CSN – Agrees with the finding.
• Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place:
The Office of Grants and Contracts Post-Award Management assigned a Senior Accountant to identify instructional or ...
CSN – Agrees with the finding.
• Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place:
The Office of Grants and Contracts Post-Award Management assigned a Senior Accountant to identify instructional or non-instructional expenditures when billing the sponsor monthly. This analysis assists the project director of this award to monitor the percentages throughout the year. CSN may adjust the spending to ensure that administrative non-instructional costs will not exceed the allowable amount.
CSN will also budget for less than the maximum proportional limit negotiated for non-instruction. Therefore, if instruction costs are less than expected, we will not exceed the non-instructional percentage. This change will be processed with the first budget revision request in FY25.
• How compliance and performance will be measured and documented for future audit, management and performance review:
Reconciliation of budget to actual expenditures is performed on a regular basis to ensure spending on non-instructional costs is within the maximum limit negotiated with the State eligible agency.
• Who will be responsible and may be held accountable in the future if repeat or similar observations are noted:
The Project Director of the Adult Education – Basic Grants to States Award will be responsible for repeat or similar observations.
WNC – Agrees with the finding.
• Detailed corrective action taken, including what will be done to avoid the identified issues in the future, and when these measures will be in place:
Western Nevada College (WNC) Adult Education acknowledges the finding related to non-instructional expenditures exceeding the maximum proportional limit as negotiated with the state eligible agency. We recognize the importance of complying with Title 2 of the U.S. Code of Federal Regulations (CFR) Part 200, the Uniform Guidance, and the Workforce Innovation and Opportunity Act (WIOA) requirements. The corrective actions to be taken include the following activities listed below.
Review and Alignment of Monthly Reimbursement Requests (RFFs):
The Adult Education department will carefully review the monthly RFFs to ensure they align with the approved budget and spending guidelines. A detailed review of these requests will help prevent potential misclassification of expenditures. As part of our corrective action, we will improve this process by verifying that each submission corresponds correctly to the budget categories.
Training for Accurate Expense Categorization:
We also recognize that a contributing factor to the discrepancies was a lack of clarity on what constitutes AEFLA instructional versus non-instructional costs. This confusion is compounded by the fact that NDE function codes do not always align perfectly with instructional and non-instructional classifications. To address this, we will provide additional training for staff involved in processing grant-related expenses to ensure they are familiar with these distinctions.
Enhanced Documentation for Financial Transactions:
Moving forward, we will implement a new process in which every grant-related transaction will include specific details in the memo line, such as the grant category, object code, function code, and whether the expense is instructional or non-instructional. This will provide clear guidance to the Controller’s Office team or any future staff processing these transactions, ensuring that expenditures are correctly classified in the general ledger and that we remain in compliance with the allowable limits for instructional and non-instructional costs.
Timeline for Corrective Action:
We will fully implement these corrective actions by December 31, 2024, and will continue working closely with NSHE and NDE to ensure compliance with federal guidelines and alignment with system-wide practices.
• How compliance and performance will be measured and documented for future audit, management and performance review:
Monthly general ledger activity and reconciliations will provide documentation that expenditures are in compliance with allowable amounts.
• Who will be responsible and may be held accountable in the future if repeat or similar observations are noted:
The Adult Education department may be held accountable in the futures if repeat or similar observations are noted. Name of contact person responsible for corrective action plan:
Rhett R. Vertrees, Assistant Chief Financial Officer
2601 Enterprise Road, Reno NV 89512-1666
Phone: (775)784-3409, Fax: (775)784-1127
Email: rvertrees@nshe.nevada.edu