have internal controls to ensure the amounts reported were adequately documented and supported. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of four reports out of a population of 14 submitted during the audit period was selected for testing. Variances were noted as follows: Quarter Ended September 30, 2022 (FFY2021 – 2101NVCCDF) Amount Reported Amount per General Ledger Line 1d – Direct Services (Col C) $17,839,132 $17,912,019 Quarter Ended March 31, 2023 (FFY2020 – 2001NVCCDF) Amount Reported Amount per General Ledger Line 1 – Total Expenditures (Col B) $16,920,153 $23,235,306 Line 1d – Direct Services (Col B) $15,304,717 $16,294,920 Line 2a – State Expenditures (Col B) $625,234 $6,940,386 Repeat Finding from Prior Year: Yes – prior year finding 2022-053. Recommendation: We recommend DWSS implement internal controls to ensure the amounts reported are adequately documented and supported. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 93.575 and 93.596 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Division of Welfare Supportive Services (DWSS) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS, and, therefore, not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of three out of a population of six applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 3 $135,360,827 Not Reported 3 $135,360,827 Not Timely 3 $135,360,827 Obligation Incorrect 3 $135,360,827 Missing Key Elements 3 $135,360,827 Repeat Finding from Prior Year: Yes – prior year finding 2022-054. Recommendation: We recommend DWSS implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Matching, Level of Effort, and Earmarking Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.596 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Applicable to the matching fund (assistance listing 93.596), state expenditures will be matched at the Federal Medical Assistance Percentage (FMAP) rate for the applicable fiscal year. Private or public donated funds may be counted as state expenditures for this purpose subject to the limitations in 45 CFR section 98.53. Condition: The Division of Welfare and Supportive Services (DWSS) utilizes donated in-kind services from partner agencies and subrecipients to satisfy the match requirement for the matching fund. The in-kind services are cumulatively tracked and applied against the required match. During our audit procedures, we noted instances where the amount reported for matching expenditures did not agree to the in-kind cumulative tracker and instances where the underlying support (certified match letters received from partner agencies and subrecipients) did not agree to the tracker. Cause: DWSS did not have adequate internal controls to ensure the in-kind service match amounts are reconciled and reported accurately. Effect: Inaccurate amounts available for match may be maintained and may impact whether the matching requirement is met. Questioned Costs: None Context/Sampling: The matching fund was tested for the federal fiscal year 2020 matching grant, which had a period performance end of September 30, 2022. The match initially required was $6,252,334 (later adjusted in a final report to $7,233,384). The match reconciled in the cumulative balance tracker was $5,858,548. The match contributed from partner agencies and subrecipients was noted as $28,506,852; however, not all of the amounts tracked agreed to the underlying support. Although, $20,190,154 was agreed to the underlying support, which was sufficient to meet the matching requirement. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS enhance internal controls to ensure in-kind service match amounts are reconciled and reported accurately. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Reporting Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listings 93.575 and 93.596 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 underlying accounting information or performance records, and are fairly presented in accordance with governing requirements. The Division of Welfare and Supportive Services (DWSS) must submit the ACF-696, Child Care and Development Fund Financial Reports quarterly. Condition: Certain amounts reported on the ACF-696 did not agree to underlying documentation. Cause: DWSS did not have internal controls to ensure the amounts reported were adequately documented and supported. Effect: Inaccurate information was reported to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of four reports out of a population of 14 submitted during the audit period was selected for testing. Variances were noted as follows: Quarter Ended September 30, 2022 (FFY2021 – 2101NVCCDF) Amount Reported Amount per General Ledger Line 1d – Direct Services (Col C) $17,839,132 $17,912,019 Quarter Ended March 31, 2023 (FFY2020 – 2001NVCCDF) Amount Reported Amount per General Ledger Line 1 – Total Expenditures (Col B) $16,920,153 $23,235,306 Line 1d – Direct Services (Col B) $15,304,717 $16,294,920 Line 2a – State Expenditures (Col B) $625,234 $6,940,386 Repeat Finding from Prior Year: Yes – prior year finding 2022-053. Recommendation: We recommend DWSS implement internal controls to ensure the amounts reported are adequately documented and supported. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 COVID-19 Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listings 93.575 and 93.596 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Division of Welfare Supportive Services (DWSS) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS, and, therefore, not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of three out of a population of six applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 3 $135,360,827 Not Reported 3 $135,360,827 Not Timely 3 $135,360,827 Obligation Incorrect 3 $135,360,827 Missing Key Elements 3 $135,360,827 Repeat Finding from Prior Year: Yes – prior year finding 2022-054. Recommendation: We recommend DWSS implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Children’s Health Insurance Program (CHIP), 93.767 Medicaid Cluster: State Medicaid Fraud Control Units, 93.775 State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare, 93.777 Medical Assistance Program (Medicaid; Title XIX), 93.778 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.767 and 93.778 on the Schedule of Expenditures of Federal Awards. Criteria: Title 42 Public Health section 435.403 State Residence provides that the State must provide Medicaid to eligible residents of the State, including residents who are absent from the State, except in cases where another state has determined that the person is a resident there for purposes of Medicaid. The Medicaid State Plan provides that the State has an eligibility determination system for data matching through the Public Assistance Reporting Information System (PARIS). The information that is requested is to be exchanged with states and other entities legally entitled to verify Title XIX applications and individuals eligible for covered Title XIX services consistent with applicable PARIS agreements. The State will transmit and receive data quarterly (February, May, August, and November). The State enrolls beneficiaries on a mandatory basis into managed care entities (managed care organizations and/or primary care case managers) in the absence of certain allowable waivers. The State contracts with managed care organizations and reimburses them for capitation payments. Condition: PARIS data was not utilized by the Division of Health Care Financing and Policy (DHCFP) or the Division of Welfare and Supportive Services (DWSS) to monitor residency changes to determine when managed care benefits needed to be terminated because the beneficiary was a resident of another state for Medicaid purposes. Cause: DHCFP and DWSS did not have internal controls in place to effectively communicate the PARIS data between the two agencies to ensure managed care benefits were terminated when appropriate. Effect: Individuals are enrolled in Medicaid (and CHIP) plans in multiple states and benefits are not being terminated timely. Therefore, the State of Nevada is paying capitation payments to managed care organizations, when the benefits should have been terminated. Questioned Costs: Projected questioned costs are $11,108,851 for Medicaid and $139,223 for CHIP. Context/Sampling: No sampling was used. The PARIS data was obtained and examined in total. The PARIS data included 55,251 participants with dual enrollment. Of those 55,251 participants, 8,439 participants were enrolled in another state after the State of Nevada. The projected questioned costs were estimated by performing the following: • Identifying individuals who enrolled in another state after they had enrolled in Nevada (termination date for Nevada). • Estimating a weighted average capitation payment based on demographics that determine the payment amount. • Applying the weighted average capitation payments from the termination date through June 30, 2023 to determine the total projected questioned costs. • The total projected questioned costs were then allocated between Medicaid and CHIP using participant counts in each plan between the ages of 0-18. Participants older than 18 were allocated to Medicaid. The allocated projected questioned costs were then multiplied by a weighted average Federal Medical Assistance Percentage (FMAP) to determine the final projected federal questioned costs. Repeat Finding from Prior Year: Yes – prior year finding 2022-061. Recommendation: We recommend DHCFP and DWSS implement internal controls to effectively communicate the PARIS data between each other and to ensure managed care benefits are terminated when appropriate. Views of Responsible Officials: The Division of Health Care Financing and Policy and the Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Medicaid Cluster: State Medicaid Fraud Control Units, 93.775 State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare, 93.777 Medical Assistance Program (Medicaid; Title XIX), 93.778 Allowable Activities and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.778 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.403 provides that costs must be adequately documented to support the allowability of the cost. Condition: Underlying supporting documentation for certain administrative costs was not maintained by the Division of Health Care Financing and Policy (DHCFP). Cause: DHCFP did not have adequate internal controls to ensure supporting documentation for administrative expenditures was maintained. Effect: Administrative costs were charged to the federal program without appropriate supporting documentation. Questioned Costs: $5,459 Context/Sampling: A nonstatistical sample of 60 transactions ($634,037) out of a population of 4,335 transactions ($134,939,132) was selected for testing. No documentation was available to support seven transactions, totaling $5,459, that were charged to the federal program. These charges included general ledger descriptions of: • Per diem in-state • Annual leave • Building and grounds lease assessment • IT virtual server hosting • IT security assessment Of the seven transactions, five were journal vouchers that did not contain the underlying support for the journal voucher. One transaction was coded as a direct payment voucher and one transaction was coded as an expenditure to a cash receipt (rather than payment voucher). Repeat Finding from Prior Year: No Recommendation: We recommend DHCFP enhance internal controls to ensure supporting documentation for administrative expenditures is maintained. Views of Responsible Officials: The Division of Health Care Financing and Policy agrees with this finding.

U.S. Department of Health and Human Services Medicaid Cluster: State Medicaid Fraud Control Units, 93.775 State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare, 93.777 Medical Assistance Program (Medicaid; Title XIX), 93.778 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.778 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. States are required to determine eligibility in accordance with the eligibility requirements defined in the approved State plan (42 CFR 457). The State plan describes certain aid categories, including the eligibility criteria and potential benefits allowed under the aid categories for eligible individuals. Condition: To enroll in Medicaid, a beneficiary must apply for benefits to the Nevada Division of Welfare and Supportive Services (DWSS). An intake employee will review, timestamp, and input the application or redetermination into a casefile to provide for a second review of the application or redetermination by a supervisor. In certain instances, the application or redetermination was either not properly filed or not maintained to allow for review by a supervisor. Cause: DWSS did not have adequate internal controls to ensure applications and redeterminations were properly documented and maintained. Effect: Individuals may receive benefits that they are not entitled to or not receive benefits for which they are entitled to. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 out of a population of 74,760 Modified Adjusted Gross Income (MAGI) based determinations was selected for testing. Two applications were not properly indexed or maintained in the casefile to allow for review by a supervisor. However, the other supporting documentation was maintained that ultimately supported the eligibility determination and conclusion. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS enhance internal controls to ensure applications and redeterminations are properly documented and maintained. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Medicaid Cluster: State Medicaid Fraud Control Units, 93.775 State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare, 93.777 Medical Assistance Program (Medicaid; Title XIX), 93.778 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 93.778 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 underlying accounting information, and are presented in accordance with program requirements. The Nevada Division of Health Care Financing and Policy (DHCFP) is required to submit Quarterly Medicaid Statement of Expenditures for the Medical Assistance Program (CMS-64) reports based on actual recorded expenditures (42 CFR 430.30). Condition: Amounts reported on the CMS-64 were not supported by the underlying accounting information. Cause: DHCFP did not have adequate internal controls to ensure CMS-64 reports were accurate or supporting documentation for reconciling items was maintained. Effect: Inaccurate information may be reported to the federal awarding agency. Questioned Costs: None Context/Sampling: A nonstatistical sample of two CMS-64 reports out of a population of four was selected for testing. DHCFP has manual adjustments to key line items within the CMS-64 from the general ledger. DHCFP did not maintain a record of any of the manual adjustments and we were unable to verify whether the manual adjustment was appropriate. In total, there were $36,128,957 in manual adjustments in the December 31, 2022 CMS-64 report and $5,364,337 in the March 31, 2023 CMS-64 report that we were unable to verify. Repeat Finding from Prior Year: Yes – prior year finding 2022-062. Recommendation: We recommend DHCFP enhance internal controls to ensure CMS-64 reports are accurate and supporting documentation is maintained. Views of Responsible Officials: The Nevada Division of Health Care Financing and Policy agrees with this finding.

U.S. Department of Health and Human Services Temporary Assistance for Needy Families, 93.558 COVID-19 Temporary Assistance for Needy Families, 93.558 Matching, Level of Effort, and Earmarking Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.558 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. As provided by 45 CFR section 264.1, the average monthly number of families that include an adult or minor child head of household, or the spouse of the head of household, who has received assistance under any state program funded by federal TANF funds for more than 60 countable months (whether or not consecutive) may not exceed 20 percent of the average monthly number of all families to which the state provided assistance during the fiscal year or the immediately preceding fiscal year (but not both), as the state may elect. Condition: The Division of Welfare and Supportive Services (DWSS) compiles the caseload criteria above in a TANF NEON Cash Cases Hardship Report. There was no evidence that this report was approved, reviewed, or otherwise monitored. Cause: DWSS did not have internal controls to ensure caseload earmarking requirements are monitored. Effect: Noncompliance with earmarking requirements may not be detected. Questioned Costs: None Context/Sampling: The caseload report was generated for the entire state fiscal year. The average cases with more than 60 countable months were 0.19% of the total cases for the state fiscal year, which is below the 20% maximum allowed. However, this report is generated internally by DWSS on a quarterly basis (and aggregated to be summarized annually), and there was no evidence of a review being performed. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS enhance internal controls to ensure caseload earmarking requirements are monitored. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Temporary Assistance for Needy Families, 93.558 COVID-19 Temporary Assistance for Needy Families, 93.558 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 93.558 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Division of Welfare and Supportive Services (DWSS) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS, and, therefore, not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of three out of a population of nine applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 3 $1,381,291 Not Reported 3 $1,381,291 Not Timely 3 $1,381,291 Obligation Incorrect 3 $1,381,291 Missing Key Elements 3 $1,381,291 Repeat Finding from Prior Year: No Recommendation: We recommend DWSS implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Temporary Assistance for Needy Families, 93.558 COVID-19 Temporary Assistance for Needy Families, 93.558 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.558 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) section 200.332 requires that: Pass-through entities monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. The Division of Welfare and Supportive Services (DWSS) has developed risk based subrecipient monitoring policies and procedures to provide for reasonable assurance that subrecipients are complying with federal requirements. These policies indicate that DWSS will perform an onsite review at least every three years, with higher risk subrecipients being subjected to increased frequency of review and oversight. Condition: Certain subrecipients were identified as high risk by DWSS and were not subjected to higher frequency monitoring procedures as described by the DWSS policy, such as a desk review or on-site visit. Cause: DWSS did not have adequate internal controls to ensure program staff had adequate capacity to perform monitoring procedures for subrecipients in accordance with DWSS policy. Effect: Noncompliance at the subrecipient level may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of three subrecipients out of a population of nine was selected for testing. Of the three subrecipients selected, two were deemed high risk by DWSS and neither were monitored through desk review or on-site review during the year. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS implement internal controls to ensure program staff have adequate capacity to perform monitoring procedures for subrecipients in accordance with DWSS policy. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Temporary Assistance for Needy Families, 93.558 COVID-19 Temporary Assistance for Needy Families, 93.558 Matching, Level of Effort, and Earmarking Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.558 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. As provided by 45 CFR section 264.1, the average monthly number of families that include an adult or minor child head of household, or the spouse of the head of household, who has received assistance under any state program funded by federal TANF funds for more than 60 countable months (whether or not consecutive) may not exceed 20 percent of the average monthly number of all families to which the state provided assistance during the fiscal year or the immediately preceding fiscal year (but not both), as the state may elect. Condition: The Division of Welfare and Supportive Services (DWSS) compiles the caseload criteria above in a TANF NEON Cash Cases Hardship Report. There was no evidence that this report was approved, reviewed, or otherwise monitored. Cause: DWSS did not have internal controls to ensure caseload earmarking requirements are monitored. Effect: Noncompliance with earmarking requirements may not be detected. Questioned Costs: None Context/Sampling: The caseload report was generated for the entire state fiscal year. The average cases with more than 60 countable months were 0.19% of the total cases for the state fiscal year, which is below the 20% maximum allowed. However, this report is generated internally by DWSS on a quarterly basis (and aggregated to be summarized annually), and there was no evidence of a review being performed. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS enhance internal controls to ensure caseload earmarking requirements are monitored. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Temporary Assistance for Needy Families, 93.558 COVID-19 Temporary Assistance for Needy Families, 93.558 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 93.558 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Division of Welfare and Supportive Services (DWSS) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS, and, therefore, not included on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: A nonstatistical sample of three out of a population of nine applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 3 $1,381,291 Not Reported 3 $1,381,291 Not Timely 3 $1,381,291 Obligation Incorrect 3 $1,381,291 Missing Key Elements 3 $1,381,291 Repeat Finding from Prior Year: No Recommendation: We recommend DWSS implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Temporary Assistance for Needy Families, 93.558 COVID-19 Temporary Assistance for Needy Families, 93.558 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.558 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) section 200.332 requires that: Pass-through entities monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. The Division of Welfare and Supportive Services (DWSS) has developed risk based subrecipient monitoring policies and procedures to provide for reasonable assurance that subrecipients are complying with federal requirements. These policies indicate that DWSS will perform an onsite review at least every three years, with higher risk subrecipients being subjected to increased frequency of review and oversight. Condition: Certain subrecipients were identified as high risk by DWSS and were not subjected to higher frequency monitoring procedures as described by the DWSS policy, such as a desk review or on-site visit. Cause: DWSS did not have adequate internal controls to ensure program staff had adequate capacity to perform monitoring procedures for subrecipients in accordance with DWSS policy. Effect: Noncompliance at the subrecipient level may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of three subrecipients out of a population of nine was selected for testing. Of the three subrecipients selected, two were deemed high risk by DWSS and neither were monitored through desk review or on-site review during the year. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS implement internal controls to ensure program staff have adequate capacity to perform monitoring procedures for subrecipients in accordance with DWSS policy. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Child Support Enforcement, 93.563 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.563 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) section 200.332 requires that: Pass-through entities ensure every subaward includes certain information at the time of the subaward. Condition: Subawards did not contain all the required information. Cause: The Division of Welfare and Supportive Services (DWSS) did not have internal controls to ensure subawards contained all required information. Effect: The subrecipient may not be aware of all requirements and noncompliance could occur. Questioned Costs: None Context/Sampling: A nonstatistical sample of three subrecipients out of a population of 15 was selected for testing. All three subrecipient agreements were missing required elements per 2 CFR 200.332. The items missing from the agreements were: •Federal Award Identification Number •Subrecipient Unique Entity Identifier •Indirect Cost Rate •Federal Award Date Repeat Finding from Prior Year: No Recommendation: We recommend DWSS implement internal controls to ensure subawards contain all required information. Views of Responsible Officials: The Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.568 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain reimbursement requests were not reviewed and approved by an individual independent of the preparation of the request. Cause: The Nevada Division of Welfare and Supportive Services (DWSS) did not have adequate internal controls to ensure all reimbursement requests were reviewed and approved. Effect: Inaccurate reimbursement requests may occur and not detected by DWSS timely. Questioned Costs: None Context/Sampling: A nonstatistical sample of 29 reimbursement requests out of a population of 141 was selected for testing. Six reimbursement requests did not have the evidence of review and approval by an individual independent of the preparation (segregation of duties). Repeat Finding from Prior Year: Yes – prior year finding 2022-047. Recommendation: We recommend DWSS enhance internal controls to ensure all reimbursement requests are reviewed and approved in accordance with the Division’s internal control policy. Views of Responsible Officials: The Nevada Division of Welfare and Supportive agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Eligibility Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.568 on the Schedule of Expenditures of Federal Awards. Criteria: As provided by 42 USC 8624(b)(2), assistance may be provided to: • Households in which one or more individuals are receiving Temporary Assistance for Needy Families (TANF), Supplemental Security Income (SSI), Supplemental Nutrition Assistance Program (SNAP) benefits, or certain needs-tested veterans’ benefits or; • Households with incomes which do not exceed the greater of 150% of the State’s established poverty level, or 60% of the State’s median income. Lower income eligibility criteria may be established, but no household may be excluded solely on the basis of income if the household income is less than 110% of the State’s poverty level. The Low-Income Home Energy Assistance State Plan (State Plan) establishes and describes assistance benefit levels, which provides for the calculation of a Fixed Annual Credit (FAC) and ultimately, the amount of assistance provided. Condition: The amount of assistance to provide was not calculated correctly. Cause: The Nevada Division of Welfare and Supportive Services (DWSS) did not have adequate internal controls to ensure annual and eligible income were correctly reflected. Effect: Benefits were not computed accurately and over disbursed. Questioned Costs: $307 Context/Sampling: A nonstatistical sample of 60 recipients ($66,234 benefits paid) out of a population of 12,285 ($16,985,706 benefits paid) was selected for testing. For one recipient, the annual and eligible income was reflected as $0. However, the annual and eligible income should have been $13,404 as supported by the case file, which impacted the benefit calculation and resulted in the over payment. Repeat Finding from Prior Year: Yes – prior year finding 2022-049. Recommendation: We recommend DWSS enhance internal controls to ensure annual and eligible income is correctly reflected. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 93.568 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 underlying accounting information, and are presented in accordance with program requirements. The Nevada Division of Welfare and Supportive Services (DWSS) is required to submit the LIHEAP Performance Data Form each year, which indicates the amount expected to be carried forward for obligation in the following fiscal year and the planned use of those funds and the sources and uses of LIHEAP funds, respectively. Condition: Amounts reported for weatherization assistance benefits, unobligated funds, and administration costs did not have underlying documentation to support the amount reported. Cause: DWSS did not have adequate internal controls to ensure amounts reported on the LIHEAP Performance DATA Form were appropriately supported. Effect: Inaccurate information may have been reported to the federal awarding agency. Questioned Costs: None Context/Sampling: The one annual report submitted during the audit period was selected for testing. Weatherization Assistance Benefits of $617,842, Unobligated Funds of $286,708, and Administration Costs of $995,181 had no supporting documentation available to show how amounts were determined. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS enhance internal controls to ensure amounts reported on the LIHEAP Performance Data Form are appropriately supported. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects grant awards 2101NVLIEA and 2201NVLIEA 2022G992201 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 underlying accounting information, and are presented in accordance with program requirements. The Nevada Division of Welfare and Supportive Services (DWSS) is required to submit the LIHEAP Carryover and Reallotment Report each year, which indicates the amount expected to be carried forward for obligation in the following fiscal year and the planned use of those funds and the sources and uses of LIHEAP funds, respectively. Condition: The projected unobligated balance (carryover amount) had no underlying documentation or support the amount. Cause: DWSS did not have internal controls to ensure amounts reported on the LIHEAP Carryover and Reallotment Report were adequately documented and supported. Effect: Inaccurate information may have been reported to the federal awarding agency. Questioned Costs: None Context/Sampling: The one annual report submitted during the audit period was selected for testing. The following variances were noted on the report: Amount Reported Amount per Reconciliation Line 1.1 – Current Year payable $15,545,877 $15,012,533 Line 1.3 – Projected unobligated balance $286,709 $999,808 No explanation for the reconciling items between the reconciliation amounts and the amounts ultimately reported were provided. Repeat Finding from Prior Year: Yes – prior year finding 2022-050. Recommendation: We recommend DWSS implement internal controls to ensure amounts reported on the LIHEAP Carryover and Reallotment Report are adequately documented and supported. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects grant awards 2101NVLIEA, 2201NVLIEA 2022G992201, 2301NVLIEA, 2301NVLIEE, and 2101NVE5C6 included under assistance listing 93.568 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Housing Division (NHD) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not include on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: We tested the entire population of 4 subawards obligated during the year. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 4 $1,398,599 Not Reported 4 $1,398,599 Not Timely 4 $1,398,599 Obligation Incorrect 4 $1,398,599 Missing Key Elements 4 $1,398,599 Repeat Finding from Prior Year: Yes – prior year finding 2022-051. Recommendation: We recommend NHD implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Housing Division agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.568 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Certain reimbursement requests were not reviewed and approved by an individual independent of the preparation of the request. Cause: The Nevada Division of Welfare and Supportive Services (DWSS) did not have adequate internal controls to ensure all reimbursement requests were reviewed and approved. Effect: Inaccurate reimbursement requests may occur and not detected by DWSS timely. Questioned Costs: None Context/Sampling: A nonstatistical sample of 29 reimbursement requests out of a population of 141 was selected for testing. Six reimbursement requests did not have the evidence of review and approval by an individual independent of the preparation (segregation of duties). Repeat Finding from Prior Year: Yes – prior year finding 2022-047. Recommendation: We recommend DWSS enhance internal controls to ensure all reimbursement requests are reviewed and approved in accordance with the Division’s internal control policy. Views of Responsible Officials: The Nevada Division of Welfare and Supportive agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Eligibility Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.568 on the Schedule of Expenditures of Federal Awards. Criteria: As provided by 42 USC 8624(b)(2), assistance may be provided to: • Households in which one or more individuals are receiving Temporary Assistance for Needy Families (TANF), Supplemental Security Income (SSI), Supplemental Nutrition Assistance Program (SNAP) benefits, or certain needs-tested veterans’ benefits or; • Households with incomes which do not exceed the greater of 150% of the State’s established poverty level, or 60% of the State’s median income. Lower income eligibility criteria may be established, but no household may be excluded solely on the basis of income if the household income is less than 110% of the State’s poverty level. The Low-Income Home Energy Assistance State Plan (State Plan) establishes and describes assistance benefit levels, which provides for the calculation of a Fixed Annual Credit (FAC) and ultimately, the amount of assistance provided. Condition: The amount of assistance to provide was not calculated correctly. Cause: The Nevada Division of Welfare and Supportive Services (DWSS) did not have adequate internal controls to ensure annual and eligible income were correctly reflected. Effect: Benefits were not computed accurately and over disbursed. Questioned Costs: $307 Context/Sampling: A nonstatistical sample of 60 recipients ($66,234 benefits paid) out of a population of 12,285 ($16,985,706 benefits paid) was selected for testing. For one recipient, the annual and eligible income was reflected as $0. However, the annual and eligible income should have been $13,404 as supported by the case file, which impacted the benefit calculation and resulted in the over payment. Repeat Finding from Prior Year: Yes – prior year finding 2022-049. Recommendation: We recommend DWSS enhance internal controls to ensure annual and eligible income is correctly reflected. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing 93.568 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 underlying accounting information, and are presented in accordance with program requirements. The Nevada Division of Welfare and Supportive Services (DWSS) is required to submit the LIHEAP Performance Data Form each year, which indicates the amount expected to be carried forward for obligation in the following fiscal year and the planned use of those funds and the sources and uses of LIHEAP funds, respectively. Condition: Amounts reported for weatherization assistance benefits, unobligated funds, and administration costs did not have underlying documentation to support the amount reported. Cause: DWSS did not have adequate internal controls to ensure amounts reported on the LIHEAP Performance DATA Form were appropriately supported. Effect: Inaccurate information may have been reported to the federal awarding agency. Questioned Costs: None Context/Sampling: The one annual report submitted during the audit period was selected for testing. Weatherization Assistance Benefits of $617,842, Unobligated Funds of $286,708, and Administration Costs of $995,181 had no supporting documentation available to show how amounts were determined. Repeat Finding from Prior Year: No Recommendation: We recommend DWSS enhance internal controls to ensure amounts reported on the LIHEAP Performance Data Form are appropriately supported. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Low-Income Home Energy Assistance, 93.568 COVID-19 Low-Income Home Energy Assistance, 93.568 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects grant awards 2101NVLIEA, 2201NVLIEA 2022G992201, 2301NVLIEA, 2301NVLIEE, and 2101NVE5C6 included under assistance listing 93.568 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Housing Division (NHD) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS and therefore not include on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: We tested the entire population of 4 subawards obligated during the year. The quantity and subaward obligation errors were noted as follows: Subawards Obligations Total Tested 4 $1,398,599 Not Reported 4 $1,398,599 Not Timely 4 $1,398,599 Obligation Incorrect 4 $1,398,599 Missing Key Elements 4 $1,398,599 Repeat Finding from Prior Year: Yes – prior year finding 2022-051. Recommendation: We recommend NHD implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Views of Responsible Officials: The Nevada Housing Division agrees with this finding.

U.S. Department of Health and Human Services Foster Care – Title IV-E, 93.658 Adoption Assistance, 93.659 Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.658 and 93.659 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that a State must claim federal financial participation for costs associated with a program only in accordance with its approved cost allocation plan. Since cost allocation plans are of a narrative nature, the Federal government needs assurance that the cost allocation plan has been implemented as approved. Condition: Allocation methods used in cost allocation did not agree to the approved cost allocation plan, amounts allocated did not agree to the general ledger, and allocation statistics did not agree to underlying support. Cause: The Nevada Division of Child and Family Services (DCFS) did not have adequate internal controls to ensure costs were allocated accurately and in accordance with the cost allocation plan. Effect: Costs may be charged to the federal programs that do not agree to the cost allocation plan. Questioned Costs: Foster Care - $24,025 Adoption Assistance - $30,475 Context/Sampling: A nonstatistical sample of two out of four quarters was selected for testing (the September 30, 2022 and March 31, 2023 quarters). In summary, errors were noted as follows: • Two allocation methods did not agree to the submitted cost allocation plan. Rural Case Management Contracts are not included within the cost allocation plan and Temporary Staffing Contracts are direct to a different grant per the cost allocation plan, but were actually allocated as a result of RMS. • Total costs allocated (across all programs) in budget account 3145 were overstated by $69,615 in the September 30, 2022 quarter and were understated by $2,297 in the March 31, 2023 quarter when agreeing amounts to the general ledger. • Two allocation statistics did not agree to the underlying supporting documentation that impacted the allocation percentages by 0.32% and .02% for two allocation methods in the March 31, 2023 cost allocation. These ultimately represented an under allocation to federal programs. Repeat Finding from Prior Year: Yes – prior year finding 2022-056. Recommendation: We recommend DCFS enhance internal controls to ensure costs are allocated accurately and in accordance with the cost allocation plan. Views of Responsible Officials: The Nevada Division of Child and Family Services agrees with this finding.

U.S. Department of Health and Human Services Foster Care – Title IV-E, 93.658 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant awards 2301NVFOST and G-2201NVFOST included under assistance listing 93.658 on the Schedule of Expenditures of Federal Awards. Criteria: The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information by the end of the month following the month in which the prime awardee obligates a subgrant award equal to or greater than $30,000. Condition: Required subaward information was not reported timely in the FFATA Subaward Reporting System (FSRS). Cause: The Nevada Division of Child and Family Services (DCFS) did not have internal controls to ensure subaward information was submitted timely in accordance with the FFATA. Effect: Subaward obligations were not reported in the FSRS timely and therefore delayed on the FFATA’s website for public information disclosure. Questioned Costs: None Context/Sampling: We tested the entire population of three subawards greater than $30,000 obligated during the year. The timeliness errors were noted as follows: Subawards Obligations Total Tested 3 $41,017,389 Not Reported - - Not Timely 2 $36,980,730 Obligation Incorrect - - Missing Key Elements - - The obligation date for the non-timely subawards was September 2022 and they were reported in January 2023. Repeat Finding from Prior Year: Yes – prior year finding 2022-057. Recommendation: We recommend DCFS implement internal controls to ensure subaward information is submitted timely in accordance with the FFATA. Views of Responsible Officials: The Nevada Division of Child and Family Services agrees with this finding.

U.S. Department of Health and Human Services Foster Care – Title IV-E, 93.658 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listings 93.658 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) section 200.332 requires that pass-through entities ensure that every subaward includes certain information at the time of the subaward and that the award’s assistance listing number is identified to the subrecipient at the time of disbursement. Condition: The assistance listing number was not identified at the time of disbursement. Cause: The Division of Child and Family Services (DCFS) did not have adequate internal controls to ensure the assistance listing number was communicated on each disbursement to a subrecipient. Effect: The subrecipient may not identify program receipts appropriately. Questioned Costs: None Context/Sampling: A nonstatistical sample of six subrecipient payments out of a population of 24 was selected for testing. The assistance listing number was not communicated on any of the payments. Repeat Finding from Prior Year: Yes – prior year finding 2022-058. Recommendation: We recommend DCFS enhance internal controls to ensure the assistance listing number is communicated on each disbursement to a subrecipient. Views of Responsible Officials: The Nevada Division of Child and Family Services agrees with this finding.

U.S. Department of Health and Human Services Foster Care – Title IV-E, 93.658 Adoption Assistance, 93.659 Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.658 and 93.659 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that a State must claim federal financial participation for costs associated with a program only in accordance with its approved cost allocation plan. Since cost allocation plans are of a narrative nature, the Federal government needs assurance that the cost allocation plan has been implemented as approved. Condition: Allocation methods used in cost allocation did not agree to the approved cost allocation plan, amounts allocated did not agree to the general ledger, and allocation statistics did not agree to underlying support. Cause: The Nevada Division of Child and Family Services (DCFS) did not have adequate internal controls to ensure costs were allocated accurately and in accordance with the cost allocation plan. Effect: Costs may be charged to the federal programs that do not agree to the cost allocation plan. Questioned Costs: Foster Care - $24,025 Adoption Assistance - $30,475 Context/Sampling: A nonstatistical sample of two out of four quarters was selected for testing (the September 30, 2022 and March 31, 2023 quarters). In summary, errors were noted as follows: • Two allocation methods did not agree to the submitted cost allocation plan. Rural Case Management Contracts are not included within the cost allocation plan and Temporary Staffing Contracts are direct to a different grant per the cost allocation plan, but were actually allocated as a result of RMS. • Total costs allocated (across all programs) in budget account 3145 were overstated by $69,615 in the September 30, 2022 quarter and were understated by $2,297 in the March 31, 2023 quarter when agreeing amounts to the general ledger. • Two allocation statistics did not agree to the underlying supporting documentation that impacted the allocation percentages by 0.32% and .02% for two allocation methods in the March 31, 2023 cost allocation. These ultimately represented an under allocation to federal programs. Repeat Finding from Prior Year: Yes – prior year finding 2022-056. Recommendation: We recommend DCFS enhance internal controls to ensure costs are allocated accurately and in accordance with the cost allocation plan. Views of Responsible Officials: The Nevada Division of Child and Family Services agrees with this finding.

U.S. Department of Health and Human Services Children’s Health Insurance Program (CHIP), 93.767 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.767 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. States are required to determine eligibility in accordance with the eligibility requirements defined in the approved State plan (42 CFR 457). The State plan describes certain aid categories, including the eligibility criteria and potential benefits allowed under the aid categories for eligible individuals. Condition: To enroll in CHIP, a beneficiary must apply for benefits to the Nevada Division of Welfare and Supportive Services (DWSS). An intake employee will review, timestamp, and input the application or redetermination into a casefile to provide for a second review of the application or redetermination by a supervisor. A redetermination was not always maintained to allow for the review by a supervisor. Cause: DWSS did not have adequate internal controls to ensure applications and redeterminations were properly documented and maintained. Effect: Individuals may receive benefits that they are not entitled to or not receive benefits for which they are entitled to. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 out of a population of 32,339 eligible participants was selected for testing. One individual did not have an application or redetermination available for review. However, other supporting documentation was maintained that ultimately supported the eligibility determination and conclusion. Repeat Finding from Prior Year: Yes – prior year finding 2022-059. Recommendation: We recommend DWSS enhance internal controls to ensure applications and redeterminations are properly documented and maintained. Views of Responsible Officials: The Nevada Division of Welfare and Supportive Services agrees with this finding.

U.S. Department of Health and Human Services Children’s Health Insurance Program (CHIP), 93.767 Medicaid Cluster: State Medicaid Fraud Control Units, 93.775 State Survey and Certification of Health Care Providers and Suppliers (Title XVIII) Medicare, 93.777 Medical Assistance Program (Medicaid; Title XIX), 93.778 Eligibility Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.767 and 93.778 on the Schedule of Expenditures of Federal Awards. Criteria: Title 42 Public Health section 435.403 State Residence provides that the State must provide Medicaid to eligible residents of the State, including residents who are absent from the State, except in cases where another state has determined that the person is a resident there for purposes of Medicaid. The Medicaid State Plan provides that the State has an eligibility determination system for data matching through the Public Assistance Reporting Information System (PARIS). The information that is requested is to be exchanged with states and other entities legally entitled to verify Title XIX applications and individuals eligible for covered Title XIX services consistent with applicable PARIS agreements. The State will transmit and receive data quarterly (February, May, August, and November). The State enrolls beneficiaries on a mandatory basis into managed care entities (managed care organizations and/or primary care case managers) in the absence of certain allowable waivers. The State contracts with managed care organizations and reimburses them for capitation payments. Condition: PARIS data was not utilized by the Division of Health Care Financing and Policy (DHCFP) or the Division of Welfare and Supportive Services (DWSS) to monitor residency changes to determine when managed care benefits needed to be terminated because the beneficiary was a resident of another state for Medicaid purposes. Cause: DHCFP and DWSS did not have internal controls in place to effectively communicate the PARIS data between the two agencies to ensure managed care benefits were terminated when appropriate. Effect: Individuals are enrolled in Medicaid (and CHIP) plans in multiple states and benefits are not being terminated timely. Therefore, the State of Nevada is paying capitation payments to managed care organizations, when the benefits should have been terminated. Questioned Costs: Projected questioned costs are $11,108,851 for Medicaid and $139,223 for CHIP. Context/Sampling: No sampling was used. The PARIS data was obtained and examined in total. The PARIS data included 55,251 participants with dual enrollment. Of those 55,251 participants, 8,439 participants were enrolled in another state after the State of Nevada. The projected questioned costs were estimated by performing the following: • Identifying individuals who enrolled in another state after they had enrolled in Nevada (termination date for Nevada). • Estimating a weighted average capitation payment based on demographics that determine the payment amount. • Applying the weighted average capitation payments from the termination date through June 30, 2023 to determine the total projected questioned costs. • The total projected questioned costs were then allocated between Medicaid and CHIP using participant counts in each plan between the ages of 0-18. Participants older than 18 were allocated to Medicaid. The allocated projected questioned costs were then multiplied by a weighted average Federal Medical Assistance Percentage (FMAP) to determine the final projected federal questioned costs. Repeat Finding from Prior Year: Yes – prior year finding 2022-061. Recommendation: We recommend DHCFP and DWSS implement internal controls to effectively communicate the PARIS data between each other and to ensure managed care benefits are terminated when appropriate. Views of Responsible Officials: The Division of Health Care Financing and Policy and the Division of Welfare and Supportive Services agrees with this finding.