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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.
Finding 367115 (2022-038)
Significant Deficiency 2022
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.
Finding 367114 (2022-037)
Significant Deficiency 2022
Finding #2022-037 – Title I Grants to Local Education Agencies, CFDA 84.010 Matching, Level of Effort, and Earmarking – Significant Deficiency in Internal Control over Compliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE enhance internal controls to ensur...
Finding #2022-037 – Title I Grants to Local Education Agencies, CFDA 84.010 Matching, Level of Effort, and Earmarking – Significant Deficiency in Internal Control over Compliance resulted in the following Eide Bailly, LLP recommendation: Eide Bailly recommended NDE enhance internal controls to ensure information included in the maintenance of effort monitoring document agrees to underlying documentation. 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.
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
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
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
Finding 367111 (2022-034)
Significant Deficiency 2022
Audit Finding 2022-034: U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Fund, 21.027 Finding: Two contracts were missing certain applicable provisions, and suspension and debarment verification procedures were not performed for two vendors. Recommendation: Recommend the Ne...
Audit Finding 2022-034: U.S. Department of Treasury Coronavirus State and Local Fiscal Recovery Fund, 21.027 Finding: Two contracts were missing certain applicable provisions, and suspension and debarment verification procedures were not performed for two vendors. Recommendation: Recommend the Nevada Governor’s Finance Office (GFO) enhance internal controls to ensure all contracts under federal awards contain the applicable provisions and procedures are followed to ensure entities are not suspended or debarred prior to entering into covered transactions. Agency Response: Does the agency Agree with Finding: Yes Additional Comments: None Corrective Action: The two contracts identified are statewide contracts manged by the Department of Administration, State Purchasing Division. The GFO will work with the Purchasing Division to encourage them to include the applicable provisions for use of federal funds to statewide contracts which are mandated for state agency use, and to complete the required suspension and debarment verifications for those contracts. Date of Completion: Pending the State Purchasing Divison’s implementation. 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
Finding 367111 (2022-034)
Significant Deficiency 2022
Audit Finding: 2022-034 Coronavirus State and Local Fiscal Recovery Fund: 21.027 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Summary: The Nevada Housing Division (“Division”) did not have adequate internal controls to ensure procedures were foll...
Audit Finding: 2022-034 Coronavirus State and Local Fiscal Recovery Fund: 21.027 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control over Compliance Summary: The Nevada Housing Division (“Division”) did not have adequate internal controls to ensure procedures were followed to verify subrecipients were not suspended or debarred prior to entering into a covered transaction. Recommendation: Enhance internal controls to ensure all contracts under federal awards contain the applicable provisions and procedures are followed to ensure entities are not suspended or debarred prior to entering into covered transactions. 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. 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
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
Audit Finding: 2022-032 Homeowner Assistance Fund: 21.026 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Summary: Subawards and disbursements did not contain all the required information, an evaluation of each subrecipient’s risk of noncompliance for purposes of determ...
Audit Finding: 2022-032 Homeowner Assistance Fund: 21.026 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Summary: Subawards and disbursements did not contain all the required information, an evaluation of each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring was not performed. 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, 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
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
Finding 367107 (2022-030)
Significant Deficiency 2022
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
Audit Finding: 2022-029 Homeowner Assistance Fund: 21.026 Cash Management Material Weakness in Internal Control over Compliance Summary: No monitoring of cash drawdowns by the subrecipient to ensure that the time elapsing between transfer of federal funds to the subrecipient and the disbursement for...
Audit Finding: 2022-029 Homeowner Assistance Fund: 21.026 Cash Management Material Weakness in Internal Control over Compliance Summary: No monitoring of cash drawdowns by the subrecipient to ensure that the time elapsing between transfer of federal funds to the subrecipient and the disbursement for the program purpose is minimized. There was no tracking of interest earned on funds advanced by the Department of Treasury and no remittance of any interest earned greater than $500 as required. Recommendation: Implement internal controls to ensure time between disbursement of federal funds to the subrecipient and their disbursement for program purposes is minimized and ensure interest is appropriately tracked and remitted. Agency Response: The Nevada Housing Division (“Division”) disagrees with this finding as cited and feels strongly that it should be only a Significant Deficiency in Internal Control over Compliance due to the lack of tracking the interest earned on funds advanced and the late remittance (an inquiry for process has been initiated). Per the HAF Guidance that was published by the U.S. Treasury and per the FAQ that currently exists on the U.S. Treasury website, the U.S. Treasury themselves noted that the funds would be disbursed in only two payments, an initial 10% and then the remaining funds per the approved plan of the recipient. If the intent of the U.S. Treasury was per section 305(b)(1), then the Treasury would either have 1) not approved the Division’s plan, and/or (2) disbursed funds on an as needed or reimbursement basis. 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. The Division has already followed up with the Controller to understand the process to have the state, who is holding the funds, remit the interest collected both in FY22 and FY23 back to Treasury. Going forward, this will be supported by the new committee. Adoption of Corrective Action: December 2023 Division Contact and Corrective Action Plan Lead: Christine Hess, Chief Financial Officer Nevada Housing Division 775-687-2249 chess@housing.nv.gov
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
Finding 367104 (2022-026)
Significant Deficiency 2022
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
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
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
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
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
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
Finding 367093 (2022-023)
Significant Deficiency 2022
Finding 2022-023 The assistance listing number was not identified at the time of disbursement. A nonstatistical sample of 60 our of a population of 603 payments to subrecipients was selected for testing. The Department did not communicate the award’s assistance listing number at the time of disburse...
Finding 2022-023 The assistance listing number was not identified at the time of disbursement. A nonstatistical sample of 60 our of a population of 603 payments to subrecipients was selected for testing. The Department did not communicate the award’s assistance listing number at the time of disbursement for all 60 payments. Recommendation We recommend the Department implement internal controls to ensure the assistance listing number is communicated on each disbursement to a subrecipient. Nevada DETR’s Response DETR has identified a solution to the character limit issue in processing accounts payables related to subrecipient monitoring. The internal control policy has been revised to include the procedure to verify that the ALN number is included on the payment as required. Estimated Date of Completion: COMPLETED Contact Person: Carrie Edlefsen, Chief Financial Officer, DETR/ESD (775)684-3952 c-edlefsen@detr.nv.gov
Finding 367092 (2022-022)
Significant Deficiency 2022
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
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
Finding 367085 (2022-018)
Significant Deficiency 2022
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
Finding 367071 (2022-001)
Significant Deficiency 2022
Finding Number: 2022-001 Contact Person(s) and responsible person: Emily Allred, Finance & Investments Director Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement. Corrective action planned: Impact Chari...
Finding Number: 2022-001 Contact Person(s) and responsible person: Emily Allred, Finance & Investments Director Explanation and specific reasons for disagreement with the audit finding or that corrective action is not required (if applicable): No disagreement. Corrective action planned: Impact Charitable performed a search on the System for Award Management (SAM) in 2023 for the procurement tested in the 2022 audit, and verified that the vendor was not suspended or debarred. Impact Charitable staff will follow its policy of awarding purchases to vendors and contractors only after staff have confirmed that the vendor is not listed on the government wide exclusions in the System for Award Management (SAM). Impact Charitable staff will keep records that this process was undertaken. Anticipated completion date: December 31, 2023
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