Corrective Action Plans

2025-001 – Cash Management Corrective action plan: 1. Remittance of $116,558.82 to the Department of Health and Human Services Payment Management System. Completed September 21, 2026. 2. Adopt a written cash management and drawdown procedure as an amendment to NFEAIE’s Financial Management Policies and Procedures Manual, requiring that each request be limited to disbursements expected within a defined period not to exceed 45 days, that the request identify the disbursements it supports, that the Chief Financial Officer (CFO) approve the request before submission, that the request and its supporting schedule be retained in the award file, and that any direction from an awarding agency to draw on a different schedule, or any award term authorizing a different payment basis, be documented in writing and retained in the award file. 3. Amend the manual to assign the CFO responsibility for computing interest earned on federal advances not less than semiannually, to prescribe the allocation of interest between federal and non-federal funds where accounts are commingled, to apply the $500 annual retention threshold, to require the amount payable to the federal government to be recorded in the period earned, and to require remittance through the Payment Management System. Interest on federal advances is currently being accrued as a payable in the period earned, as reflected in journal entry JE-INT-2026H1 recorded at June 30, 2026, and will continue to be recorded on at least a semi-annual basis. 4. Evaluate holding federal advances in a separate account so that an allocation between federal and non-federal funds is not required, and implement if operationally feasible. 5. Present both procedures to the Finance Committee and the Board of Directors for adoption at the Board's fourth quarter 2026 meeting. Personnel responsible for corrective action: Nicholas Cunningham, CFO Estimated corrective action completion date: December 31, 2026

Program: AL 84.126 – Rehabilitation Services Vocational Rehabilitation Grants to States – Reporting Corrective Action Plan: An additional review will be completed by NDE Budget and Grant Management staff to ensure accuracy. Contact: Cathy Callaway Anticipated Completion Date: Completed

Finding Number: 2024-003 Planned Corrective Action: The District will closely review the Final Expenditure Report for all grants to ensure accuracy. Anticipated Completion Date: 6/30/26 Responsible Contact Person: Kaitlin Huck, Treasurer/CFO

Program: AL 84.126 – Rehabilitation Services Vocational Rehabilitation Grants to States – Period of Performance Corrective Action Plan: A validation will be added into the case management system (QE2) that prevents an obligation from being created in a federal fiscal year with a service start date in a previous federal fiscal year. Contact: Cathy Callaway Anticipated Completion Date: April 1, 2025

Program: AL 84.126 – Rehabilitation Services Vocational Rehabilitation Grants to States – Reporting Corrective Action Plan: Instructions for completing the RSA-17 report have been updated to ensure unliquidated obligations for indirect costs are correctly reported, and the correct payroll periods are included with the appropriate supporting documentation. Unliquidated obligations will not include contract amounts unless the contracts have been completed. As noted above, administrative costs will be reported using the sub ledgers/subsidiaries already set up in E1. Contact: Cathy Callaway Anticipated Completion Date: Done

Program: AL 84.048 – Career and Technical Education – Basic Grants to States – Allowability Corrective Action Plan: The Nebraska Department of Education’s Office of Career, Technical, and Adult Education will carry out the following actions to improve procedures to ensure that all payments are supported by adequate documentation: Provide ongoing technical assistance to subrecipients and NDE staff to ensure they are familiar with and fully informed on the documentation necessary to process reimbursement for all types of expenditures. Ensure all subrecipients have a stipend policy in writing. Conduct regular desk audits to ensure subrecipients are adhering to all applicable state and federal laws and regulations. Contact: Katie Graham, Sydney Kobza, Teri Sloup Anticipated Completion Date: June 2025

All Final Expenditure Reports will include the appropriate expenditure amounts associated with the grant year.

Finding Number: 2023-002 Planned Corrective Action: We are confident that our ESSER expenditures align with the allowable purposes and intents of the grant application that was submitted in the CCIP. We also stand by the integrity of our identification of expenses in total in the American Rescue Plan ESSER Federal Grant Program despite differences identified between grant years. The FER process and the reallocation of funds by grant year was confusing. However, as in the response above, we recognize the responsibility to adhere to the strict timelines was our responsibility. All ESSER funds have now been expended and we are confident they are allowable expenses per the guidelines provided. The Treasurer, Superintendent, and Federal Funds Coordinator agree to work more collaboratively to ensure our expenditures are within the grant timeframes prior to FER submissions. Anticipated Completion Date: 03/08/2024 Responsible Contact Person: Lance A. Erlwein, Treasurer

Program: AL 84.287 – Twenty-First Century Community Learning Centers – Subrecipient Monitoring Corrective Action Plan: The NDE was provided written guidance from the U.S. Department of Education (USED) regarding source documentation required for the NDE’s review of preliminary documentation required to make payment whereas this effort is not associated with the NDE’s Grant Compliance Section performing the fiscal monitoring activities applying the required pass-through activities contained within 2 CFR 200.332. To make payment, the USED guidance states, “Uniform Guidance does not require the NDE to obtain specific source documentation from its subrecipient prior to making payments and the NDE’s Grant Guidance states that for certain reimbursement requests, such as credit card purchases, travel expenses, and personal reimbursements, subrecipient are always required to submit supporting documentation. For other expenditures, including personnel costs, and time and effort certification, supporting documents need to be retained by the subrecipient for at least three years and must be available for auditing and monitoring purposes”. For the reimbursement request tested to make payment, additional source documentation was acquired from the subrecipient upon the APA’s request and submitted for review on March 1, 2024. Contact: Jen Utemark, Administrator, Office of Budget & Grants Management Anticipated Completion Date: March 1, 2024

Program: Various, including AL 84.027 – Special Education Grants to States; AL 84.173 – COVID-19 Special Education Preschool Grants; AL 84.425D – COVID-19 Education Stabilization Fund – Elementary and Secondary School Emergency Relief Fund (ESSER I and ESSER II); AL 84.425U – COVID-19 Education Stabilization Fund – American Rescue Plan – Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – Subrecipient Monitoring Corrective Action Plan: First SPED subrecipient – As education subrecipients have had a significant influx of subawards to mitigate post-COVID supports for Nebraska education with limited staff capacity, the Department has remained mindful of these conditions and is on schedule to complete its annual fiscal monitoring efforts within the normal timelines afforded each year. Second SPED subrecipient – Because the UNL utilizes PVS as allowed by 2 CFR 200.430 in regard to salary and wage benefit costs for employees working on a project under a contractual grant agreement, the NDE going forward will require PVS supporting documentation be submitted as a minimum semi-annually for each contract to verify the salary and benefit costs being requested for reimbursement as recommended by the U.S. Department of Education beginning with any payments occurring after March 1, 2023. Third SPED subrecipient – The documentation to support the review of purchased services and supplies during fiscal monitoring was provided to the APA on March 4, 2024. Single Audits – The Director of Grants Management and Director of Grants Compliance will work collaboratively to ensure all subrecipient audits are reviewed and applicable management decision letters are issued within the requested timeframe. Contact: Jen Utemark, Administrator, Office of Budget & Grants Management Anticipated Completion Date: July 1, 2024

Program: AL 84.010 ? Title I Grants to Local Educational Agencies ? Allowability and Subrecipient Monitoring Corrective Action Plan: The Department will contact the two subrecipients noted to provide one-on-one technical assistance and will also provide additional technical assistance regarding proper time and effort documentation to all subrecipients. Additionally, time and effort guidance is available to all subrecipients on the Department?s website, will be discussed at upcoming subrecipient training opportunities and supported by a dedicated Grants Management Training Specialist. The Department will ensure the identified written deficiencies noted in the subrecipient fiscal monitoring exit letter clearly identifies a finding vs. technical assistance needed; whereas a finding is supported by follow-up in accordance with federal UGG regulations and technical assistance provides knowledge of the Department?s training and resources available. Contact: Jen Utemark, Budget and Grants Management Anticipated Completion Date: December 31, 2023

Finding Number: 2022-004 Planned Corrective Action: The Treasurer will include the correct amounts on the FERs moving forward as required. Anticipated Completion Date: Fall 2023 FER filings Responsible Person: Maria Robinson, Treasurer