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 contro...
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.