U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award 2133818 under assistance listing 47.047 included within the Research and Development Cluster for UNR as a direct program on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 of U.S. Code of Federal Regulation (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that costs must be, in part: • Necessary and reasonable for the performance of the award • Consistent with policies and procedures that apply uniformly to federally financed and other activities • Adequately documented Condition: An expenditure was incurred and charged to the federal award without initially receiving or maintaining appropriate documentation to support the assertion that the expenditure was necessary and reasonable for performance of the federal award. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure appropriate documentation was initially received or maintained to support an international payment charged to a federal award. Effect: Unallowable costs may be charged to a federal award. Questioned Costs: $3,535 Context/Sampling: A nonstatistical sample of 60 ($739,423) non-payroll expenditures within the Research and Development Cluster across the Nevada System of Higher Education was selected for testing. UNR non-payroll expenditures were 26 ($266,217) of the 60 selected for testing. We noted one non-payroll transaction totaling $3,535 lacked adequate documentation. The transaction was an international wire and an agreement for the services performed, invoice for the services performed, or other appropriate documentation was not maintained. During the audit process, UNR received and subsequently provided a letter from a professor at the foreign University describing the work performed by their colleague. This letter was considered but deemed to lack the adequacy of documentation necessary to support the charge and did not address the initial internal controls necessary to process the initial payment. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure appropriate documentation is received and maintained to support international payments. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards under the Research and Development Cluster for DRI and UNLV 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. Grantors require the submission of Requests for Reimbursement. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. In addition, indirect costs were unintentionally charged at a lower rate than approved. Cause: Desert Research Institute (DRI) and University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to provide for the documented review and approval of Requests for Reimbursement submitted to the grantor. Effect: Inaccurate information may be reported to the grantor, and funds may not be drawn on a reimbursement basis or for immediate cash needs and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 62 Requests for Reimbursement out of a population of 525 across the Nevada System of Higher Education was tested. The following errors were noted by institution: Desert Research Institute 11 requests were selected; nine had no evidence of review by an individual independent of the preparer. All nine requests were made prior to April 30, 2025, while the two requests with review and approval were performed in May 2025 and June 2025. University of Nevada, Las Vegas 17 requests were selected; one request applied an indirect cost rate lower than the approved rate, resulting in an under‑reimbursement of $256. Repeat Finding from Prior Year: Yes – prior year finding 2024-007. Recommendation: We recommend DRI and UNLV enhance internal controls to ensure Requests for Reimbursement are accurately prepared and include documented review and approval. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The University of Nevada, Las Vegas agrees with this finding.
U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR 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 200.332 requires that: • Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. • Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. • Pass-through entities ensure that every subaward includes certain information at the time of the subaward. • Pass-through entities monitor the activities of a 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. • 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 take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessments were not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: • Desert Research Institute (DRI) • Nevada State University (NSU) • University of Nevada, Las Vegas (UNLV) • University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2025 Context/Sampling: A nonstatistical sample of 60 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute DRI had five subrecipients selected for testing out of the sample of 60. • Risk assessment was not performed for one of the subrecipients selected for testing. The subaward period of performance had ended during the year and thus a risk assessment was not deemed necessary by DRI. • Subawards were missing required information for two of the subawards to subrecipients selected for testing. These two subawards were entered into in prior years but had current year payments. We were unable to see subsequent communication (after the initial subawards) that required information had been communicated. • Monitoring activities were not documented adequately to provide for reasonable assurance that two of the subrecipients were using the award for authorized purposes and meeting performance objectives. • Audit reports for one subrecipient were not reviewed timely to ensure a management decision letter would be issued within six months of the clearinghouse acceptance date, if required. Nevada State University NSU had one subrecipient selected for testing out of the sample of 60. • Risk assessment was not performed for the subrecipient selected for testing. University of Nevada, Las Vegas UNLV had 23 subrecipients selected for testing out of the sample of 60. • UNLV does not have written subrecipient monitoring policies. • Risk assessment was not performed for four of the subrecipients selected for testing. • Subawards were missing required information for three of the subawards to subrecipients selected for testing. • Monitoring activities were not documented adequately for 21 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. • Audit reports for five subrecipients were not reviewed timely to ensure a management decision letter would be issued within six months of the clearinghouse acceptance date, if required. University of Nevada, Reno UNR had 30 subrecipients selected for testing out of the sample of 60. • Subawards were missing required information for two of the subawards to subrecipients selected for testing. • Audit reports for two subrecipients were not reviewed timely to ensure a management decision letter would be issued within six months of the clearinghouse acceptance date, if required. Repeat Finding from Prior Year: Yes – prior year finding 2024-009. Recommendation: We recommend UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding. The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Department of Commerce Direct and Pass-through Nevadaworks as listed in the Schedule of Expenditures of Federal Awards Economic Development Cluster, 11.307 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects grant award 077907854 included under assistance listing 11.307 as a direct award for UNLV 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 200.306 requires, in part, that: Cost sharing funds must: • Be verifiable in the recipient's records • Be necessary and reasonable for achieving objectives of the Federal award • Be allowable under subpart E, which requires costs to be: o Consistent with policies and procedures that apply uniformly to federally financed and other activities o Adequately documented o For personnel expenses, documentation must support the distribution of the employee’s salary or wages Condition: Certain costs claimed under cost sharing were not adequately documented or verifiable. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure costs claimed for cost share were adequately documented and verifiable. Effect: Unallowable costs may be used to meet cost sharing requirements. Questioned Costs: $133,988 (cost-sharing) Context/Sampling: A nonstatistical sample of eight ($23,751) cost-share expenditure transactions out of a population of 48 ($144,572) cost-share expenditures were selected for testing at UNLV. Five of the eight transactions consisted of payroll costs that were used for cost share. There was no time and effort documentation to support the actual time spent on the activities to ensure the payroll allocated to cost share was appropriate. We received a summary in the aggregate, noting $110,143 in total payroll was used as cost share. For one transaction, a shared facility in-kind cost at the subrecipient was used for cost sharing, but support to determine the appropriateness of the in-kind valuation was not maintained. We received a summary in the aggregate, noting $23,845 in total for this in-kind valuation was used as cost share. Repeat Finding from Prior Year: No Recommendation: We recommend that UNLV enhance internal controls to ensure costs claimed for cost share are adequately documented and verifiable. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
U.S. Department of Commerce Direct and Pass-through Nevadaworks as listed in the Schedule of Expenditures of Federal Awards Economic Development Cluster, 11.307 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 11.307 for WNC, UNLV, and TMCC 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information. The pass-through entity requires the submission of Requests for Reimbursement. Condition: There was no evidence of review and approval (segregation of duties) between preparer and reviewer. Cause: The following institutions at the Nevada System of Higher Education did not have adequate internal controls to provide for the documented review and approval of reports submitted to the pass-through entity or federal agency: • Western Nevada College (WNC) • Truckee Meadows Community College (TMCC) • University of Nevada, Las Vegas (UNLV) Effect: Inaccurate information may be reported and not detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 14 Requests for Reimbursement out of a population of 96 across the Nevada System of Higher Education was selected for testing. The entire population of one subaward report required by FFATA submitted during the year was selected for testing. The following errors are noted by institution: Western Nevada College Four of the 14 Requests for Reimbursement were applicable to WNC. We noted that there was no evidence of review on one (the August 2024 submission) of the four Requests for Reimbursement that were tested. Truckee Meadows Community College Five of the 14 Requests for Reimbursement were applicable to TMCC. We noted that there was no evidence of review on one (January 2025 submission) of the five Requests for Reimbursement that were tested. University of Nevada, Las Vegas We noted there was no evidence of review for the one subaward report required by the FFATA. Repeat Finding from Prior Year: No Recommendation: We recommend the Nevada System of Higher Education institutions listed above enhance internal controls to provide for the documented review and approval of reports submitted to grantors. Views of Responsible Officials: The Western Nevada College agrees with this finding. The Truckee Meadows Community College agrees with this finding. The University of Nevada, Las Vegas agrees with this finding.
U.S. Department of Commerce Direct and Pass-through Nevadaworks as listed in the Schedule of Expenditures of Federal Awards Economic Development Cluster, 11.307 Subrecipient Monitoring Material Weakness in Internal Controls of Compliance Grant Award Number: Affects grant award 077907854 included under assistance listing 11.307 as a direct award for UNLV 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 200.332 requires that: • Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate 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 take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented and subrecipient audit reports were not reviewed or confirmed to not be required. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls in place to ensure subrecipients obtained required single audits or confirmed they were not required to have one. Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: No sampling was used; there is only one subrecipient applicable to this program. UNLV does not have risk-based monitoring policies for its subrecipients. In addition, for the one subrecipient tested, an inquiry was performed by UNLV to receive the single audit from the subrecipient. There was no documentation available that the subrecipient ever responded to the inquiry or that UNLV concluded the inquiry with whether a single audit was required or not. Repeat Finding from Prior Year: No Recommendation: We recommend that UNLV establish subrecipient monitoring policies and enhance internal controls to ensure subrecipients obtain a required single audit or confirm they are not required to have one. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
U.S. Department of the Interior BLM Fuels Management and Community Fire Assistance Program Activities, 15.228 Period of Performance Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant awards L25AC00118-00 and L24AC00252 included under assistance listing 15.228 as direct awards for UNR 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 non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The terms and conditions of the grant agreements specified that the period of performance began on January 1, 2025 for award L25AC00118-00 and July 1, 2024 for award L24AC00252. Condition: Expenditures charged to the grant were incurred outside of the period of performance. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure that costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($38,351) out of a population of 833 ($309,363) non-payroll expenditures at UNR was selected for testing. We noted two transactions, totaling $642, that were charged to the grant for costs incurred between January 2024 and May 2024, which was prior to the period of performance. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
U.S. Department of the Interior BLM Fuels Management and Community Fire Assistance Program Activities, 15.228 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award L24AC00252 included under assistance listing 15.228 as a direct award for UNR 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure the documented review and approval of subaward information required under the Federal Funding Accountability and Transparency Act (FFATA). Effect: Inaccurate information may be reported and not detected. Questioned Costs: None Context/Sampling: The entire population of one subaward report submitted during the year was selected for testing. We noted there was no evidence of review for the one subaward report required by the FFATA. Repeat Finding from Prior Year: No Recommendation: We recommend that UNR enhance internal controls to ensure the documented review and approval of subaward information required under FFATA. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
U.S. Department of Treasury Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Coronavirus State and Local Fiscal Recovery Fund, 21.027 Reporting Material Weakness in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 21.027 for UNLV and UNR as reported in 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 reporting requirements for subrecipients are as specified by the pass-through entity. The pass-through entities required the submission of Quarterly Progress Reports. Condition: There was no evidence of review and approval (segregation of duties) between the prepare and reviewer. Information reported to the pass‑through entity did not agree with the underlying supporting records. Cause: The following institutions of the Nevada System of Higher Education did not have adequate internal controls to provide for the documented review and approval of reports submitted to the pass-through entity: • University of Nevada, Reno (UNR) • University of Nevada, Las Vegas (UNLV) Effect: Inaccurate information was reported to the pass-through entity by UNLV and inaccurate information may be reported to the pass-through entity by UNR and not detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine Quarterly Progress Reports out of a population of 54 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2025 The following errors were noted by institution: University of Nevada, Las Vegas Four of the nine Quarterly Progress Reports were applicable to UNLV. For all four reports sampled, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer.University of Nevada, Reno Four of the nine Quarterly Progress Reports were applicable to UNR. We noted there was no evidence of review for one of the four Quarterly Progress Reports. Repeat Finding from Prior Year: Yes – prior year finding 2024-014. Recommendation: We recommend UNR and UNLV enhance internal controls to provide for documented review and approval of reports submitted to the pass-through entities and ensure amounts are supported by underlying records. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
U.S. Department of Education Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Career and Technical Education - Basic Grants to States, 84.048 Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 84.048 for GBC as reported in 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: There was no evidence of review and approval (segregation of duties) of certain payroll expenditures charged to the grant. Cause: The Great Basin College (GBC) did not have adequate internal controls to provide for documented review and approval of payroll costs for terminated employees charged to the grant program. Effect: Inaccurate payroll expenses may be recorded to the federal grant and remain undetected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 ($299,78) out of a population of 402 ($1,245,527) payroll expenditures across the Nevada System of Higher Education was selected for testing. GBC payroll expenditures were 15 ($115,473) of the 60 selected for testing. There were two payroll charges ($10,704) for one terminated employee that did not have evidence of review and approval. Repeat Finding from Prior Year: No Recommendation: We recommend GBC enhance internal controls to provide for documented review and approval for terminated employees charged to the grant program. Views of Responsible Officials: The Great Basin College agrees with this finding.
U.S. Department of Education Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Career and Technical Education - Basic Grants to States, 84.048 Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 84.048 for WNC as reported in 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. Grantors require submission of Requests for Reimbursement. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: Western Nevada College (WNC) did not have adequate internal controls to provide for the documented review and approval of Requests for Reimbursement submitted to the pass-through entity. Effect: Funds may not be drawn on a reimbursement basis, for immediate cash needs, or an error may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 16 Requests for Reimbursement out of a population of 102 across the Nevada System of Higher Education was selected for testing. WNC had four Requests for Reimbursement selected for testing of the sample of 16. We noted there was no evidence of review by an individual independent of the preparer for one of the four requests. Repeat Finding from Prior Year: No Recommendation: We recommend WNC enhance internal controls to provide for the documented review and approval of Requests for Reimbursement. Views of Responsible Officials: The Western Nevada College agrees with this finding.
U.S. Department of Education Direct and pass through State of Nevada as listed in the Schedule of Expenditures of Federal Awards Gaining Early Awareness and Readiness for Undergraduate Programs, 84.334 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 84.334 for CSN, GBC, SA, UNLV, UNR, and WNC 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 200.306 requires, in part, that: Cost sharing funds must: • Be verifiable in the recipient's records • Be necessary and reasonable for achieving objectives of the Federal award • Be allowable under subpart E, which requires costs to be: o Consistent with policies and procedures that apply uniformly to federally financed and other activities o Adequately documented o For personnel expenses, documentation must support the distribution of the employee’s salary or wages Condition: Certain costs claimed under cost sharing were not adequately documented or verifiable. Cause: The following institutions did not have adequate internal controls to ensure costs claimed for cost share were adequately documented and verifiable: • College of Southern Nevada (CSN) • Great Basin College (GBC) • System Administration (SA) • University of Nevada, Las Vegas (UNLV) • University of Nevada, Reno (UNR) • Western Nevada College (WNC) Effect: Unallowable costs may be used to meet cost sharing requirements. Questioned Costs: None, several individual institutions did not meet cost sharing requirements; however, the Nevada System of Higher Education met cost share as a whole. Context/Sampling: A nonstatistical sample of 40 ($64,311) cost-share expenditure transactions out of a population of 939 ($1,124,401) cost-share expenditures across the Nevada System of Higher Education were selected for testing. Errors identified by institution are summarized below: College of Southern Nevada Four out of the 40 transactions sampled were for CSN. For 2 of the 4 samples tested, office space usage and facility‑related expenses were included both in the total direct expenses and again recovered through the unrecovered F&A rate. This resulted in unallowable cost share expenses of $5,365. Great Basin College Two out of the 40 transactions sampled were for GBC. For one of the two samples tested, an incorrect annual salary amount was used in the calculation, resulting in unallowable cost share expenses of $60. System Administration Ten out of the 40 transactions sampled were for SA. For three of the ten samples, an incorrect fringe rate was used, resulting in unallowable cost share expenses of $824. University of Nevada, Las Vegas 11 out of the 40 transactions sampled were for UNLV. There was no time and effort documentation to support the actual time spent on the grant activities to ensure the payroll allocated to cost share was appropriate (except for one transaction tested where budgeted hours were utilized when actual time spent was available). In addition, for two of the transactions, the incorrect salary was used. We reviewed the aggregate payroll expenditures claimed noting unallowable cost share of $196,288. University of Nevada, Reno Nine out of 40 transactions sampled were for UNR. For one of the 9 samples, time and effort documentation to support the actual time spent on the grant activities to ensure the payroll allocated to cost share was appropriate was not available. We noted this time and effort was not available for the employee’s allocated annual amount. This resulted in unallowable cost share of $63,300. Western Nevada College One out of the 40 transactions sampled were for WNC. For the one transaction tested, an incorrect fringe rate was used, resulting in unallowable cost share expenses of $188. In the aggregate, we noted $266,025 in questioned costs related to cost share for a lack of supporting documentation. However, the Nevada System of Higher Education as a whole had other allowable expenditures that, in the aggregate, exceeded the overall cost share requirement. Repeat Finding from Prior Year: No Recommendation: We recommend the Nevada System of Higher Education institutions listed above enhance internal controls to ensure amounts used for cost share are adequately documented and verifiable. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. The Great Basin College agrees with this finding. The System Administration agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding. The Western Nevada College agrees with this finding.
U.S. Department of Education Direct and pass through State of Nevada as listed in the Schedule of Expenditures of Federal Awards Gaining Early Awareness and Readiness for Undergraduate Programs, 84.334 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards included under assistance listing 84.334 for CSN, GBC, NSU, TMCC, UNLV, UNR, and WNC, as reported in 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. US Department of Education requires the submission of Annual Performance Reports from direct recipients. The OMB Compliance Supplement provides that reporting requirements for subrecipients are as specified by the pass-through entity. The pass-through entities required the submission of Interim and Final Progress Reports. Condition: Information reported to the federal agency and the pass-through entity did not agree with the underlying supporting records. Cause: The following institutions at the Nevada System of Higher Education (NSHE) did not have adequate internal controls to ensure that amounts reported to the federal agency and pass-through entity were supported by underlying documentation: • College of Southern Nevada (CSN) • Great Basin College (GBC) • Nevada State University (NSU) • Truckee Meadows Community College (TMCC) • University of Nevada, Las Vegas (UNLV) • University of Nevada, Reno (UNR) • Western Nevada College (WNC) Effect: Inaccurate information was reported to the pass-through entity. Questioned Costs: None Context/Sampling: A nonstatistical sample of was selected across the Nevada System of Higher Education as follows: • Interim Progress Reports: Three sampled from a population of ten • Final Progress Reports: Three sampled from a population of ten • Direct Award Progress Reports: All reports out of a population of 3 tested Repeat Finding from Prior Year: No Recommendation: We recommend that the Nevada System of Higher Education institutions listed above enhance their internal controls to ensure that all reports submitted to pass‑through entities are subject to appropriate review and approval, and that all reported amounts are fully supported by the underlying records. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. The Great Basin College agrees with this finding. The Nevada State University agrees with this finding. The Truckee Meadows Community College agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding. The Western Nevada College agrees with this finding.
U.S. Department of Health and Human Services Direct and Pass-through State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Substance Abuse and Mental Health Services Projects of Regional and National Significance, 93.243 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award 1H79SM084442-01 included as a direct award under assistance listing 93.243 for CSN on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 of U.S. Code of Federal Regulation (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that costs must be, in part: • Necessary and reasonable for the performance of the award • Consistent with policies and procedures that apply uniformly to federally financed and other activities • Adequately documented Condition: An expenditure was not necessary or reasonable for the performance of the award and was charged against the program. Cause: The College of Southern Nevada (CSN) did not have adequate internal controls to ensure only necessary and reasonable costs were charged to the grant. Effect: Expenditures that were not related to the federal program were charged to the federal program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($41,027) non-payroll transactions out of a population of 1,265 ($432,891) non-payroll transactions across the Nevada System of Higher Education were selected for testing. CSN non-payroll transactions were 6 ($19,816) of the 60 selected for testing. A flight and related travel agent fee was originally charged to the grant. However, it was later determined by CSN that this was an error and the flight had been booked erroneously as the employee was not attending the training. The flight was refunded and removed from the expenditures charged to the grant. However, the non-refundable travel agent fee ($25) was not adjusted and still charged to the grant. Since the travel was booked in error, the directly associated expense (travel agent fee) is not necessary and reasonable for the program. Repeat Finding from Prior Year: No Recommendation: We recommend CSN enhance internal controls to ensure only necessary and reasonable costs are charged to the grant. Views of Responsible Officials: The College of Southern Nevada agrees with this finding.
U.S. Department of Health and Human Services Direct and Pass-through State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Substance Abuse and Mental Health Services Projects of Regional and National Significance, 93.243 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards passed-through to UNR under assistance listing 93.243 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 Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information. The OMB Compliance Supplement provides that reporting requirements for subrecipients are as specified by the pass-through entity. The pass-through entities required the submission of Quarterly Progress Reports. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and the reviewer. Information reported to the pass-through entity did not agree to underlying supporting records. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to provide for the documented review and approval of quarterly progress reports or subaward information required by the FFATA. In addition, UNR did not have adequate internal controls to ensure amounts reported to the pass-through entity were supported by the underlying records. Effect: Inaccurate information may be reported. Questioned Costs: None Context/Sampling: A nonstatistical sample of two Quarterly Progress Reports was selected from a population of five across the Nevada System of Higher Education. Repeat Finding from Prior Year: No Recommendation: We recommend the UNR enhance internal controls to provide for the documented review and approval of reports submitted to pass-through entities and subaward information required by the FFATA. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
U.S. Department of Health and Human Services Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Epidemiology and Laboratory Capacity for Infectious Diseases, 93.323 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects award SG26176 included under assistance listing 93.323 for UNLV 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 200.332 requires that: • Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. • Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. Condition: Subrecipient monitoring policies are not documented and risk assessment was not performed. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure subrecipient monitoring policies were established and to ensure risk assessments were performed. Effect: Noncompliance may occur at a subrecipient and not be detected by UNLV. Questioned Costs: None Context/Sampling: No sampling was performed, the one subrecipient applicable to the grant was tested. We noted UNLV does not have documented subrecipient monitoring policies and a risk assessment was not performed for the subrecipient. Repeat Finding from Prior Year: No Recommendation: We recommend that UNLV establish subrecipient monitoring policies and enhance internal controls to ensure risk assessments are performed. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
U.S. Department of Health and Human Services Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Epidemiology and Laboratory Capacity for Infectious Diseases, 93.323 Period of Performance Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award SG-2025-00809 included under assistance listing 93.323 for UNR 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 non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The terms and conditions of the grant agreements specified that the period of performance began on August 1, 2024. Condition: Expenditures charged to the grant were incurred outside of the period of performance. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($200,390) non-payroll transactions out of a population of 698 ($1,483,710) across the Nevada System of Higher Education was selected for testing. UNR non-payroll transactions represented for 55 ($184,639) of the 60 transactions selected for testing. We noted two transactions totaling $951 were charged to the grant for services in July 2024. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
U.S. Department of Health and Human Services Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Epidemiology and Laboratory Capacity for Infectious Diseases, 93.323 Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant awards SG-2025-00557 included under assistance listing 93.323 for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 of U.S. Code of Federal Regulation (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that costs must be, in part: • Necessary and reasonable for the performance of the award • Consistent with policies and procedures that apply uniformly to federally financed and other activities • Adequately documented Condition: An incorrect time and effort percentage was used to allocate longevity pay to the grant. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to longevity pay was allocated based on actual time and effort. Effect: Unallowable costs were charged to the program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($283,923) payroll expenditures was selected from a population of 279 ($1,039,323) across the Nevada System of Higher Education was selected for testing. UNR payroll expenditures were 47 ($247,438) out of the 60 selected for testing. We noted one payroll transaction totaling $825 was charged to the grant based on budget estimates rather than the actual time and effort percentage. The amount over-allocated was $46. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure longevity pay is allocated based on actual time and effort. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
U.S. Department of Health and Human Services Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Epidemiology and Laboratory Capacity for Infectious Diseases, 93.323 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 93.323 for UNR 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 controls that provide 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 reporting requirements for subrecipients are as specified by the pass-through entity. The pass-through entity requires the submission of Monthly Activity Reports. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to provide for the documented review and approval of reports submitted to the pass-through entity. Effect: Inaccurate information may be reported to the pass-through entity and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 6 Monthly Activity Reports was selected from a population of 36 at UNR were selected for testing. We noted there was no evidence of review on any of the 6 Monthly Activity Reports tested. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to provide for the documented review and approval of reports submitted to pass-through entities. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
U.S. Department of Health and Human Services Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Block Grant for Community Mental Health Services, 93.958 Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.958 for System-Related Organizations on the Schedule of Expenditures of Federal Awards. Criteria: State cost principle requirements apply to this federal program as it is exempt from the provisions of OMB cost principles. Per the subaward from the State of Nevada, expenditures must comply with any statutory guidelines, the DHHS Grant Instructions and Requirements, and the State Administrative Manual. The subaward indicates that reimbursement is based on actual expenditures incurred during the period being reported. In addition, the DHHS Grant Instructions and Requirements indicates that source documentation for personnel costs includes activity-based timesheets and/or the actual pay stubs that show all the deductions and hours worked by the employee. If the employee is not a 100% funded position, the notations must identify what other funds are paying the additional hours. Condition: Payroll was charged to the grant based on budget estimates for employees that are not 100% funded by the grant. Cause: The System Related Organization of Nevada System of Higher Education – UNLV Health (UNLV Health) did not have adequate internal controls to ensure payroll costs incurred were allocated to the grant based on actual time spent for employees who were only partially charged to the program. Effect: Unallowable costs were charged to the program. Questioned Costs: $63,660 Context/Sampling: A nonstatistical sample of 14 ($41,745) payroll transactions out of a population of 83 ($308,370) at UNLV Health was selected for testing. We noted 11 payroll transactions were allocated based on budget rather than actual time spent. We obtained the aggregate payroll charged to the grant for these employees, noting $63,660 in annual payroll related costs charged to the grant for these specific employees. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV Health enhance internal controls to ensure payroll costs incurred are appropriately allocated to the grant. Views of Responsible Officials: The System Related Organization of Nevada System of Higher Education – UNLV Health agrees with this finding.
U.S. Department of Health and Human Services Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Block Grant for Community Mental Health Services, 93.958 Period of Performance Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.958 for System-Related Organizations 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 non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The terms and conditions of the grant agreements specified that the period of performance began on December 1, 2024. Condition: Expenditures charged to the grant were incurred outside of the period of performance. Cause: The System Related Organization of Nevada System of Higher Education – UNLV Health (UNLV Health) did not have adequate internal controls to ensure costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 14 ($41,745) payroll transactions out of a population of 83 ($308,370) at UNLV Health was selected for testing. We noted one payroll transaction that occurred in November and December 2024. The November pay was not excluded from the grant. Therefore, $722 was charged to the grant for service in November 2024. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV Health enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The System Related Organization of Nevada System of Higher Education – UNLV Health agrees with this finding.
U.S. Department of Health and Human Services Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Block Grant for Community Mental Health Services, 93.958 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Grant Award Number: Affects grant award SG-2025-00677, SG-2025-00820, and SG-26361 included under the under assistance listing 93.958 for UNLV 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 200.332 requires that: • Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. • Pass-through entities monitor the activities of a 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. Condition: Subrecipient monitoring policies are not documented and monitoring of activities was not performed. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure required subrecipient monitoring policies were established and perform monitoring activities. Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: The entire population of three subrecipients/subawards was selected for testing across both UNLV (one) and UNR (two). The following error was noted: University of Nevada, Las Vegas • UNLV does not have written subrecipient monitoring policies. • Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. Repeat Finding from Prior Year: Yes – prior year finding 2024-023. Recommendation: We recommend UNLV establish subrecipient monitoring policies and enhance internal controls to ensure subrecipients are monitored for compliance with award terms and conditions. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
U.S. Department of Education and U.S. Department of Health and Human Services Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Cash Management Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards under assistance listing 84.063 included in the Student Financial Assistance Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: An institution requests funds under the advance, reimbursement, or heighted cash monitoring payment methods. For purposes of determining compliance with cash management requirements to minimize time between funds transfer and disbursement, a disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either Title IV funds or institutional funds used in advance of drawing down federal funds (34 CFR 668.164(a)(1)(i) & (ii)). Under the advance payment method, an institution submits a request for funds. The institution’s request may not exceed the amount of funds the institution needs immediately for disbursements the institution has made or will make to eligible students. The institution must disburse the funds requested as soon as administratively feasible but no later than three business days following the date the institution received those funds (34 CFR 668.162(b)). Condition: Documentation was not maintained to support the cash on hand balances for Pell drawdowns and subsequent disbursements to determine if funds were disbursed within three business days. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure the Pell disbursement roster was retained to support the draw amount and demonstrate compliance with immediate cash needs. Effect: Funds may have been drawn in advance of immediate cash needs. Questioned Costs: None Context/Sampling: A nonstatistical sample of ten out of a population of 64 draw requests was selected for testing. Four of the ten draw requests were related to Pell totaling $15,457,354. UNR was unable to provide support to address immediate cash needs for three of the four draw requests, totaling $14,328,466. However, UNR was able to provide support that the aggregate disbursement of Pell was consistent with total Pell drawdowns for the year. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure the Pell disbursement roster is retained to support the draw request and demonstrate compliance with immediate cash needs. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
U.S. Department of Education and U.S. Department of Health and Human Services Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Eligibility Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards under assistance listing 84.063 under the Student Financial Assistance Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: A student is eligible to receive a Federal Pell Grant for the period of time required to complete his or her first undergraduate baccalaureate course of study. An otherwise eligible student who has a baccalaureate degree and is enrolled in a postbaccalaureate program is eligible to receive a Federal Pell Grant for the period of time necessary to complete the program if: • The postbaccalaureate program consists of courses that are required by a State for the student to receive a professional certification or licensing credential that is required for employment as a teacher in an elementary or secondary school in that State; • The postbaccalaureate program does not lead to a graduate degree; • The institution offering the postbaccalaureate program does not also offer a baccalaureate degree in education; • The student is enrolled as at least a half-time student; and • The student is pursuing an initial teacher certification or licensing credential within the State (34 CFR 690.6). Condition: Pell was disbursed to graduate students who were not eligible as they did not meet the criteria for an allowable exception. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to monitor Pell eligibility for students who were initially enrolled as an undergraduate (for example in the Fall) and re-enrolled as a graduate student within the school year (for example in the Spring). Effect: Over-awards of the Pell Grant were made. Questioned Costs: $3,144 Context/Sampling: A nonstatistical sample of 60 out of a population of 4,289 students who had Title IV disbursements was selected for testing. The total Title IV aid provided in the sample was $571,500, of which $153,212 were Pell Grants (37 students). We noted three students were initially enrolled as an undergraduate student in the Fall 2024 and as a graduate student in Spring 2025. These three graduate students received a Pell Grant totaling $3,144, when they were no longer eligible. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure Pell eligibility is reassessed for students that are initially enrolled as undergraduate and re-enroll as a graduate student within the school year. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
U.S. Department of Education and U.S. Department of Health and Human Services Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Special Tests & Provisions – Return of Title IV (R2T4) Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included in the Student Financial Assistance Cluster for CSN on the Schedule of Expenditures of Federal Awards. Criteria: In accordance with 34 CFR 668.173(b) when a return of Title IV aid is required, an institution has 45 days (or 30 days for students that never began attendance) to return the funds to Ed. Condition: One instance identified in which Title IV funds were not returned within the required allotted time. Cause: The College of Southern Nevada did not have adequate internal controls to ensure funds were returned within the required timeframe. Effect: The U.S. Department of Education did not receive returns timely. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 out of a population of 4,576 student returns was selected for testing. One return of the 60 tested was late. The return occurred after 53 days, rather than the 45 required. Repeat Finding from Prior Year: Yes – prior year finding 2024-011. Recommendation: We recommend CSN enhance internal controls to ensure funds are returned within the required timeframe. Views of Responsible Officials: The College of Southern Nevada agrees with this finding.
U.S. Department of Education and U.S. Department of Health and Human Services Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Special Tests & Provisions – Enrollment Reporting Material Weakness in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included in the Student Financial Assistance Cluster for CSN and NSU on the Schedule of Expenditures of Federal Awards. Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statues, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. Condition: Change in enrollment status was not reported accurately or timely. Cause: The College of Southern Nevada (CSN) did not have adequate internal controls to ensure changes in a student’s enrollment status were correctly reported to the National Student Clearinghouse. The Nevada State University (NSU) did not have adequate internal controls to ensure timely reporting of the change in enrollment status. Effect: Non-timely and inaccurate reporting to the NSLDS could potentially impact future eligibility determinations and repayment provisions. Questioned Costs: None Context/Sampling: For CSN, a nonstatistical sample of 60 out of a population of 3,506 students who had a change in their enrollment status was selected for testing. We noted the date of change for one student was not reported accurately. School records did not agree to the NSLDS by 53 days for the one student. For NSU, a nonstatistical sample of 60 out of a population of 748 students who had a change in their enrollment status was selected for testing. We noted two enrollment status changes were not reported timely. One change was reported after 68 days and the other after 155 days. Repeat Finding from Prior Year: Yes – prior year finding 2024-012 (NSU only). Recommendation: We recommend CSN enhance internal controls to ensure accurate reporting of the change in enrollment status. We recommend NSU enhance internal controls to ensure timely reporting of the change in enrollment status. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. The Nevada State University agrees with this finding.
U.S. Department of Education and U.S. Department of Health and Human Services Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Special Tests & Provisions – Gramm-Leach-Bliley Act – Student Information Security Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included in the Student Financial Assistance Cluster for UNLV on the Schedule of Expenditures of Federal Awards. Criteria: The Gramm-Leach Bliley Act (Public Law 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Tile IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial assistance information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). The GLBA requires, in part, the following safeguards to be addressed in the written information security program: • Encryption of customer information on the institution’s system and when it’s in transit • Implementation of multi-factor authentication for anyone accessing customer information on the institution’s system • Disposition of customer information securely • Maintenance of a log of authorized users’ activity and unauthorized access Condition: The GLBA Information Security Program did not address some of the required safeguards. Cause: Updates were made to the UNLV’s written information security program. However, UNLV did not have adequate internal controls to ensure all required elements under the GLBA were addressed within the updated program. Effect: Certain elements of security required by the GLBA may not be adhered to. Questioned Costs: None Context/Sampling: No sampling was performed. The GLBA Information Security Program for UNLV was reviewed for compliance in its entirety. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV enhance internal controls to ensure all required Gramm-Leach-Bliley Act provisions are included within the written information security program. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.