INCLINE VILLAGE GENERAL IMPROVEMENT DISTRICTLocal Government

2025 – 005 – Suspension and Debarment Federal Agency: Environmental Protection Agency Federal Program Name: Capitalization Grants for Clean Water State Revolving Funds Assistance Listing Number: 66.458 Federal Award Identification Number: CS-32000123-0, 4C-98T68401-0 Pass-Through Agency: Nevada Division of Environmental Protection Pass-Through Number(s): CW2402 Award Period: December 1, 2023 to December 1, 2026 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Noncompliance Criteria or specific requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Before entering into a covered transaction the entity must verify that the contractor is not suspended, debarred or otherwise excluded from participating in the transaction. Condition: Through our testing we noted that suspension and debarment checks were not performed for two vendors prior to entering into the transactions. Questioned costs: None noted. Context: Suspension and debarment procedures were not performed for two of the two vendors selected prior to entering into the transactions. Cause: The District did not have controls in place to ensure that suspension and debarment checks were performed prior to entering into covered transactions. Effect: Without checking suspension and debarment before engaging services, the District could have entered into an agreement with a vendor that was suspended or debarred from receiving federal funding. Repeat Finding: Not a repeat finding. Recommendation: CLA recommends that the District implement procedures to ensure that federal guidance is followed relating to suspension and debarment for both new and existing vendors and provide training on these procedures. Views of responsible officials: There is no disagreement with the audit finding. Finance and Public Works will coordinate the vendor bidding process and document the suspension and debarment check prior to awarding a vendor for the project.

(2023-004) Documentation of Purchasing Compliance - Significant deficiency Criteria Per CFR §180.300 and 2 CFR §200.214, the District must verify vendors are not suspended or debarred or otherwise excluded from participating in a covered transaction. This verification may be accomplished by checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA); collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity. Condition During our testing of suspension and debarment compliance, we noted that the District did not retain documentation demonstrating that vendors were verified as not suspended, debarred, or otherwise excluded from participation in federal programs prior to execution of two contracts, each with expenditures exceeding $25,000. Cause The District did not have formalized procedures to ensure suspension and debarment verifications were performed and documented prior to executing covered contracts. Effect Without adequate verification and documentation, there is a risk that the District could contract with vendors who are ineligible to receive federal funds, resulting in noncompliance with federal regulations. Questioned Costs No questioned costs were identified as a result of our procedures. Context/Sampling Two vendor contracts with expenditures greater than $25,000 were selected for testing. In both cases, the District did not provide documentation of suspension and debarment verification at the time of contract execution. Recommendation We recommend that the District implement procedures to verify vendor eligibility prior to entering into federally funded contracts. Acceptable methods include retaining a SAM.gov screenshot, obtaining vendor certification, or including a suspension and debarment clause in the contract. The District should also ensure documentation is retained in the procurement file and assign responsibility for this task to appropriate staff. Training and periodic reviews should be conducted to reinforce compliance and reduce the risk of using ineligible vendors. Management’s Corrective Action Planned Management concurs with the recommendation. IVGID will implement a procedure to document the procurement process and review of suspension and debarment for all vendors that undergo the bidding process.

(2023-005) Late Submission of Single Audit Reporting Package Criteria Per 2 CFR § 200.512(l), non-federal entities must submit the Single Audit reporting package to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor’s report or nine months after the fiscal year-end. Condition The District’s reporting package for the fiscal year ended June 30, 2023, was not submitted to the Federal Audit Clearinghouse within the required timeframe. As of the date of this report, the reporting package has not yet been submitted. Cause The District did not have adequate procedures in place to ensure timely completion of the financial audit and preparation of the reporting package. Effect The District did not comply with the Uniform Guidance submission deadline, which may impact the timeliness of federal oversight and potentially affect future federal funding decisions. Questioned Costs No questioned costs were identified as a result of our procedures. Context/Sampling The FY2023 Single audit was performed in 2025 after it was determined that the grant funds were expended on eligible activities, triggering the Single Audit requirement. The delay was due to the District not identifying the requirement timely and lacking procedures to ensure prompt submission. Recommendation We recommend that the District implement processes and internal controls to ensure future Single Audits are completed and submitted within the required timeframe. Management’s Corrective Action Planned Management concurs with the recommendation. IVGID will establish a procedure to review and reconcile grants both federal and state at year-end to determine the need for a single audit and submission to the required agencies.