Corrective Action Plans

Finding 367121 (2022-044)

Material Weakness 2022

State of Nevada

NV

Reporting Subrecipient Monitoring Material Weakness

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 i...

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.

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Finding 367120 (2022-043)

Material Weakness 2022

State of Nevada

NV

Reporting Internal Control / Segregation of Duties Subrecipient Monitoring § 200.303

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 informati...

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.

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Finding 367119 (2022-041)

Material Weakness 2022

State of Nevada

NV

Internal Control / Segregation of Duties Material Weakness Reporting

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 contr...

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.

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Finding 367118 (2022-042)

Material Weakness 2022

State of Nevada

NV

Matching / Level of Effort / Earmarking Subrecipient Monitoring Allowable Costs / Cost Principles

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 im...

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.

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Finding 367117 (2022-040)

Material Weakness 2022

State of Nevada

NV

Special Tests & Provisions Material Weakness Reporting

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.

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Finding 367116 (2022-039)

Material Weakness 2022

State of Nevada

NV

Reporting Subrecipient Monitoring Material Weakness

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 submit...

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.

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Finding 367115 (2022-038)

Significant Deficiency 2022

State of Nevada

NV

Reporting Significant Deficiency

Finding #2022-038 – 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 the State per-Pupil Expenditur...

Finding #2022-038 – 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 the State per-Pupil Expenditure Report is complete accurately. 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 (1.10 F-33 Report, Annual Survey of School System Finances) documenting the process for the development, review, and finalization of the F-33 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.

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Finding 367113 (2022-036)

Material Weakness 2022

State of Nevada

NV

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles

Audit Finding 2022-036: U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Fund, 21.027 Finding: The Nevada Governor’s Finance Office (GFO) did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA. Recommendation: Rec...

Audit Finding 2022-036: U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Fund, 21.027 Finding: The Nevada Governor’s Finance Office (GFO) did not have adequate internal controls to ensure payments to subrecipients were appropriately reported on the SEFA. Recommendation: Recommend the GFO enhance internal controls to ensure payments to subrecipients are appropriately reported on the SEFA. Agency Response: Does the agency Agree with Finding: Yes Additional Comments: None Corrective Action: The GFO will update internal controls related to SEFA reporting to ensure payments to subrecipients are appropriately reported. Date of Completion: June 30, 2024 Department or Agency Responsible for Corrective Action Plan: Agency: Nevada Governor’s Finance Office Contract: Brenda Berry, ASO 200 Musser Street, Ste 200 Carson City, NV 89703 Signature: Amy Stephenson, Director

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Finding 367110 (2022-033)

Material Weakness 2022

State of Nevada

NV

Allowable Costs / Cost Principles Material Weakness Reporting

Audit Finding 2022-033: U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Fund, 21.027 Finding: The maximum allowable expenditures to be spent on government services pursuant to lost public sector revenue was inaccurate. Recommendation: Recommend the Nevada Governor’s Finance...

Audit Finding 2022-033: U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Fund, 21.027 Finding: The maximum allowable expenditures to be spent on government services pursuant to lost public sector revenue was inaccurate. Recommendation: Recommend the Nevada Governor’s Finance Office (GFO) enhance internal controls to ensure the revenue loss calculation is prepared in accordance with the governing requirements. Agency Response: Does the agency Agree with Finding: Yes Additional Comments: Lost revenue was calculated under the Interim Final Rule, which was the guidance available at the time, and was not calculated using the Final Rule’s definition of State revenue. Corrective Action: The GFO will re-calculate revenue loss on a fund-by-fund basis rather than relying on the Census Bureau's Annual Survey of State and Local Government Finances. The Interim Final Rule requested that data used in the calculation must come from the Census Bureau's Annual Survey of State and Local Government Finances, and the revenue used in the calculation must come from the State's own sources. The auditor's recalculation used a microdata file from the State Controller's Office, re-calculating revenue on a fund-by-fund basis rather than relying on the Census Bureau's Annual Survey of State and Local Government Finances. Additionally, the Final Rule's definition of revenue from own sources is more expansive of revenue sources than the Interim Final Rule’s guidance. Date of Completion: Estimated to be completed by January of 2024 Department or Agency Responsible for Corrective Action Plan: Agency: Nevada Governor’s Finance Office Contract: Brenda Berry 200 Musser Street, Ste 200 Carson City, NV 89703 Signature: Amy Stephenson, Director

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Finding 367108 (2022-031)

Material Weakness 2022

State of Nevada

NV

Reporting Subrecipient Monitoring Material Weakness

Audit Finding: 2022-031 Homeowners Assistance Fund: 21.026 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 rec...

Audit Finding: 2022-031 Homeowners Assistance Fund: 21.026 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 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, 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

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Finding 367107 (2022-030)

Significant Deficiency 2022

State of Nevada

NV

Reporting Allowable Costs / Cost Principles Significant Deficiency § 200.303

Audit Finding: 2022-030 Homeowner Assistance Fund: 21.026 Reporting Significant Deficiency in Internal Control over Compliance Summary: There was no evidence that the one-time interim report was reviewed by an individual separate from the preparer. Recommendation: Implement internal controls to ens...

Audit Finding: 2022-030 Homeowner Assistance Fund: 21.026 Reporting Significant Deficiency in Internal Control over Compliance Summary: There was no evidence that the one-time interim report was reviewed by an individual separate from the preparer. Recommendation: Implement internal controls to ensure compliance with subrecipient monitoring requirements. Agency Response: The Division agrees with the 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, 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. This will include ensuring policies and procedures are followed in which reports submitted to federal funders are reviewed by an individual independent of the preparation of the reports. 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

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Finding 367105 (2022-027)

Material Weakness 2022

State of Nevada

NV

Reporting Material Weakness

Audit Finding: 2022-027 Emergency Rental Assistance Program: 21.023 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: Quarterly Reports submitted for ERA2 were not prepared with the same underlying methodology as the ERA1 Quarterly Reports and adequa...

Audit Finding: 2022-027 Emergency Rental Assistance Program: 21.023 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: Quarterly Reports submitted for ERA2 were not prepared with the same underlying methodology as the ERA1 Quarterly Reports and adequate documentation was not available to support the inconsistent reporting. Recommendation: Enhance internal controls to ensure Quarterly Reports are prepared consistently and with appropriate supporting documentation. Agency Response: The 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. Additionally, U.S. Treasury guidance was often confusing and contradictory. Corrective Action: The Division will establish an internal audit and compliance committee. 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 which includes the submission of all required federal reports. 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

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Finding 367104 (2022-026)

Significant Deficiency 2022

State of Nevada

NV

Reporting Internal Control / Segregation of Duties § 200.303

Audit Finding: 2022-026 Emergency Rental Assistance Program: 21.023 Reporting Significant Deficiency in Internal Control over Compliance Summary: There was no review of the SF-425 reports or Quarterly Reports by an individual independent of the preparation of the reports. Recommendation: Implement i...

Audit Finding: 2022-026 Emergency Rental Assistance Program: 21.023 Reporting Significant Deficiency in Internal Control over Compliance Summary: There was no review of the SF-425 reports or Quarterly Reports by an individual independent of the preparation of the reports. Recommendation: Implement internal controls to ensure reports are reviewed prior to submission. Agency Response: The Nevada Housing Division (“Division”) agrees with the 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, 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. This will include ensuring policies and procedures are followed in which reports submitted to federal funders are reviewed by an individual independent of the preparation of the reports. 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

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Finding 367103 (2022-025)

Material Weakness 2022

State of Nevada

NV

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Audit Finding 2022-025: U.S. Department of the Treasury Coronavirus Relief Fund, 21.019 Finding: Assistance listing numbers were not communicated at disbursement and there was no evidence that subrecipient audit reports were monitored. Recommendation: Recommend the Nevada Governor’s Finance Offic...

Audit Finding 2022-025: U.S. Department of the Treasury Coronavirus Relief Fund, 21.019 Finding: Assistance listing numbers were not communicated at disbursement and there was no evidence that subrecipient audit reports were monitored. Recommendation: Recommend the Nevada Governor’s Finance Office (GFO) enhance internal controls to ensure Financial Progress Reports are prepared in accordance with governing requirements. Agency Response: Does the agency Agree with Finding: Yes Additional Comments: None Corrective Action: The corrective action to add the assistance listing number to disbursements was completed approximately January of 2023. The GFO has contracted with a vendor to complete all monitoring of subrecipients. Date of Completion: Estimated completion March 2024. Department or Agency Responsible for Corrective Action Plan: Agency: Nevada Governor’s Finance Office Contract: Brenda Berry 200 Musser Street, Ste 200 Carson City, NV 89703 Signature: Amy Stephenson, Director

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Finding 367103 (2022-025)

Material Weakness 2022

State of Nevada

NV

Subrecipient Monitoring Allowable Costs / Cost Principles Material Weakness

Finding #: 2022-025 – Material Weakness in Internal Control Over Compliance Condition: Assistance listing numbers were not communicated at disbursement Cause: Adequate internal controls were not in place to ensure compliance Effect: Noncompliance at the subrecipient level may occur Corrective Action...

Finding #: 2022-025 – Material Weakness in Internal Control Over Compliance Condition: Assistance listing numbers were not communicated at disbursement Cause: Adequate internal controls were not in place to ensure compliance Effect: Noncompliance at the subrecipient level may occur Corrective Action In February 2023, Court accounting staff were made aware of the need to include the CFDA # on payments made with federal funds and began including the CFDA # as part of the Line Description for all payables transmitted to the State, which was then included on the subrecipients’ remittance advices. If you have any questions, please contact Casandra Vanzura, Chief Accountant, at cvanzura@nvcourts.nv.gov. Sincerely, Todd Myler Chief Financial Officer

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Finding 367102 (2022-024)

Material Weakness 2022

State of Nevada

NV

Reporting Subrecipient Monitoring Material Weakness

Audit Finding 2022-024: U.S. Department of the Treasury Coronavirus Relief Fund, 21.019 Finding: Some expenditures were not reported in the appropriate classification or by vendor. Recommendation: Recommend the Nevada Governor’s Finance Office (GFO) enhance internal controls to ensure Financial P...

Audit Finding 2022-024: U.S. Department of the Treasury Coronavirus Relief Fund, 21.019 Finding: Some expenditures were not reported in the appropriate classification or by vendor. Recommendation: Recommend the Nevada Governor’s Finance Office (GFO) enhance internal controls to ensure Financial Progress Reports are prepared in accordance with governing requirements. Agency Response: Does the agency Agree with Finding: Yes Additional Comments: The GFO relied on the U.S. Department of Treasury guidance, frequently asked questions and other reporting and recordkeeping documents to administer the fund. This information was revised multiple times throughout the grant period, which was extended for an additional year on December 28, 2020, two days before it was to expire in December 2020 causing difficulties in decision determination. It wasn’t until the guidance for the American Rescue Plan Act was received and reviewed that the manner in which the reporting for the payments to state agencies was questioned. Corrective Action: On November 12, 2021, a request was sent to the CARES help desk at U.S. Department of Treasury for clarification regarding state agency reimbursements for COVID related expenditures. This response verified that reporting for state agency reimbursement needed to be completed for each vendor by contract, grant or direct payment over $50,000. Once confirmation was received from U.S. Department of Treasury, the process to determine expenditures by vendor over $50,000 (reporting under contract, direct or grant) for each State Agency Reimbursement Project by Fiscal Year. This analysis was in process while the Single Audit was ongoing and was completed and reported in GrantSolutions for the quarter ending June 2022. The reporting during this quarter was revised to address the finding of payroll costs separated by fiscal year according to the dropdown categories of substantially dedicated public health and safety and administrative leave. These payroll costs were eliminated from the Direct section in the reporting portal to the Aggregate of Direct Payments to Individuals section in the amount of $304,516,094 since the payroll was for the prime recipient. Date of Completion: October 2022 Department or Agency Responsible for Corrective Action Plan: Agency: Nevada Governor’s Finance Office Contract: Brenda Berry 200 Musser Street, Ste 200 Carson City, NV 89703 Signature: Amy Stephenson, Director

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Finding 367099 (2022-021)

Material Weakness 2022

State of Nevada

NV

Internal Control / Segregation of Duties Special Tests & Provisions Allowable Costs / Cost Principles § 200.303

Finding 2022-021 Investigations performed by the UI BAM supervisor or senior investigator are not reviewed by someone other than the investigator. In addition, completion of cases and timely data entry requirements were not met. A nonstatistical sample of 60 completed BAM cases out of a population ...

Finding 2022-021 Investigations performed by the UI BAM supervisor or senior investigator are not reviewed by someone other than the investigator. In addition, completion of cases and timely data entry requirements were not met. A nonstatistical sample of 60 completed BAM cases out of a population of 734 was selected for testing. The investigator and reviewer were the same person for 17 of the cases tested. In addition, a time lapse report of case completion was examined for paid claims accuracy. Of these investigations, 85.19% of the cases were completed within 90 days, rather than the 95% required. In addition, the total completion was 92.12% complete, rather than the 98% completion required. Recommendation We recommend the Department implement internal controls to ensure appropriate segregation of duties on all BAM investigations and to ensure timeliness requirements are met. Nevada DETR’s Response The Employment Security Division’s Unemployment Insurance Support Services (UISS) recognizes the importance of internal controls for a system of checks and balances to ensure no one person has control over all parts of BAM investigations, and to ensure investigation timeliness. Background: BAM timeliness has been impacted since 2020 due to many factors that include but are not limited to significant staff turnover (i.e., retirement, promotions, and recruitment/retainment of qualified staff). Historically, the BAM supervisor PCN 5089 has been tasked with training and reviewing new staff work and activities, which resulted in experienced investigators’ work not being reviewed in attempts to meet timeliness on other BAM cases. Nevada DETR ESD UISS’ Corrective Action Plan: Attached (ATTACHMENT A) is DETR’s Benefit Accuracy Measurement (BAM) Segregation of Duties Internal Control. Estimated Date of Completion: COMPLETED Contact Person: Kristine K. Nelson, ESD Administrator, DETR/ESD (775)684-3828, kknelson@detr.nv.gov

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Finding 367098 (2022-020)

Material Weakness 2022

State of Nevada

NV

Reporting Material Weakness

Finding 2022-020 Amounts reported on the ETA 2112 were misreported by category (benefit type). A nonstatistical sample of four out of 12 monthly reports was selected for testing. Errors were noted on each of the four reports tested as follows: Month Ended July 31, 2021 • Deposit and disbursemen...

Finding 2022-020 Amounts reported on the ETA 2112 were misreported by category (benefit type). A nonstatistical sample of four out of 12 monthly reports was selected for testing. Errors were noted on each of the four reports tested as follows: Month Ended July 31, 2021 • Deposit and disbursement total variances of $29,400. • Off-setting variances in specific benefits ranging from $1,069 to $522,826. Month Ended August 31, 2021 • Off-setting variances in specific benefits ranging from $2,993 to $3,244,522. Month Ended December 31, 2021 • Off-setting variances in specific benefits ranging from $4,785 to $373,125. Month Ended April 30, 2022 • Off-setting variances in specific benefits ranging from $2,992 to $161,515. Recommendation We recommend the Department enhance the internal controls to ensure benefit payments are appropriately categorized by type. Nevada DETR’s Response DETR has revised the current internal control procedure to ensure benefit payments are appropriately categorized by type. Please reference the sections titled “Previous day Adjustments” and “Verify the Draw Request to Treasurer’s Draw Confirmation”. Estimated Date of Completion: COMPLETED Contact Person: Carrie Edlefsen, Chief Financial Officer, DETR/ESD (775)684-3952 c-edlefsen@detr.nv.gov

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Finding 367092 (2022-022)

Significant Deficiency 2022

State of Nevada

NV

Reporting Subrecipient Monitoring Significant Deficiency

Finding 2022-022 Accurate and timely subaward information was not reported in the FFATA Subaward Reporting System (FSRS). A nonstatistical sample of three out of a population of eight applicable subawards obligations during the year was selected for testing: Obligation dates were reported as October...

Finding 2022-022 Accurate and timely subaward information was not reported in the FFATA Subaward Reporting System (FSRS). A nonstatistical sample of three out of a population of eight applicable subawards obligations during the year was selected for testing: Obligation dates were reported as October 1, 2021 for all three subawards rather than August 2, 2021 (two subawards) or September 22, 2021 (one subaward). Recommendation We recommend the Department implement internal controls to ensure subaward information is submitted in accordance with the FFATA. Nevada DETR’s Response DETR-Fiscal Management Unit has established a procedure for FFATA Sub-Contract and Award Reporting. This procedure was placed in effect in May 2023 and will be provided as an attachment to DETR’s corrective action plan. In addition to the newly implemented procedure, internal controls have been updated - the Grants and Projects Analyst will be responsible for implementing this process and ensuring the reports are submitted in accordance with the FFATA. Estimated Date of Completion: COMPLETED Contact Person: Carrie Edlefsen, Chief Financial Officer, DETR/ESD (775)684-3952 c-edlefsen@detr.nv.gov

View Audit 290300

Finding 367086 (2022-019)

Material Weakness 2022

State of Nevada

NV

School Nutrition Programs Reporting Subrecipient Monitoring

Finding 2022-019: U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Wea...

Finding 2022-019: U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance The Nevada Department of Agriculture (NDA) did not have internal controls to ensure subaward information was submitted in accordance with the FFATA. Subaward obligations were not reported in the FSRS and therefore not included on the FFATA’s website for public information disclosure. A nonstatistical sample of 6 out of a population of 54 applicable subaward obligations was selected for testing. The quantity and subaward obligation errors were noted as follows: The NDA accepts these findings and will take corrective action to enhance internal controls to ensure FFATA required information is reported annually. Corrective action: The NDA will begin submitting information in accordance with FFATA at the end of the 2023 award period per direction from the federal partner that annual submittals are in compliance with FFATA for the Child Nutrition Cluster programs. The submittal of information will be done as part of the NDA’s closing procedure for these awards. Date of completion: February 28, 2024

View Audit 290300

Finding 367085 (2022-018)

Significant Deficiency 2022

State of Nevada

NV

School Nutrition Programs Reporting Significant Deficiency

Finding 2022-018: U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Significant ...

Finding 2022-018: U.S. Department of Agriculture Child Nutrition Cluster: School Breakfast Program, 10.553 National School Lunch Program, 10.555 Special Milk Program for Children, 10.556 Summer Food Service Program for Children, 10.559 Fresh Fruit and Vegetable Program, 10.582 Reporting Significant Deficiency in Internal Control over Compliance The Nevada Department of Agriculture (NDA) did not have adequate internal controls to ensure accurate information was reported to the federal awarding agency. Inaccurate information was reported to FNS. A nonstatistical sample of seven out of a population of 36 reports was selected for testing. The October 2021 FNS-10 report includes annual information (rather than monthly). Line 12b – Membership (Enrollment) of Public Schools was reported as 13. The actual enrollment supported by the underlying documentation of public schools was 22. The NDA accepts these findings and will take corrective action to enhance internal controls to ensure amounts reported to FNS are correct. Corrective action: The NDA has new staff completing data entry and certification of these reports in the federal system that have been extensively trained on required federal reporting. NDA will ensure that additional checks and balances are put in place to review the FNS-10 reports to ensure they match up with appropriate data collected. Date of completion: June 30, 2024

View Audit 290300

Finding 367055 (2022-002)

Significant Deficiency 2022

Mental Health & Addiction Association of Oregon

OR

Reporting Subrecipient Monitoring Matching / Level of Effort / Earmarking § 200.329

2.) Finding 2020-002 Report Submission Delay a. Program Information: 17.270 Reentry Employment Opportunities b. Criteria: In accordance with 2 CFR 200.329, non-Federal entities must submit quarterly financial reports at the interval required by the Federal awarding agency or pass-through entity no l...

2.) Finding 2020-002 Report Submission Delay a. Program Information: 17.270 Reentry Employment Opportunities b. Criteria: In accordance with 2 CFR 200.329, non-Federal entities must submit quarterly financial reports at the interval required by the Federal awarding agency or pass-through entity no later than the specified due date. If a justified request is submitted by a non-Federal entity, the Federal agency may extend the due date for any quarterly financial report. c. Condition: During our audit, we identified one quarterly financial report that was submitted to the Contracting Officer’s Representative (COR) after the stated due date. Response: Explanation: This delay was due to an unawareness of process limitations regarding the user application process for the Payment Management System (PMS), which is required for any new Finance Director. A formal application and access request form needs to be submitted along with documentation to support the request for access (including proof of identity, proof of employment, and role confirmation). These conditions, along with the 24-72 hour processing time required to get a user application approved by the PMS providers, led to our one-day-late submission of the required quarterly financial report. Corrective Action: We have established a more proactive approach to managing reporting requirements and a protocol for timely submissions of reports. This includes: - Mandatory PMS application processing as part of the early onboarding process for any new Finance Director. - Early preparation of reports, scheduling reviews a month ahead of the submission deadline. - Direct communication lines with the contract administrators and program directors. - Standard procedures identified to request extensions in case of anticipated delays, specific to each contracting agency. Future Measures: Regular training session for our team are planned to help staff stay informed about reporting requirements, procedures, and deadlines. Contact person responsible for corrective action: John Domingo, Finance & IT Director Compleion date: 07/01/2023

View Audit 290222

Finding 367051 (2022-002)

Significant Deficiency 2022

Housing Authority of the City of West Bend

WI

HUD Housing Programs Eligibility Reporting

Finding 2022-002: Eligibility, Reporting and Special Test and Provision Repeat Finding of Portions of 2021-002 Federal Program: Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numb...

Finding 2022-002: Eligibility, Reporting and Special Test and Provision Repeat Finding of Portions of 2021-002 Federal Program: Section 8 Housing Choice Vouchers Federal Agency: Department of Housing and Urban Development Pass-Through Entity: N/A Assistance Listing Number: 14.871 Federal Award Numbers: N/A Criteria: Per 24 CFR section 982.516, the Housing Authority must conduct a reexamination of family income and composition at least annually. Third-party verification of family income, value of assets, expenses deducted from income, and other factors that affect adjusted income must be obtained and documented. The Housing Authority must determine income eligibility and calculate the tenant's rent payment using the documentation from third-party verification in accordance with 24 CFR part 5 subpart F. The Housing Authority is also required to submit HUD-50058, Family Report, for each examination per 24 CFR part 908. The amount paid for housing assistance payments (HAP) must correspond to HUD-50058. Condition/Context: No documentation of family income, composition, third-party verification, or HUD‑50058 were provided for two of the twenty five tenants selected for testing for the required reexamination during the fiscal year. Our sample was not statistically valid. Questioned Costs: Housing assistance payments for the tenants noted above is not determinable. Cause: The lack of supporting documentation may be related to the Housing Authority changing voucher program administrators during fiscal year 2020. While the current administrator has access to tenant files, the eligibility determinations done in fiscal 2020 were done by a previous contractor. Also due to the Housing Authority falling behind on obtaining audits, the documents being requested by auditors are several years old. Effect: The Housing Authority may be making inaccurate or ineligible HAP payments on behalf of tenants. Recommendation: The Housing Authority should ensure their vendors properly maintain documentation regarding eligibility determinations. Views of Responsible Officials: WBHA is concerned that the current contract administrator for the HCV Program has failed to comply with providing the requested documentation. We are engaging with our current HCV Contract Administrator (Allegiant Property Management, LLC) on expectations for compliance currently and in the future. WBHA is also exploring other contract administrators or possibly opting out of the HCV Program altogether and working with WHEDA to administer WBHA’s HCV Program vouchers.

View Audit 290217

Finding 366952 (2022-002)

Material Weakness 2022

Coon Rapids-Bayard Community School District

IA

Internal Control / Segregation of Duties Reporting

The District remains committed to segregating duties as much as possible with our limited staff. District personnel recently attended continuing education regarding segregation of duties and anticipates revisions to current procedures. The District will continue to review internal control procedur...

The District remains committed to segregating duties as much as possible with our limited staff. District personnel recently attended continuing education regarding segregation of duties and anticipates revisions to current procedures. The District will continue to review internal control procedures, including the segregation of duties, in an effort to obtain the maximum internal control possible.

View Audit 290135

Finding 366915 (2022-001)

None 2022

Center for Community, INC

AK

Reporting

Center for Community was unable to employ a finance director to oversee the timely preparation of the accounting records for audit. To correct this issue, the organization has contracted with a business that provides part-time controller/finance director services. Center for Community anticipates ...

Center for Community was unable to employ a finance director to oversee the timely preparation of the accounting records for audit. To correct this issue, the organization has contracted with a business that provides part-time controller/finance director services. Center for Community anticipates this change in the accounting department will enable it to file timely required reports.

View Audit 290087

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