Corrective Action Plans

Finding 370113 (2022-003)

Material Weakness 2022

Metropolitan School District of Lawrence Township

IN

Subrecipient Monitoring Internal Control / Segregation of Duties Matching / Level of Effort / Earmarking § 200.302 § 200.303 § 200.328 § 200.329 § 200.334

FINDING 2022-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting complianc...

FINDING 2022-003 Finding Subject: COVID-19 - Education Stabilization Fund - Reporting Summary of Finding: An effective internal control system was not designed, nor implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Reporting compliance requirements. The annual Elementary and Secondary School Emergency Relief (ESSER) Data Collection reports were complied, prepared and submitted by three different staff members; however, this process was not properly designed or implemented to prevent, or detect and correct, errors. The School Corporation completed and submitted three annual Data Collection reports (Reports) for the ESSER grants. For two of the three reports tested, the report was not supported by the unit’s records. The financial information provided did not agree to the data submitted in the Reports, therefore we could not determine their accuracy. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Contact Person Responsible for Corrective Action: Matthew Miles, CFO Contact Phone Number and Email Address: 317-423-8380 mattmiles@msdlt.k12.in.us Views of Responsible Officials: We concur with the finding. Description of Corrective Action Plan: The School District will work to ensure the ESSER report amounts tie to the accounting records and will improved record keeping of supporting documentation. If the amounts do not match, District will document support for all claims. Anticipated Completion Date: The School District will implement changes described in the Corrective Action Plan in February 2024.

View Audit 291623

Finding 369984 (2022-002)

None 2022

Warren County, Missouri

MO

Reporting Subrecipient Monitoring Period of Performance

Finding Reference Number: 2022-002 Federal Agency: U.S. Department of the Treasury Program Name: COVID-19 Coronavirus Relief Fund ALN Number: 21.019 Responsible Official: County Commission Views of Responsible Individuals: We understand the importance of having adequate documentation for Federal Gra...

Finding Reference Number: 2022-002 Federal Agency: U.S. Department of the Treasury Program Name: COVID-19 Coronavirus Relief Fund ALN Number: 21.019 Responsible Official: County Commission Views of Responsible Individuals: We understand the importance of having adequate documentation for Federal Grant programs. We hired an outside agency to oversee the Coronavirus Relief Fund who did not provide us the adequate documentation needed. We did; however, provide email confirmations that the monies spent were reported to the Treasury. The County will handle all Federal Grant programs in the future to ensure that adequate documentation is maintained by the County.

View Audit 291498

Finding 369974 (2022-002)

Material Weakness 2022

The County of Crawford, Pennsylvania

PA

Subrecipient Monitoring § 200.332

CORRECTIVE ACTION PLAN September 28, 2023 Crawford County Human Services respectfully submits the following corrective action plan for calendar year ended December 31, 2022. Name and address of independent public accounting firm: Maher Duessel, CPA’s 503 Martindale Street, Suite 600 Pittsburgh, ...

CORRECTIVE ACTION PLAN September 28, 2023 Crawford County Human Services respectfully submits the following corrective action plan for calendar year ended December 31, 2022. Name and address of independent public accounting firm: Maher Duessel, CPA’s 503 Martindale Street, Suite 600 Pittsburgh, PA 15212 Audit period: January 1, 2022 – December 31, 2022 The finding from the December 31,2022 schedule of findings is discussed below: FINDING—SUBRECIPIENT MONITORING Dept. of Health and Human Services Passed through PA Dept. of Human Services Foster Care – Title IV-E – ALN 93.658 Finding 2002-002 Recommendation: We recommend that the County ensure adherence to the monitoring policy related to subrecipients and that these subrecipients be monitored on an annual basis in accordance with the policy. Action taken: Crawford County Human Services has created a Fiscal Technician position to aid in the monitoring process. The Fiscal Technician position has been approved by the County Commissioners and State Civil Service. Crawford County Human Services is activity recruiting for the position. The monitoring policy will be updated to insure inclusion of IV-E providers and will outline a set of criteria to determine the frequency of monitoring. Sincerely yours, Roberta Clark Fiscal Operations Officers Crawford County Human Services

View Audit 291438

Finding 369787 (2022-003)

Significant Deficiency 2022

Housing Authority of the Birmingham District

AL

HUD Housing Programs Subrecipient Monitoring Significant Deficiency

Recommendation: We recommend management should designate one person to oversee the inspection processes to ensure the policies set in place in the Authorities administrative plan are being followed. Explanation of disagreement with audit finding: There is no disagreement. Action taken in response ...

Recommendation: We recommend management should designate one person to oversee the inspection processes to ensure the policies set in place in the Authorities administrative plan are being followed. Explanation of disagreement with audit finding: There is no disagreement. Action taken in response to finding: The Authority will designate one person to oversee the inspection processes to ensure the policies set in place in the Authorities administrative plan are being followed. Name of the contact person responsible for corrective action: Dontrelle Young Foster, President & Chief Executive Officer Planned completion date for corrective action plan: We expect to have the finding resolved by issuance of next year's audit.

View Audit 291313

Finding 369784 (2022-002)

Significant Deficiency 2022

Housing Authority of the Birmingham District

AL

Questioned Costs HUD Housing Programs Subrecipient Monitoring

Recommendation: We recommend management should designate one person to oversee the recertifications and inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Explanation of disagre...

Recommendation: We recommend management should designate one person to oversee the recertifications and inspections are being performed in a timely manner. Furthermore, management should ensure no HAP payments are issued for units that have not passed HQS housing inspections. Explanation of disagreement with audit finding: There is no disagreement. Action taken in response to finding: The Authority will designate one person to oversee the recertifications and inspections are being performed in a timely manner. Name of the contact person responsible for corrective action: Dontrelle Young Foster, President & Chief Executive Officer Planned completion date for corrective action plan: We expect to have the finding resolved by issuance of next year's audit.

View Audit 291313 Questioned Costs: $1

Finding 369478 (2022-002)

Material Weakness 2022

Tennessee Immigrant and Refugee Rights Coalition

TN

Questioned Costs Subrecipient Monitoring

Management accepts the recommendation. Corrective Action Taken: The organization has since implemented additional controls to monitor subrecipients' use of American Rescue Plan federal awards in 2022 which include an addendum, signed and adopted May 2023, to the subgrant agreement to ensure the subr...

Management accepts the recommendation. Corrective Action Taken: The organization has since implemented additional controls to monitor subrecipients' use of American Rescue Plan federal awards in 2022 which include an addendum, signed and adopted May 2023, to the subgrant agreement to ensure the subrecipients provide invoices and financial reports as well as programmatic reports every 6 months to ensure the organization and subrecipients' compliance. The organization has updated our subgrant agreement to ensure an appropriate monitoring process is included for future cycles. In addition, we have established clear staff roles for monitoring subrecipient reporting compliance. Given the additional systems in place, we do not anticipate an issue with subrecipient monitoring and oversight moving forward. Anticipated Completion Date: April 1, 2024

View Audit 290698 Questioned Costs: $1

Finding 369476 (2022-001)

Significant Deficiency 2022

City of St. Louis Mental Health Board of Trustees

MO

Subrecipient Monitoring Reporting Significant Deficiency

FFATA Reporting U.S. Department of Health and Human Services Recommendation: We recommend the agency implement a process that includes tracking timely submission of the Federal Funding Accountability and Transparency Act (FFATA) reports and training employees on the FFATA reporting requirements. Exp...

FFATA Reporting U.S. Department of Health and Human Services Recommendation: We recommend the agency implement a process that includes tracking timely submission of the Federal Funding Accountability and Transparency Act (FFATA) reports and training employees on the FFATA reporting requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Annually, the City of St. Louis Mental Health Board of Trustees will review expenditures to ensure FFATA reporting is completed for all eligible subrecipient and contracts. Name(s) of the contact person(s) responsible for corrective action: Serena Muhammad Planned completion date for corrective action plan: September 30, 2024

View Audit 290694

Finding 369453 (2022-004)

Significant Deficiency 2022

Boone County Fiscal Court

KY

Subrecipient Monitoring Reporting § 200.331

The guidance was unclear when reporting began in 2021. The delineation is now understood and will be corrected in the next quarterly report to the Treasury Department. Anticipated Completion Date: January 31, 2024.

View Audit 290646

Finding 369417 (2022-002)

Significant Deficiency 2022

City of Clarkston

WA

Procurement, Suspension & Debarment Subrecipient Monitoring § 200.318

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Clarkston January 1, 2022 through December 31, 2022 This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part...

CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE City of Clarkston January 1, 2022 through December 31, 2022 This schedule presents the corrective action planned by the City for findings reported in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Finding ref number: 2022-002 Finding caption: The City did not have adequate internal controls for ensuring compliance with federal procurement requirements. Name, address, and telephone of City contact person: Steve Austin, Clerk Treasurer 829 5th Street, Clarkston, WA 99403 (509) 758-5541 Corrective action the auditee plans to take in response to the finding: The City updated the policy regarding federal procurement to ensure compliance with usage of federal funds in November 2022. This audit determined that additional levels of internal control needed to be implemented to comply with Uniform Guidance and federal regulations. The City plans to update the procurement policy and standards of conduct policy to ensure that federal standards are being maintained. The City will strengthen internal controls to ensure that procurement of goods and services will comply with Uniform Guidance, the federal regulations and the City’s procurement policy. Anticipated date to complete the corrective action: Completed before the 2024 year-end.

View Audit 290602

Finding 367217 (2022-001)

Material Weakness 2022

Douglas County

WA

Procurement, Suspension & Debarment Subrecipient Monitoring

Finding ref number: 2022-001 Finding caption: The County’s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements Name, address, and telephone of County contact person: Karen Goodwin 140 19ᵗʰ Street N.W. 509-888-6596 Corrective action the audi...

Finding ref number: 2022-001 Finding caption: The County’s internal controls were inadequate for ensuring compliance with federal suspension and debarment requirements Name, address, and telephone of County contact person: Karen Goodwin 140 19ᵗʰ Street N.W. 509-888-6596 Corrective action the auditee plans to take in response to the finding: The County has hired a Grants and Public Relations Specialist. This position provides technical assistance to county staff and outside contractors to ensure compliance. Anticipated date to complete the corrective action: Done

View Audit 290331

Finding 367174 (2022-058)

Significant Deficiency 2022

State of Nevada

NV

Subrecipient Monitoring

Program: U.S. Department of Health and Human Services Foster Care - Title IV-E, CFDA 93.658 Corrective Action Plan Finding Number: 2022-058 Finding: The assistance listing number was not identified at the time of disbursement. Corrective Action Taken or To Be Taken: Technical assistance will be soug...

Program: U.S. Department of Health and Human Services Foster Care - Title IV-E, CFDA 93.658 Corrective Action Plan Finding Number: 2022-058 Finding: The assistance listing number was not identified at the time of disbursement. Corrective Action Taken or To Be Taken: Technical assistance will be sought to amend internal controls and staff will be trained on the internal control to ensure the assistance listing number is communicated on each disbursement to a subrecipient. If already taken, date of completion: If to be taken, estimated date of completion: The internal control will be updated and staff will be trained by 6/30/2024. 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: Heather Bugg, Administrative Services Office IV Address: 4126 Techonology Way City, State, Zip Code: Carson City, NV 89706 Phone Number: 775-684-4462 Email: hbugg@dcfs.nv.gov Reviewed and Approved Tiffany Greenameyer, Deputy Administrator

View Audit 290300

Finding 367173 (2022-057)

Material Weakness 2022

State of Nevada

NV

Reporting Student Financial Aid Subrecipient Monitoring

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...

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

View Audit 290300

Finding 367166 (2022-052)

Material Weakness 2022

State of Nevada

NV

Subrecipient Monitoring

Audit Finding: 2022-052 Low-Income Home Energy Assistance: 93.568 Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: The Nevada Housing Division (“Division”) did not have adequate internal controls to ensure compliance with subrecipient...

Audit Finding: 2022-052 Low-Income Home Energy Assistance: 93.568 Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: The Nevada Housing Division (“Division”) did not have adequate internal controls to ensure compliance with subrecipient monitoring requirements. The following items were noted: a risk assessment was not performed, the subaward was missing required information and no monitoring procedures were performed to ensure audits required by Uniform Guidance were performed. Recommendation: Implement internal controls to ensure compliance with subrecipient monitoring requirements. 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. 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. Additionally, Division counsel was asked to begin incorporating the missing items in future agreements with subrecipients of federal funds. 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

View Audit 290300

Finding 367165 (2022-051)

Material Weakness 2022

State of Nevada

NV

Reporting Subrecipient Monitoring Material Weakness

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 dir...

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

View Audit 290300

Finding 367152 (2022-055)

Material Weakness 2022

State of Nevada

NV

Subrecipient Monitoring Matching / Level of Effort / Earmarking

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: 2022-055 – Reporting Material Weakness in Internal Control over Compliance Finding: Title...

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: 2022-055 – Reporting Material Weakness in Internal Control over Compliance Finding: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.332 requires that: •Pass-through entities ensure every subaward includes certain information at the time of the subaward. •Pass-through entities evaluate each subrecipient’s risk of noncompliance with federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Corrective Action Taken or To Be Taken: The Child Care and Development Fund (CCDF) has contracted with a CPA from My Office Staff to conduct subrecipient monitoring of all the Program’s subrecipients. Procedure is in place to ensure every subaward contains a Risk Assessment prior to final approval. Agency Response Does the Agency agree with finding: Yes Individual Responsible for Corrective Action Plan: Name, Title: Gary Long Phone Number: 775-684-0655 Email: gxlong@dwss.nv.gov Reviewed and Approved Crystal Buscay, CFO

View Audit 290300

Finding 367151 (2022-054)

Material Weakness 2022

State of Nevada

NV

Reporting Matching / Level of Effort / Earmarking Subrecipient Monitoring

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 Non...

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

View Audit 290300

Finding 367123 (2022-046)

Significant Deficiency 2022

State of Nevada

NV

Reporting Subrecipient Monitoring Allowable Costs / Cost Principles

Finding #2022-046 – Education Stabilization Fund, CFDA 84.425 Other – Significant Deficiency in Internal Control over Compliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE enhance internal controls to ensure payments to subrecipients are recorded to the de...

Finding #2022-046 – Education Stabilization Fund, CFDA 84.425 Other – Significant Deficiency in Internal Control over Compliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE enhance internal controls to ensure payments to subrecipients are recorded to the designated subrecipient general ledger accounts within the chart of accounts. NDE Response NDE agrees with this finding. Corrective Action NDE shall develop a comprehensive Policy and Procedure (1.15 SEFA Reporting) documenting the process for the development, review, and finalization of all SEFA reports. 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 revise existing internal controls to expand the controls applied as it relates to verifications and reviews/approvals. The Office of Division Compliance will collaborate with the Office of Fiscal Operations to develop and finalize these documents. Responsible Parties and Anticipated Completion Date Student Investment Division, Offices of Division Compliance and Fiscal Operations; May 1, 2024. Please reach out to Amelia Thibault at sidcompliance@doe.nv.gov with any questions.

View Audit 290300

Finding 367122 (2022-045)

Material Weakness 2022

State of Nevada

NV

Subrecipient Monitoring

Finding #2022-045 – Education Stabilization Fund, CFDA 84.425 Reporting – Material Weakness in Internal Control over Compliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE enhance internal controls to ensure subawards and disbursements to subrecipients incl...

Finding #2022-045 – Education Stabilization Fund, CFDA 84.425 Reporting – Material Weakness in Internal Control over Compliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE enhance internal controls to ensure subawards and disbursements to subrecipients include all required information. NDE Response At the time of this Corrective Action Plan, NDE believes this issue has been remediated. Specifically, multiple offices previously had access to the electronic grants management system (ePAGE); recent changes have limited control over ePAGE and the grant development process to the Grants Management Unit. Controls have been further instituted within the Grants Management Unit; specifically, comprehensive review processes through ePage Request Forms and Planner Task Tracking. Corrective Action NDE shall review revised processes and documentation to ensure that all required subrecipient data is included within the checklist for subaward review prior to approval. 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.

View Audit 290300

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.

View Audit 290300

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.

View Audit 290300

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.

View Audit 290300

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.

View Audit 290300

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

View Audit 290300

Finding 367112 (2022-035)

Material Weakness 2022

State of Nevada

NV

Subrecipient Monitoring

Audit Finding 2022-035: U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Fund, 21.027 Finding: Five pass-through payments applicable to the Nevada Governor’s Finance Office were tested. The assistance listing was not communicated at the time of disbursement for all pass-thr...

Audit Finding 2022-035: U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Fund, 21.027 Finding: Five pass-through payments applicable to the Nevada Governor’s Finance Office were tested. The assistance listing was not communicated at the time of disbursement for all pass-through payments tested. Recommendation: Recommend the Governor’s Finance Office (GFO) enhance internal controls to ensure compliance with subrecipient monitoring 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. Date of Completion: Approximately January of 2023 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 367112 (2022-035)

Material Weakness 2022

State of Nevada

NV

Subrecipient Monitoring

Audit Finding: 2022-035 Coronavirus State and Local Fiscal Recovery Fund: 21.027 Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: The Nevada Housing Division ((“Division”) did not have adequate internal controls to ensure compliance w...

Audit Finding: 2022-035 Coronavirus State and Local Fiscal Recovery Fund: 21.027 Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Summary: The Nevada Housing Division ((“Division”) did not have adequate internal controls to ensure compliance with subrecipient monitoring requirements. The following items were noted: a risk assessment was not performed, the subaward was missing required information and no monitoring procedures were performed as necessary to ensure the subaward was used for authorized purposes. Recommendation: Enhance internal controls to ensure compliance with subrecipient monitoring requirements. Agency Response: The Division agrees with the finding; however, 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. Additionally, Division counsel was asked to begin incorporating the missing items in future agreements with subrecipients of federal funds. 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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