Elko County School DistrictLocal Government

2025-004: U.S. Department of Education Passed through State of Nevada Department of Education Title I Grants to Local Educational Agencies, 84.010 Eligibility Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing number 84.010 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Local educational agencies are required to equitably allocate Part A funds to each participating school, in rank order, on the basis of the number of public-school children from low-income families residing in the area or attending the school (20 USC 6313). Condition: In certain instances, the amounts disbursed to each school was not in accordance with the allocation. In addition, an amendment was made to the original allocation and was not equitably distributed. Cause: Elko County School District did not have sufficient internal controls to ensure eligibility determinations of the amounts disbursed were being appropriately followed. Effect: Noncompliance with eligibility requirements may not be detected. Questioned Costs: None Context/Sampling: Eligibility requirements were tested as a whole for the District. It was noted that there was an amended allocation of $6,228.22 that was not equitably distributed across the eleven eligible schools. In addition, $32,657.07 of the funds were not properly disbursed to the schools in accordance with the allocation or carried forward into the following year’s budget. Repeat Finding from Prior Year(s): No Recommendation: We recommend Elko County School District enhance internal controls to ensure eligibility requirements are being followed, specifically regarding allocations and disbursement of funds. Views of Responsible Officials: Management agrees with the finding.

2025-005: U.S. Department of Education Passed through State of Nevada Department of Education Title I Grants to Local Educational Agencies, 84.010 Matching, Level of Effort, and Earmarking Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing number 84.010 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Underlying supporting documentation that the Elko County School District compiled to monitor local compliance with level of effort requirements was not maintained. Cause: Elko County School District did not have sufficient internal controls to ensure level of effort tracking was maintained and reviewed. Effect: Noncompliance with level of effort requirements may not be detected. Questioned Costs: None Context/Sampling: Underlying supporting documentation for monitoring was not maintained. A recalculation of the level of effort requirements, as applicable, for the fiscal year ending June 30, 2025, was performed and no issues of noncompliance were noted. Repeat Finding from Prior Year(s): Yes, prior year finding 2024-005. Recommendation: We recommend Elko County School District enhance internal controls to ensure information used in the level of effort monitoring is maintained. Views of Responsible Officials: Management agrees with the finding.

2025-006: U.S. Department of Education Passed through State of Nevada Department of Education Title I Grants to Local Educational Agencies, 84.010 Special Tests and Provisions – Annual Report Card, High School Graduation Rate Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing number 84.010 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Pursuant to 20 USC 2011h, the District is required to report graduation rate data for all public high schools for the District for each graduating cohort. To remove a student from the cohort, the District must confirm, in writing, that the student transferred out, emigrated to another country, transferred to a prison or juvenile facility, or is deceased. Condition: Underlying supporting documentation that the Elko County School District was reviewing the reporting for removal of a student from the cohort was missing in some instances. Cause: Elko County School District did not have sufficient internal controls to ensure all documentation for the removal of students from the cohort was maintained. Effect: Noncompliance with the special test for annual report grade, high school graduation rate requirements may not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of sixty-eight removals out of 617 was selected for testing. Seventeen of the sixty-eight sample selections did not maintain approval documentation. Repeat Finding from Prior Year(s): No Recommendation: We recommend Elko County School District enhance internal controls to support the review of information used to support the removal of students from a cohort is maintained. Views of Responsible Officials: Management agrees with the finding.

2025-007: U.S. Department of Agriculture Passed through State of Nevada Department of Agriculture Child Nutrition Cluster School Breakfast Program, 10.553 National School Lunch Program, 10.555 Fresh Fruit and Vegetable Program, 10.582 U.S. Department of Treasury Passed through State of Nevada Department of Education and the State of Nevada Department of Agriculture COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing numbers 10.582, and 21.027 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires entities use their own documented procurement procedures, provided they reflect State, Local, and Federal laws and regulations. In addition, procurements must be carried out in a manner consistent with free and open competition and contain the applicable provisions described in Appendix II to Part 200 for contracts under federal awards. Condition: Procurement processes required for acquiring goods and services were not followed. Procedures were not followed to maintain documentation regarding obtaining rate quotations or maintaining sole source vendor documentation, if applicable. In addition, contracts were missing required provisions per Appendix II to Part 200 for contracts under federal awards. Cause: Elko County School District did not have adequate internal controls to ensure that procurement processes were followed relating to obtaining rate quotations or maintaining sole source vendor documentation, if applicable, or including required contract provisions. Effect: Noncompetitive purchases may be deemed improper. Contractors may not be aware of required terms and conditions. Questioned Costs: None Context/Sampling: Fresh Fruit and Vegetable, 10.582 There were only two vendors that had purchases over the micro-purchase threshold over $10,000. We tested both vendors and noted the vendor documentation maintained did not have the documented rate quotations or single source vendor documentation. COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 A nonstatistical sample of four procurement transactions out of 20 was selected for testing, including one contract subject to Appendix II to Part 200. The one contract was missing certain required provisions from Appendix II to Part 200. Repeat Finding from Prior Year(s): Yes, prior year finding 2024-004 Recommendation: We recommend Elko County School District implement internal control policies to follow required procurement processes including obtaining rate quotations or maintaining single source vendor documentation and including required contract provisions. Views of Responsible Officials: Management agrees with the finding.

2024-003: U.S. Department of Education Direct Program Impact Aid, 84.041 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing numbers 84.041 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Internal Controls requires that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is adequate documentation to support reporting required under the grant award. Condition: Impact aid annual application did not have evidence of the reporting figures used at the time of submission of the report. Cause: Elko County School District did not have adequate internal controls to ensure maintenance of records used to support the reporting required under the grant award. Effect: Reporting figures may be incorrect and not detected by Elko County School District. Questioned Costs: None noted Context/Sampling: An annual application is required and was selected for testing. Reporting was not maintained to substantiate key line items for current year membership on the survey date reported. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Elko County School District implement internal control policies to require maintenance of records used to complete required reporting for the Impact Aid grant award. Views of Responsible Officials: Management agrees with the finding.

2024-004: U.S. Department of Agriculture Passed through State of Nevada Department of Agriculture Child Nutrition Cluster School Breakfast Program, 10.553 National School Lunch Program, 10.555 Fresh Fruit and Vegetable Program, 10.582 U.S. Department of Treasury Passed through State of Nevada Department of Education and the State of Nevada Department of Agriculture COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Procurement, Suspension and Debarment Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing numbers 10.553, 10.555, 10.582, and 21.027 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires entities use their own documented procurement procedures, provided they reflect State, Local, and Federal laws and regulations. In addition, procurements must be carried out in a manner consistent with free and open competition and contain the applicable provisions described in Appendix II to Part 200 for contracts under federal awards. Condition: Procurement processes required for acquiring goods and services were not followed. Procedures were not followed to maintain documentation regarding obtaining rate quotations or maintaining sole source vendor documentation, if applicable. In addition, contracts were missing required provisions per Appendix II to Part 200 for contracts under federal awards. Cause: Elko County School District did not have adequate internal controls to ensure that procurement processes were followed relating to obtaining rate quotations or maintaining sole source vendor documentation, if applicable, or including required contract provisions. Effect: Noncompetitive purchases may be deemed improper. Contractors may not be aware of required terms and conditions. Questioned Costs: None Context/Sampling: Child Nutrition Cluster, 10.553, 10.555 and 10.582 A nonstatistical sample of three procurement transactions out of nine was selected for testing for purchases over the micro-purchase threshold over $10,000. We noted three vendors where the vendor documentation maintained did not have the documented rate quotations or single source vendor documentation. COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 A nonstatistical sample of five procurement transactions out of 18 was selected for testing, including one contract subject to Appendix II to Part 200. The one contract was missing certain required provisions from Appendix II to Part 200. Repeat Finding from Prior Year(s): Yes Recommendation: We recommend Elko County School District implement internal control policies to follow required procurement processes including obtaining rate quotations or maintaining single source vendor documentation and including required contract provisions. Views of Responsible Officials: Management agrees with the finding.

2024-005: U.S. Department of Education Passed through State of Nevada Department of Education Supporting Effective Instruction State Grants, 84.367 Matching, Level of Effort, and Earmarking Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing number 84.367 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) section 200.303 provides that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: Underlying supporting documentation that the Elko County School District compiled to monitor local compliance with level of effort requirements was not maintained. Cause: Elko County School District did not have sufficient internal controls to ensure level of effort tracking was maintained and reviewed. Effect: Noncompliance with level of effort requirements may not be detected. Questioned Costs: None Context/Sampling: Underlying supporting documentation for monitoring was not maintained. A recalculation of the level of effort requirements, as applicable, for the fiscal year ending June 30, 2024, was performed and no issues of noncompliance were noted. Repeat Finding from Prior Year(s): No Recommendation: We recommend Elko County School District enhance internal controls to ensure information used in the level of effort monitoring is maintained. Views of Responsible Officials: Management agrees with the finding.

2023-003: U.S. Department of Agriculture Passed through State of Nevada Department of Agriculture Child Nutrition Cluster School Breakfast Program, 10.553 National School Lunch Program, 10.555 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing numbers 10.553 and 10.555 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Internal Controls requires that non-federal entities must establish and maintain effective internal control that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the Federal award. A key component of effective internal control is adequate documentation to support payroll costs through approved timecards. Condition: Payroll costs charged to the program did not have evidence of timecards by the employee. Cause: Elko County School District did not have adequate internal controls to ensure maintenance of timecards charged to the program with approvals. Effect: Unallowable costs may be charged to the program and not detected by Elko County School District. Questioned Costs: None noted Context/Sampling: A nonstatistical sample of 40 payroll charges out of a population of 2,021 charges were selected for testing. For five charges made there was no documented timecards with appropriate approval. Repeat Finding from Prior Year(s): No Recommendation: We recommend the Elko County School District implement internal control policies to require maintenance of timecards for the program with appropriate approvals. Views of Responsible Officials: Management agrees with the finding.

2023-004: U.S. Department of Education Passed through State of Nevada Department of Education Special Education Cluster (IDEA) Special Education Grants to States, 84.027 COVID-19, Special Education Grants to States, 84.027 Special Education Preschool Grants, 84.173 COVID-19, Special Education Preschool Grants, 84.173 U.S. Department of Agriculture Passed through State of Nevada Department of Agriculture Child Nutrition Cluster School Breakfast Program, 10.553 National School Lunch Program, 10.555 Fresh Fruit and Vegetable Program, 10.582 U.S. Department of Treasury Passed through State of Nevada Department of Education and the State of Nevada Department of Agriculture COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects all grant awards included under assistance listing numbers 84.027, 84.173, 10.553, 10.555, 10.582, and 21.027 on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires procurement processes for acquiring goods and services over $10,000 include obtaining rate quotations, otherwise sole source vendor documentation must be maintained. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: Procurement processes required for acquiring goods and services were not followed. Procedures were not followed to maintain documentation regarding the verification of whether an entity was suspended or debarred before entering into a covered transaction. Cause: Elko County School District did not have adequate internal controls to ensure that procurement processes were followed relating to obtaining rate quotations or to verify subrecipients were not suspended or debarred prior to entering into a covered transaction. Effect: Procurement policies are not adhered to. A covered transaction may be entered into with an entity or subrecipient that is suspended or debarred. Questioned Costs: None Context/Sampling: Special Education Cluster (IDEA), 84.027 and 84.173 A nonstatistical sample of four vendors which had purchases over the micropurchase threshold over $10,000 for the fiscal year out of a population of ten vendors meeting this criteria were selected for testing. For all four vendors there was no documented rate quotations or single source vendor documentation maintained or evidence of verification if the parties were suspended or debarred. Child Nutrition Cluster, 10.553, 10.555 and 10.582 All vendors which had purchases over the micro-purchase threshold over $10,000 for the fiscal year were selected for testing as the population was three. For two vendors there was no documented rate quotations or single source vendor documentation maintained or evidence of verification if the parties were suspended or debarred. COVID-19, Coronavirus State and Local Fiscal Recovery Fund, 21.027 A nonstatistical sample of five vendors which had purchases over the micropurchase threshold over $10,000 for the fiscal year out of a population of 25 vendors meeting this criteria were selected for testing. There were four vendors with no documented rate quotations or single source vendor documentation maintained or evidence of verification if the parties were suspended or debarred. Repeat Finding from Prior Year(s): No Recommendation: We recommend Elko County School District implement internal control policies to follow required procurement processes including obtaining rate quotations and ensuring entities are not suspended or debarred prior to entering into covered transactions. Views of Responsible Officials: Management agrees with the finding.