Corrective Action Plans

Views of responsible officials and planned corrective action: The Authority experienced significant turnover in employees during the year and as a result certain processes were not followed and source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired a new Executive Director who will implement the required safeguards and ensure that the Authority follows it’s the Regulatory Agreements related to the Mortgage Insurance for the Purchase or Refinancing of Existing Multifamily Projects and the HUD compliance requirements to remedy the aforementioned deficiencies. Leonard Spicer, Executive Director, is responsible for implementing this corrective action by December 31, 2023.

Views of responsible officials and planned corrective action: The Authority experienced significant turnover in employees during the year and as a result certain processes were not followed and source documents were misplaced or destroyed. Management agrees with the Auditors' finding and has hired a new Executive Director who will implement the required safeguards and ensure that the Authority follows its Section 8 Administrative Plan and the HUD compliance requirements to remedy the aforementioned deficiencies. Leonard Spicer, Executive Director, is responsible for implementing this corrective action by December 31, 2023.

Reference Number 2022-004, 2022-005, and 2022-006 Finding summary: These three findings all related to specific provider relief fund reporting of lost revenues by the Medical Center. The Medical Center experienced turnover in key accounting staff during the start of 2023 which resulted in the updated option iii reporting for lost revenues. To be modified. The current staff modified the method of calculating loss revenues from the Phase 1 reporting and were unaware of the potential impact on previously reported funding. Errors were also noted in the accumulation of data and in the reporting which was due to inadequate control processes surrounding the review and approval of the computation by someone independent of the calculation process. Corrective Action Plan: We do not anticipate having to complete a future provider relief fund reporting submission. However, for any future federal grant reporting requirements we will implement a process to have an independent individual review the reporting information along with supporting documentation prior to submission of the grant reporting form. The independent review will be documented in writing as to the date and time of the review and approval. Anticipated Completion Date: This will be implemented with the next federal grant reporting.

Reference Number 2022-004, 2022-005, and 2022-006 Finding summary: These three findings all related to specific provider relief fund reporting of lost revenues by the Medical Center. The Medical Center experienced turnover in key accounting staff during the start of 2023 which resulted in the updated option iii reporting for lost revenues. To be modified. The current staff modified the method of calculating loss revenues from the Phase 1 reporting and were unaware of the potential impact on previously reported funding. Errors were also noted in the accumulation of data and in the reporting which was due to inadequate control processes surrounding the review and approval of the computation by someone independent of the calculation process. Corrective Action Plan: We do not anticipate having to complete a future provider relief fund reporting submission. However, for any future federal grant reporting requirements we will implement a process to have an independent individual review the reporting information along with supporting documentation prior to submission of the grant reporting form. The independent review will be documented in writing as to the date and time of the review and approval. Anticipated Completion Date: This will be implemented with the next federal grant reporting.

Reference Number 2022-004, 2022-005, and 2022-006 Finding summary: These three findings all related to specific provider relief fund reporting of lost revenues by the Medical Center. The Medical Center experienced turnover in key accounting staff during the start of 2023 which resulted in the updated option iii reporting for lost revenues. To be modified. The current staff modified the method of calculating loss revenues from the Phase 1 reporting and were unaware of the potential impact on previously reported funding. Errors were also noted in the accumulation of data and in the reporting which was due to inadequate control processes surrounding the review and approval of the computation by someone independent of the calculation process. Corrective Action Plan: We do not anticipate having to complete a future provider relief fund reporting submission. However, for any future federal grant reporting requirements we will implement a process to have an independent individual review the reporting information along with supporting documentation prior to submission of the grant reporting form. The independent review will be documented in writing as to the date and time of the review and approval. Anticipated Completion Date: This will be implemented with the next federal grant reporting.

Statement of Condition: The Department of Health and Human Services Appropriations Act 2022 restricts the amount of salary to Executive Level II of the Federal Executive pay scale for a full time 12 months total compensation for the grant period from March 2022 to February 2023. Correction Action Planned for 2022-006: The salary of our executive director has consistently adhered to established limits, and our Program and Director of Finance, underscoring the effectiveness of our internal controls, swiftly identified any anomaly. Anticipated Completion Date June 2023

Statement of Condition: The Municipality’s disbursement test, we tested 113 vouchers and found 2 disbursements without System Award Management number or not active. Correction Action Planned for 2022-005: To forestall similar situations in the future, we are actively reviewing and fortifying our supplier’s selection processes while implementing robust contractual measures. It is important to underscore that this response was an exceptional one to address non-compliance, and we are steadfast in our commitment to avoiding such occurrences in the future. Anticipated Completion Date JUNE 2023

Statement of Condition: The Municipality did not submit the required Financial Reports to the US Housing and Urban Development of fiscal year ending June 30, 2022, during the required period. The unaudited Financial Report was not submitted on or before August 31, 2022, also, the audited Financial Report was not submitted on or before September 30, 2022. Correction Action Planned for 2022-004: For the upcoming fiscal year, we are actively seeking a company to provide guidance and assistance in reporting issuance, aiming to streamline and address these processes effectively. Anticipated Completion Date JUNE 2023

Statement of Condition: Preliminary Financial reports and programs financial information were available on August 22, 2023, to prepare the Single Audit Reporting Package. Correction Action Planned for 2022-003: We are actively seeking a company to provide guidance and assistance in report issuance, aiming to streamline and address these processes effectively. Anticipated Completion Date JUNE 2023

Finding 2022-065: Reporting. The Nevada Division of Public and Behavioral Health (DPBH) did not maintain underlying documentation to support the amounts reported in annual and midyear Performance Progress Reports (PPR). Nevada Division of Public and Behavioral Health response: The Nevada Division of Public and Behavioral Health accepts this finding and will initiate corrective action as described below. Corrective Action: The Bureau of Behavioral Health, Wellness, and Prevention (BBHWP) developed a document retention system to ensure subgrantee grant reports and supporting documentation is saved and is easily accessible for each award period. This new system will remove unnecessary barriers for accessing reports moving forward. Date of Completion: BBHWP: December 2023 Responsible Party: BBHWP State Opioid Response Unit: Breanne Van Dyne, Health Program Manager II If you have any questions, please contact Kitty DeSocio, Administrative Services Officer IV at 775-684-3481 or by email at kdesocio@health.nv.gov.

Program: U.S. Department of Health and Human Services Children’s Health Insurance Program (CHIP), 93.767 Eligibility Material Weakness in Internal Control over Compliance Finding Number: 22-059 Finding: Individuals were deemed eligible but were placed in an incorrect aid category or did not have supporting documentation available for review. Individuals may receive benefits that they are not entitled to or not receive benefits for which they are entitled to. The Division did not have adequate internal controls to ensure aid categories were accurate or applications for CHIP were maintained. Prior year finding 2021-056. Corrective Action Taken: HOH UPI XXXXX2000/CHILD UPI XXXXX9100 – Worker failed to complete re-evaluation for higher aid code (REHA function) to obtain correct eligibility. Corrective Action: REHA function was completed on 9/27/2021 to obtain correct eligibility. HOH UPI XXXXX6100/CHILD UPI XXXXX6100 – The Division of Welfare and Supportive Services (Division) did not have adequate internal controls to maintain supporting documentation available for review. Corrective Action: The Division has revised scanning procedures across the state, which includes routing more documents to our vendor for scanning, rather than being retained in each district office. The Division also utilizes an internal team, Records Management Unit (RMU), that assists with Quality Assurance of all scanned documents. HOH UPI XXXXX8000/CHILD UPI XXXXX3200 – The Division did not have adequate internal controls to maintain supporting documentation available for review. Corrective Action: The Division has revised scanning procedures across the state, which includes routing more documents to our vendor for scanning, rather than being retained in each district office. The Division also utilizes an internal team, Records Management Unit (RMU), that assists with Quality Assurance of all scanned documents. Future Corrective Action: The Division will collaborate with all appropriate parties to move from an annual mandatory REHA training to a semiannual mandatory REHA training (every 6 months), for field staff. A new Quality Assurance tip to field staff was provided on 11/10/2022 and an updated mandatory REHA training was administered with a required completion date for all field staff of 02/2023. The next REHA training is scheduled for January/February of 2024. The Division will also continue to follow the updated process for scanning of documents and utilize the RMU for increased Quality Assurance of documents. The Eligibility and Payments (E&P) and Program Operations, Support & Targeted Outreach (POST) teams will work closely with the Internal Controls and Audit team within the Division to ensure internal controls are strengthened. The Division anticipates the internal controls to be updated within two months to reflect the release of a semi-annual REHA training, along with a new annual Quality Assurance REHA tip. Agency Response Does the Agency agree With the findings: Yes If No or Partial, please explain reason(s) why: N/A Individual Responsible for Corrective Action Plan: Name, Title: Tonya Stevens, Social Services Chief III, Eligibility and Payments Phone Number: 775-684-0553 Email: tstevens@dwss.nv.gov Name, Title: Shelly Aguilar, Social Services Chief III, Program Operations, Support & Targeted Outreach Phone Number: 702-631-2337 Email: saguilar@dwss.nv.gov Reviewed and Approved Tonya Stevens, Chief III, Eligibility and Payments

Program: U.S. Department of Health and Human Services Foster Care - Title IV-E, CFDA 93.658 Corrective Action Plan Finding Number: 2022-057 Finding: Required subaward information was not reported in the FFATA Subaward Reporting System (FSRS). Corrective Action Taken or To Be Taken: Internal controls have been reviewed and updated to ensure subaward information is submitted in accordance with FFATA. If already taken, date of completion: Internal control updated in SFY23. If to be taken, estimated date of completion: Agency Response Does the Agency agree with this finding? The Nevada Division of Child and Family Services agrees with this finding. If no or partial, please explain reason(s) why: Additional comments: Prior year finding 2021-055 Division Responsible for Corrective Action Name, Title: Kelsey McCann-Navarro, Social Services Chief III Address: 4126 Techonology Way City, State, Zip Code: Carson City, NV 89706 Phone Number: 775-684-4431 Email: kelsey.navarro@dcfs.nv.gov Reviewed and Approved Tiffany Greenameyer, Deputy Administrator

Audit Finding: 2022-051 Low-Income Home Energy Assistance: 93.568 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: Required subaward information was not reported per the Federal Funding Accountability and Transparency Act (FFATA). 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 $30,000. Recommendation: Implement internal controls to ensure subaward information is submitted in accordance with FFATA. Agency Response: The Nevada Housing Division (“Division”) agrees with the finding. The Division also acknowledges this is a prior year finding. The Division would like to note, and be given consideration for, the substantive fact of the context of the time period in a pandemic, a once in a lifetime crisis that was impacting daily work and personal lives of all Nevadans, including Division staff. Corrective Action: The Division will establish an internal audit and compliance committee to enhance oversight of existing policies for assessing risk (which include verifying suspension or debarment), monitoring and sharing best practices across its business. The internal audit and compliance committee will be responsible for reviewing internal controls and policies on an annual basis, following up on any audit findings and ensuring follow-through of corrective action plans. Adoption of Corrective Action: January 2024 Division Contact and Corrective Action Plan Lead: Christine Hess, Chief Financial Officer Nevada Housing Division 775-687-2249 chess@housing.nv.gov

U.S. Department of Health and Human Services Low Income Home Energy Assistance, 93.568 Finding Number: 2022-048 – Eligibility Material Weakness in Internal Control over Compliance Finding: Supervisor case reviews were not performed in accordance with the State Plan. Corrective Action Taken or To Be Taken: During the review period there were vacancies in both supervisory positions in the Energy Assistance Program. The Division filled these positions during the review period. The supervisory case reviews began for July 2022. In addition, the LIHEAP State Plan has been amended to allow additional staff members to review case work for new staff. The changes were approved at the June 29, 2023, Public Hearing. These changes have been included in the FFY 2024 LIHEAP State Plan to address staff shortages if they arise again. If to be taken, estimated date of completion Corrective Actions are already in place. Agency Response Does the Agency agree with finding: Yes X No Partially Individual Responsible for Corrective Action Plan: Name, Title: Maria Wortman-Meshberger, Chief Employment and Support Services Phone Number: 775-684-0506 Email: mrwortman@dwss.nv.gov Reviewed and Approved Robert H. Thompson, Administrator Date December 19, 2023

Finding number: 2022-050 – Reporting Material Weakness in Internal Control over Compliance Finding: The projected unobligated balance (carryover amount) did not agree to the underlying actual unobligated balance and there was no underlying documentation or support to support the variance. Corrective Action Taken or To Be Taken: Due to multiple staff vacancies, a written procedure for the reporting of Carryover Funds was delayed. Upon completion of those updated procedures in August 2023 in response to prior finding 2021-048, the reporting process for the projected unobligated balance is better understood and the tighter internal controls will ensure adequate documentation and review as required. If to be taken, estimated date of completion: These procedures were implemented August 14, 2023. Agency Response Does the Agency agree With finding: Yes If No or Partial, please Explain reason(s) why: Individual Responsible for Corrective Action Plan: Name, Title: Brooke Barlow, Chief of Fiscal Phone Number: 775-684-0659 Email: bebarlow@dwss.nv.gov Reviewed and Approved: Crystal Buscay, CFO

AUDIT FINDING 2022-062 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 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). Amounts reported on the CMS-64 were not supported by the underlying accounting information. DHCFP did not have adequate internal controls to ensure CMS-64 reports were accurate or supporting documentation for reconciling items was maintained. Inaccurate information may be reported to the federal awarding agency. 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 $91,007,519 in manual adjustments in the December 31, 2021 CMS-64 report and $121,971,786 in the March 31, 2022 CMS-64 report that we were unable to verify. Recommendation: We recommend DHCFP enhance internal controls to ensure CMS-64 reports are accurate and supporting documentation is maintained. Agency Response Does the Agency Agree with Finding?: Yes Additional Comments: None Corrective Action Taken or To Be Taken Action: The Division will enhance internal controls to ensure CMS-64 reports are accurate and supporting documentation is reviewed, reconciled, and maintained. The Division is actively filling vacancies and training staff to ensure reconciliations are perfomred to ensure the integrity of data and reports are correct. Date of Completion or Estimated Completion: December 2024 Department or Agency Responsible for Corrective Action Plan Agency: Department of Healthcare Financing and Policy Contact: Russ Steele, Audit Manager 1000 E William St., Suite 110 Carson City, NV 89701 (775) 684-3609 rsteele@dhcfp.nv.gov Reviewed and Approved 12/15/2023 Signature of Ashwini Prasad, Date Administrative Services Officer 4

CORRECTIVE ACTION PLAN FOR AUDIT FINDING AUDIT FINDING 2022-061 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 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. 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. 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. 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. Projected questioned costs are $12,743,890 for Medicaid and $186,062 for CHIP. No sampling was used. The PARIS data was obtained and examined in total. The PARIS data included 56,892 participants with dual enrollment. Of those 56,892 participants, 9,722 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, 2022 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. 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. Agency Response Does the Agency Agree with Finding?: Yes Additional Comments: None. Corrective Action Taken or To Be Taken Action: The Division is in the process of updating its policies and procedures for its Public Assistance Reporting Information System (PARIS) data matching process, which occurs on a quarterly basis (i.e., once every February, May, August, and November). Currently, the process is primarily a manual caseworker process conducted by caseworker staff at DWSS. However, in many states; this activity is an automated process and considered a program-integrity function of the Medicaid program rather than an eligibility function. Nevada agrees with this practice and intends to implement an automated process, while transitioning the PARIS data matching process to its program-integrity unit at the Division. To do this, the Division will be procuring a vendor to establish a Surveillance and Utilization Review section (SUR) data system, which will include the PARIS data matching process, with new federal funds from the American Rescue Plan Act (ARPA). DHCFP has started the Request for Proposal (RFP) process for this new SUR Data System. DHCFP anticipates a contract start date of January 1, 2024 and an estimated implementation date of December 31, 2024. By automating and streamlining this process in the future, Nevada Medicaid aims to increase the state's capacity to act more quickly on eligibility redeterminations that stem from a PARIS data match finding. In return, this will allow the program to adjust enrollment and payments to managed care plans, more quickly. This adjustment process is fully automated in the Division's Medicaid Management Information System (MMIS) which was certified by CMS in May of 2019. Date of Completion or Estimated Completion: December 31, 2024 Department or Agency Responsible for Corrective Action Plan Agency: Contact: Department of Healthcare Financing and Policy Russ Steele, Audit Manager 1000 E William St., Suite 110 Carson City, NV 89701 (775) 684-3609 rsteele@dhcfp.nv.gov Signature of Sandie Ruybalid, Deputy Administrator

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care and Development Fund, 93.596 Finding Number: 2022-054 – Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Finding: Affects all grant awards included under assistance listings 93.575 and CFDA 93.596 on the Schedule of Expenditures of Federal Awards. 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 $30,000. Corrective Action Taken or To Be Taken:DWSS is currently bringing FFATA reporting up to date. The Grant Procurement Officer has been assigned to enter federal grants following the necessary requirements. Procedures to overcome this finding will be authored and approved by leadership. If to be taken, estimated date of completion: The project’s anticipated completion date is July 1, 2024. Agency Response Does the Agency agree with finding: Yes Individual Responsible for Corrective Action Plan: Name, Title: Gary Long, Chief of FACT Phone Number: 775-684-0655 Email: gxlong@dwss.nv.gov Reviewed and Approved Crystal Buscay, CFO

U.S. Department of Health and Human Services CCDF Cluster: Child Care and Development Block Grant, 93.575 Child Care Mandatory and Matching Funds of the Child Care & Development Fund, 93.596 Finding number: 2022-053 – Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Finding: The Division of Welfare and Support Services (DWSS) did not maintain underlying documentation to support the amounts reported in the ACF-696 reports. Corrective Action Taken or To Be Taken: Due to multiple staff vacancies, reporting documentation had been misfiled in accordance with the Division’s existing internal controls. The Division has added additional internal controls to validate that the fiscal amounts reported on the ACF-696 will have supporting documentation in the applicable state fiscal year and additional guidance will be provided to new staff on those tighter internal controls. If to be taken, estimated date of completion: These procedures were implemented July 1, 2023. Agency Response Does the Agency agree With finding: Yes If No or Partial, please Explain reason(s) why: Individual Responsible for Corrective Action Plan: Name, Title: Brooke Barlow, Chief of Fiscal Phone Number: 775-684-0659 Email: bebarlow@dwss.nv.gov Reviewed and Approved Crystal Buscay, CFO

Finding #2022-044 – Education Stabilization Fund, CFDA 84.425 Reporting – Material Weakness in Internal Control over Compliance and Material Noncompliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE enhance internal controls to ensure subaward information is submitted in accordance with the FFATA. NDE Response At the time of this Corrective Action Plan, NDE has remediated reporting deficiencies under FFATA. Specifically, a new process, to include updated templates, formulas, reporting practices, and crosschecks, has been implemented to accurately and completely capture FFATA reporting requirements. Successful implementation of this process has led to accurate and complete reporting for all COVID-relief funding reports, and pends finalized process documentation. Corrective Action NDE shall develop a comprehensive Policy and Procedure (1.11 FFATA Reporting) documenting the process for the development, review, and finalization of FFATA reports. Supplemental to the Policy and Procedure, NDE shall develop a Business Rule which clearly crosswalks source data to reporting outcomes and explains the use of various templates and formulas. Finally, NDE shall implement internal control monitoring specific to this report upon completion of an internal monitoring assessment. Responsible Parties and Anticipated Completion Date Student Investment Division, Office of Division Compliance; March 1, 2024. Please reach out to Amelia Thibault at sidcompliance@doe.nv.gov with any questions.

Finding #2022-043 – Education Stabilization Fund, CFDA 84.425 Reporting – Material Weakness in Internal Control over Compliance and Material Noncompliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE implement internal controls to identify required information to be reported, ensure accuracy, and maintain adequate document retention to support compliance. NDE Response Due to rapid turnover, changes in assigned personnel, and inconsistent file architecture, NDE has struggled to ensure that source documentation is labeled and retained appropriately. Efforts to ensure consistent business practices within the Student Investment Division are underway. Corrective Action NDE shall develop a comprehensive Policy and Procedure (1.9 Title I ESEA MOE) documenting the process for the development, review, and finalization of the MOE report. Supplemental to the Policy and Procedure, NDE shall develop a Business Rule which clearly crosswalks source data to reporting outcomes. This business rule shall integrate principles from NDE’s Records Management Program, to include clear file architecture for supporting documentation. A checklist detailing the chain of review shall also be implemented to track the review and approval process of federal reports prior to submission. Finally, NDE shall implement internal control monitoring specific to this report upon completion of an internal monitoring assessment. NDE will further review existing internal controls to determine if further support is necessary. The Office of Division Compliance will collaborate with the Office of District Support Services to develop and finalize these documents. Responsible Parties and Anticipated Completion Date Student Investment Division, Offices of District Support Services and Division Compliance; May 1, 2024. Please reach out to Amelia Thibault at sidcompliance@doe.nv.gov with any questions.

Finding #2022-041 – Education Stabilization Fund, CFDA 84.425 Level of Effort, Maintenance of Effort – Significant Deficiency in Internal Control over Compliance and Material Noncompliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE implement internal controls to level of effort is tracked and supporting documents are maintained. NDE Response NDE maintains that the Governor’s Finance Office was responsible for the maintenance of effort for higher education. Evidence of the review process was lost following the departure of a former employee; however, upon becoming aware of the issue, NDE has worked to identify and mitigate the situation to the best of our ability. Corrective Action NDE shall develop a comprehensive Business Rule documenting the process for the development, review, and finalization of the ESF MOE report, to include clear crosswalks between source data and reporting outcomes. This business rule shall integrate principles from NDE’s Records Management Program, to include clear file architecture for supporting documentation. A checklist detailing the chain of review shall also be implemented to track the review and approval process of federal reports prior to submission. Finally, NDE shall implement internal control monitoring specific to this report upon completion of an internal monitoring assessment. NDE will further review existing internal controls to determine if further support is necessary. The Office of Division Compliance will collaborate with offices across the Student Investment Division to develop this documentation. Responsible Parties and Anticipated Completion Date Student Investment Division, Offices of Division Compliance; May 1, 2024. Please reach out to Amelia Thibault at sidcompliance@doe.nv.gov with any questions.

Finding #2022-042 – Education Stabilization Fund, CFDA 84.425 Earmarking – Material Weakness in Internal Control over Compliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE enhance internal controls to ensure earmarking requirements are initially met and implement internal controls to ensure ongoing compliance is monitored. NDE Response At the time of this Corrective Action Plan, NDE is able to demonstrate appropriate earmarking for summer enrichment and after-school programs. Related to earmark monitoring, upon receipt of a grant award, NDE utilizes a Notice of Incoming Funding Form pursuant to Policy and Procedure 10.2 Funding Opportunities; this form and corresponding policy include information regarding the grant funding and support whether an earmarking spreadsheet would be necessary. Corrective Action NDE shall develop a comprehensive Policy and Procedure (10.12 Match, Maintenance of Effort, and Earmarking) documenting the earmarking process, to include monitoring; additional information shall be added to 10.1 Grant Applications and 10.2 Funding Opportunities to ensure smooth establishment of necessary forms related to the funding requirements. Training on these Policies shall be provided across the agency. NDE shall implement internal control monitoring specific to this report upon completion of an internal monitoring assessment. NDE will further review existing internal controls to determine if further support is necessary. The Office of Division Compliance will collaborate with the Office of School and Student Supports to develop and finalize these documents. Responsible Parties and Anticipated Completion Date Student Investment Division, Offices of Division Compliance; Student Achievement Division, Office of Student and School Supports; May 1, 2024. Please reach out to Amelia Thibault at sidcompliance@doe.nv.gov with any questions.

Finding #2022-040 – Title I Grants to Local Education Agencies, CFDA 84.010 Special Tests and Provisions – Material Weakness in Internal Control over Compliance and Material Noncompliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE implement internal controls to ensure appropriate documentation of compliance with section 4306(c) of the ESEA is maintained. NDE Response Due to rapid turnover at NDE and unclear policies related to the digital retention of employee files, NDE lost access to the historical records of ESEA 4306(c) reports from FY18-FY23 following the departure of a former employee. Upon becoming aware of the issue, NDE has worked to identify and mitigate the situation to the best of our ability. Corrective Action NDE shall develop a comprehensive Policy and Procedure (2.2 Title I Earmarking and Hold Harmless Reporting) documenting the process for the development, review, and finalization of the ESEA 4306(c) report. Supplemental to the Policy and Procedure, NDE shall develop a Business Rule which clearly crosswalks source data to reporting outcomes. This business rule shall integrate principles from NDE’s Records Management Program, to include clear file architecture for supporting documentation. A checklist detailing the chain of review shall also be implemented to track the review and approval process of federal reports prior to submission. Finally, NDE shall implement internal control monitoring specific to this report upon completion of an internal monitoring assessment. NDE will further review existing internal controls to determine if further support is necessary. The Office of Division Compliance will collaborate with the Office of School and Student Supports to develop and finalize these documents. In addition, NDE shall review its Policies and Procedures related to email and file retention (4.7 Telecommunications, 4.8 Devices, and 6.6 Records Retention) to ensure that this issue is prevented in future. The Office of Division Compliance will collaborate with the Office of Assessments, Data, and Accountability Management and other applicable NDE Offices to facilitate this process. Responsible Parties and Anticipated Completion Date Student Investment Division, Offices of Division Compliance; Student Achievement Division, Offices of Student and School Supports and Assessment, Data, and Accountability Management; May 1, 2024. Please reach out to Amelia Thibault at sidcompliance@doe.nv.gov with any questions.

Finding #2022-039 – Title I Grants to Local Education Agencies, CFDA 84.010 Reporting – Significant Deficiency in Internal Control over Compliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE enhance internal controls to ensure subaward information is submitted timely in accordance with the FFATA. NDE Response At the time of this Corrective Action Plan, NDE has remediated reporting deficiencies under FFATA. Specifically, a new process, to include updated templates, formulas, reporting practices, and crosschecks, has been implemented to accurately and completely capture FFATA reporting requirements. Successful implementation of this process has led to accurate and complete reporting for FY23 and FY24 reports, and pends finalized process documentation. Corrective Action NDE shall develop a comprehensive Policy and Procedure (1.11 FFATA Reporting) documenting the process for the development, review, and finalization of FFATA reports. Supplemental to the Policy and Procedure, NDE shall develop a Business Rule which clearly crosswalks source data to reporting outcomes and explains the use of various templates and formulas. Finally, NDE shall implement internal control monitoring specific to this report upon completion of an internal monitoring assessment. Responsible Parties and Anticipated Completion Date Student Investment Division, Office of Division Compliance; March 1, 2024. Please reach out to Amelia Thibault at sidcompliance@doe.nv.gov with any questions.