EIN: 886000024
UEI: F995DBS4SRN3
Audited by: Eide Bailly, LLP
Cognizant agency: 84 [Department of Education]
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Data as of September 14, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 17, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 17, 2026 (2 days from today).
What is a management decision? →An expenditure was incurred and charged to the federal award without initially receiving or maintaining appropriate documentation to support the assertion that the expenditure was necessary and reasonable for performance of the federal award. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure appropriate documentation was initially received or maintained to support an international payment charged to a federal award. Effect: Unallowable costs may be charged to a federal award. Questioned Costs: $3,535 Context/Sampling: A nonstatistical sample of 60 ($739,423) non-payroll expenditures within the Research and Development Cluster across the Nevada System of Higher Education was selected for testing. UNR non-payroll expenditures were 26 ($266,217) of the 60 selected for testing. We noted one non-payroll transaction totaling $3,535 lacked adequate documentation. The transaction was an international wire and an agreement for the services performed, invoice for the services performed, or other appropriate documentation was not maintained. During the audit process, UNR received and subsequently provided a letter from a professor at the foreign University describing the work performed by their colleague. This letter was considered but deemed to lack the adequacy of documentation necessary to support the charge and did not address the initial internal controls necessary to process the initial payment. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure appropriate documentation is received and maintained to support international payments. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award 2133818 under assistance listing 47.047 included within the Research and Development Cluster for UNR as a direct program on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 of U.S. Code of Federal Regulation (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that costs must be, in part: • Necessary and reasonable for the performance of the award • Consistent with policies and procedures that apply uniformly to federally financed and other activities • Adequately documented Condition: An expenditure was incurred and charged to the federal award without initially receiving or maintaining appropriate documentation to support the assertion that the expenditure was necessary and reasonable for performance of the federal award. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure appropriate documentation was initially received or maintained to support an international payment charged to a federal award. Effect: Unallowable costs may be charged to a federal award. Questioned Costs: $3,535 Context/Sampling: A nonstatistical sample of 60 ($739,423) non-payroll expenditures within the Research and Development Cluster across the Nevada System of Higher Education was selected for testing. UNR non-payroll expenditures were 26 ($266,217) of the 60 selected for testing. We noted one non-payroll transaction totaling $3,535 lacked adequate documentation. The transaction was an international wire and an agreement for the services performed, invoice for the services performed, or other appropriate documentation was not maintained. During the audit process, UNR received and subsequently provided a letter from a professor at the foreign University describing the work performed by their colleague. This letter was considered but deemed to lack the adequacy of documentation necessary to support the charge and did not address the initial internal controls necessary to process the initial payment. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure appropriate documentation is received and maintained to support international payments. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles Responses UNR – 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; Supplier Invoice requests will be reviewed and approved by a manager independent of the preparer. The manager’s review will include verifying appropriate documentation is received and maintained to support payments processed. ● How compliance and performance will be measured and documented for future audit, management and performance review. The manager’s independent review and approval of each supplier invoice request, including verification of required documentation to support payments, will be tracked and attached within the system’s business process. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: 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
There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. In addition, indirect costs were unintentionally charged at a lower rate than approved. Cause: Desert Research Institute (DRI) and University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to provide for the documented review and approval of Requests for Reimbursement submitted to the grantor. Effect: Inaccurate information may be reported to the grantor, and funds may not be drawn on a reimbursement basis or for immediate cash needs and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 62 Requests for Reimbursement out of a population of 525 across the Nevada System of Higher Education was tested. The following errors were noted by institution: Desert Research Institute 11 requests were selected; nine had no evidence of review by an individual independent of the preparer. All nine requests were made prior to April 30, 2025, while the two requests with review and approval were performed in May 2025 and June 2025. University of Nevada, Las Vegas 17 requests were selected; one request applied an indirect cost rate lower than the approved rate, resulting in an under‑reimbursement of $256. Repeat Finding from Prior Year: Yes – prior year finding 2024-007. Recommendation: We recommend DRI and UNLV enhance internal controls to ensure Requests for Reimbursement are accurately prepared and include documented review and approval. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The University of Nevada, Las Vegas agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards under the Research and Development Cluster for DRI and UNLV 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. Grantors require the submission of Requests for Reimbursement. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. In addition, indirect costs were unintentionally charged at a lower rate than approved. Cause: Desert Research Institute (DRI) and University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to provide for the documented review and approval of Requests for Reimbursement submitted to the grantor. Effect: Inaccurate information may be reported to the grantor, and funds may not be drawn on a reimbursement basis or for immediate cash needs and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 62 Requests for Reimbursement out of a population of 525 across the Nevada System of Higher Education was tested. The following errors were noted by institution: Desert Research Institute 11 requests were selected; nine had no evidence of review by an individual independent of the preparer. All nine requests were made prior to April 30, 2025, while the two requests with review and approval were performed in May 2025 and June 2025. University of Nevada, Las Vegas 17 requests were selected; one request applied an indirect cost rate lower than the approved rate, resulting in an under‑reimbursement of $256. Repeat Finding from Prior Year: Yes – prior year finding 2024-007. Recommendation: We recommend DRI and UNLV enhance internal controls to ensure Requests for Reimbursement are accurately prepared and include documented review and approval. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The University of Nevada, Las Vegas agrees with this finding.
Cash Management Responses DRI – 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; Controls were implemented beginning on April 14, 2025, to require secondary approvals on all sponsored invoice transactions. NSHE’s accounting system was reconfigured to require a review step for all invoice business processes. An individual other than the preparer must now review and approve all transactions. ● How compliance and performance will be measured and documented for future audit, management and performance review. Documentation for all sponsor invoice transactions occurs through the business process history in the accounting system. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. UNLV agrees with this 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; UNLV Office of Sponsored Programs (OSP) has an internal control that requires a reconciliation form to be completed with each invoice submission. With any manual control, human error may occur, as in this case; however, the reconciliation form is used every time and is reviewed by the originator and approving authority. ● How compliance and performance will be measured and documented for future audit, management, and performance review. Reinforcement of cross-checking of the reconciliation form is enforced and will be used as documentation for review. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: 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
2024-007
Subrecipient monitoring policies are not documented, risk assessments were not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: • Desert Research Institute (DRI) • Nevada State University (NSU) • University of Nevada, Las Vegas (UNLV) • University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2025 Context/Sampling: A nonstatistical sample of 60 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute DRI had five subrecipients selected for testing out of the sample of 60. • Risk assessment was not performed for one of the subrecipients selected for testing. The subaward period of performance had ended during the year and thus a risk assessment was not deemed necessary by DRI. • Subawards were missing required information for two of the subawards to subrecipients selected for testing. These two subawards were entered into in prior years but had current year payments. We were unable to see subsequent communication (after the initial subawards) that required information had been communicated. • Monitoring activities were not documented adequately to provide for reasonable assurance that two of the subrecipients were using the award for authorized purposes and meeting performance objectives. • Audit reports for one subrecipient were not reviewed timely to ensure a management decision letter would be issued within six months of the clearinghouse acceptance date, if required. Nevada State University NSU had one subrecipient selected for testing out of the sample of 60. • Risk assessment was not performed for the subrecipient selected for testing. University of Nevada, Las Vegas UNLV had 23 subrecipients selected for testing out of the sample of 60. • UNLV does not have written subrecipient monitoring policies. • Risk assessment was not performed for four of the subrecipients selected for testing. • Subawards were missing required information for three of the subawards to subrecipients selected for testing. • Monitoring activities were not documented adequately for 21 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. • Audit reports for five subrecipients were not reviewed timely to ensure a management decision letter would be issued within six months of the clearinghouse acceptance date, if required. University of Nevada, Reno UNR had 30 subrecipients selected for testing out of the sample of 60. • Subawards were missing required information for two of the subawards to subrecipients selected for testing. • Audit reports for two subrecipients were not reviewed timely to ensure a management decision letter would be issued within six months of the clearinghouse acceptance date, if required. Repeat Finding from Prior Year: Yes – prior year finding 2024-009. Recommendation: We recommend UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding. The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR 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 200.332 requires that: • Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. • Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. • Pass-through entities ensure that every subaward includes certain information at the time of the subaward. • Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. • Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessments were not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: • Desert Research Institute (DRI) • Nevada State University (NSU) • University of Nevada, Las Vegas (UNLV) • University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2025 Context/Sampling: A nonstatistical sample of 60 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute DRI had five subrecipients selected for testing out of the sample of 60. • Risk assessment was not performed for one of the subrecipients selected for testing. The subaward period of performance had ended during the year and thus a risk assessment was not deemed necessary by DRI. • Subawards were missing required information for two of the subawards to subrecipients selected for testing. These two subawards were entered into in prior years but had current year payments. We were unable to see subsequent communication (after the initial subawards) that required information had been communicated. • Monitoring activities were not documented adequately to provide for reasonable assurance that two of the subrecipients were using the award for authorized purposes and meeting performance objectives. • Audit reports for one subrecipient were not reviewed timely to ensure a management decision letter would be issued within six months of the clearinghouse acceptance date, if required. Nevada State University NSU had one subrecipient selected for testing out of the sample of 60. • Risk assessment was not performed for the subrecipient selected for testing. University of Nevada, Las Vegas UNLV had 23 subrecipients selected for testing out of the sample of 60. • UNLV does not have written subrecipient monitoring policies. • Risk assessment was not performed for four of the subrecipients selected for testing. • Subawards were missing required information for three of the subawards to subrecipients selected for testing. • Monitoring activities were not documented adequately for 21 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. • Audit reports for five subrecipients were not reviewed timely to ensure a management decision letter would be issued within six months of the clearinghouse acceptance date, if required. University of Nevada, Reno UNR had 30 subrecipients selected for testing out of the sample of 60. • Subawards were missing required information for two of the subawards to subrecipients selected for testing. • Audit reports for two subrecipients were not reviewed timely to ensure a management decision letter would be issued within six months of the clearinghouse acceptance date, if required. Repeat Finding from Prior Year: Yes – prior year finding 2024-009. Recommendation: We recommend UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding. The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Reno agrees with this finding.
Subrecipient Monitoring Responses DRI – 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; o DRI implemented controls to require the documentation of risk assessment procedures for all subawards issued beginning in November 2024. Depending on the results of the risk assessment, monitoring procedures are designed to ensure compliance. o DRI will review all subawards issued in prior years that are still active. For any that may be missing required information, communication will be sent to the subrecipient by March 31, 2026. o DRI will ensure future monitoring activities are adequately documented. Currently, procedures do require those knowledgeable of subaward activities to review and approve subaward invoices. Procedures will be updated beginning in February 2026 to include an intermittent review of supporting documentation for invoices received based on the subrecipient’s level of risk. o DRI will update procedures to ensure subrecipient audit reports are collected timely beginning in February 2026. ● How compliance and performance will be measured and documented for future audit, management and performance review. Documentation will be maintained in DRI’s pre-award system or in the accounting system, as appropriate, to ensure compliance. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. NSU – 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; Nevada State University (NSU) has implemented procedures and staff training to ensure that a risk assessment tool/checklist is completed prior to issuance of a subaward. ● How compliance and performance will be measured and documented for future audit, management and performance review. NSU will conduct a risk assessment using a checklist prior to issuing a subaward. NSU will request and review prospective subrecipients’ annual financial statements and audit reports and will verify suspension and debarment status. Based on the results of this review, NSU will adjust subrecipient monitoring as appropriate. All risk assessments, reviews, and monitoring activities will be documented and maintained in the subrecipient files and in Workday. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Director of Grants Award Services will be responsible with additional oversight by the Associate Vice President of Fiscal Services. UNLV agrees with this 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; UNLV OSP has implemented a comprehensive policies and procedures document, in place as of July 2025, covering the entire subrecipient lifecycle and includes internal controls such as a checklist, review of risk before issuance, a biannual sub monitoring review of financial audit, and Authorized purposes review. Additional reviews of the policy and procedures are conducted throughout the fiscal year to ensure the related practices are relevant and effective, with adjustments made as necessary. ● How compliance and performance will be measured and documented for future audit, management and performance review. Per the UNLV OSP policy, documentation is required throughout the lifecycle and will be used for future audits. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. UNR – 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; All required subaward documents will be retained in a centralized database for easy access and compliance tracking. Subaward Specialist will review subrecipient audit reports timely to ensure a management decision letter will be issued within six months of the clearinghouse acceptance date if required. ● How compliance and performance will be measured and documented for future audit, management and performance review. Once subrecipient letters of certification have been issued, management will perform a monthly reconciliation to ensure completeness and timely follow-up. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Pre Award Official Contact: 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
2024-009
Documentation was not maintained to support the cash on hand balances for Pell drawdowns and subsequent disbursements to determine if funds were disbursed within three business days. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure the Pell disbursement roster was retained to support the draw amount and demonstrate compliance with immediate cash needs. Effect: Funds may have been drawn in advance of immediate cash needs. Questioned Costs: None Context/Sampling: A nonstatistical sample of ten out of a population of 64 draw requests was selected for testing. Four of the ten draw requests were related to Pell totaling $15,457,354. UNR was unable to provide support to address immediate cash needs for three of the four draw requests, totaling $14,328,466. However, UNR was able to provide support that the aggregate disbursement of Pell was consistent with total Pell drawdowns for the year. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure the Pell disbursement roster is retained to support the draw request and demonstrate compliance with immediate cash needs. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education and U.S. Department of Health and Human Services Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Cash Management Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards under assistance listing 84.063 included in the Student Financial Assistance Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: An institution requests funds under the advance, reimbursement, or heighted cash monitoring payment methods. For purposes of determining compliance with cash management requirements to minimize time between funds transfer and disbursement, a disbursement of funds occurs on the date an institution credits a student’s account or pays a student or parent directly with either Title IV funds or institutional funds used in advance of drawing down federal funds (34 CFR 668.164(a)(1)(i) & (ii)). Under the advance payment method, an institution submits a request for funds. The institution’s request may not exceed the amount of funds the institution needs immediately for disbursements the institution has made or will make to eligible students. The institution must disburse the funds requested as soon as administratively feasible but no later than three business days following the date the institution received those funds (34 CFR 668.162(b)). Condition: Documentation was not maintained to support the cash on hand balances for Pell drawdowns and subsequent disbursements to determine if funds were disbursed within three business days. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure the Pell disbursement roster was retained to support the draw amount and demonstrate compliance with immediate cash needs. Effect: Funds may have been drawn in advance of immediate cash needs. Questioned Costs: None Context/Sampling: A nonstatistical sample of ten out of a population of 64 draw requests was selected for testing. Four of the ten draw requests were related to Pell totaling $15,457,354. UNR was unable to provide support to address immediate cash needs for three of the four draw requests, totaling $14,328,466. However, UNR was able to provide support that the aggregate disbursement of Pell was consistent with total Pell drawdowns for the year. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure the Pell disbursement roster is retained to support the draw request and demonstrate compliance with immediate cash needs. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Cash Management Responses UNR – 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 Financial Aid Office has implemented enhanced reconciliation and cash management procedures designed to strengthen internal controls and mitigate future risk. The monthly reconciliation process has been revised to ensure that each reconciliation clearly documents all outstanding items, including timing differences and variances. ● How compliance and performance will be measured and documented for future audit, management and performance review. Under the revised process, the Assistant Director for Compliance and Processing ensures drawdowns are supported by detailed reconciliation schedules, discrepancies are formally identified and tracked, and resolution occurs within established timeframes. The updated procedures have been fully implemented and are operating as designed. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Assistant Director for Compliance and Processing and the Interim Financial Aid Director. Official Contact: 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
Pell was disbursed to graduate students who were not eligible as they did not meet the criteria for an allowable exception. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to monitor Pell eligibility for students who were initially enrolled as an undergraduate (for example in the Fall) and re-enrolled as a graduate student within the school year (for example in the Spring). Effect: Over-awards of the Pell Grant were made. Questioned Costs: $3,144 Context/Sampling: A nonstatistical sample of 60 out of a population of 4,289 students who had Title IV disbursements was selected for testing. The total Title IV aid provided in the sample was $571,500, of which $153,212 were Pell Grants (37 students). We noted three students were initially enrolled as an undergraduate student in the Fall 2024 and as a graduate student in Spring 2025. These three graduate students received a Pell Grant totaling $3,144, when they were no longer eligible. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure Pell eligibility is reassessed for students that are initially enrolled as undergraduate and re-enroll as a graduate student within the school year. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education and U.S. Department of Health and Human Services Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Eligibility Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards under assistance listing 84.063 under the Student Financial Assistance Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: A student is eligible to receive a Federal Pell Grant for the period of time required to complete his or her first undergraduate baccalaureate course of study. An otherwise eligible student who has a baccalaureate degree and is enrolled in a postbaccalaureate program is eligible to receive a Federal Pell Grant for the period of time necessary to complete the program if: • The postbaccalaureate program consists of courses that are required by a State for the student to receive a professional certification or licensing credential that is required for employment as a teacher in an elementary or secondary school in that State; • The postbaccalaureate program does not lead to a graduate degree; • The institution offering the postbaccalaureate program does not also offer a baccalaureate degree in education; • The student is enrolled as at least a half-time student; and • The student is pursuing an initial teacher certification or licensing credential within the State (34 CFR 690.6). Condition: Pell was disbursed to graduate students who were not eligible as they did not meet the criteria for an allowable exception. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to monitor Pell eligibility for students who were initially enrolled as an undergraduate (for example in the Fall) and re-enrolled as a graduate student within the school year (for example in the Spring). Effect: Over-awards of the Pell Grant were made. Questioned Costs: $3,144 Context/Sampling: A nonstatistical sample of 60 out of a population of 4,289 students who had Title IV disbursements was selected for testing. The total Title IV aid provided in the sample was $571,500, of which $153,212 were Pell Grants (37 students). We noted three students were initially enrolled as an undergraduate student in the Fall 2024 and as a graduate student in Spring 2025. These three graduate students received a Pell Grant totaling $3,144, when they were no longer eligible. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure Pell eligibility is reassessed for students that are initially enrolled as undergraduate and re-enroll as a graduate student within the school year. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Eligibility Responses UNR – 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 Financial Aid Office has implemented a daily query to check for awards not matching the academic program and level. The query is run by the data team and then again by the Compliance team to mitigate improper awarding due to manual changes. ● How compliance and performance will be measured and documented for future audit, management and performance review. This revised process ensures that any mismatched program awards are resolved without negatively impacting students and resolution occurs within established time frames. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Assistant Director for Compliance and Processing, Program Manager of Federal Funding, and the Interim Financial Aid Director. Official Contact: 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
One instance identified in which Title IV funds were not returned within the required allotted time. Cause: The College of Southern Nevada did not have adequate internal controls to ensure funds were returned within the required timeframe. Effect: The U.S. Department of Education did not receive returns timely. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 out of a population of 4,576 student returns was selected for testing. One return of the 60 tested was late. The return occurred after 53 days, rather than the 45 required. Repeat Finding from Prior Year: Yes – prior year finding 2024-011. Recommendation: We recommend CSN enhance internal controls to ensure funds are returned within the required timeframe. Views of Responsible Officials: The College of Southern Nevada agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education and U.S. Department of Health and Human Services Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Special Tests & Provisions – Return of Title IV (R2T4) Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included in the Student Financial Assistance Cluster for CSN on the Schedule of Expenditures of Federal Awards. Criteria: In accordance with 34 CFR 668.173(b) when a return of Title IV aid is required, an institution has 45 days (or 30 days for students that never began attendance) to return the funds to Ed. Condition: One instance identified in which Title IV funds were not returned within the required allotted time. Cause: The College of Southern Nevada did not have adequate internal controls to ensure funds were returned within the required timeframe. Effect: The U.S. Department of Education did not receive returns timely. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 out of a population of 4,576 student returns was selected for testing. One return of the 60 tested was late. The return occurred after 53 days, rather than the 45 required. Repeat Finding from Prior Year: Yes – prior year finding 2024-011. Recommendation: We recommend CSN enhance internal controls to ensure funds are returned within the required timeframe. Views of Responsible Officials: The College of Southern Nevada agrees with this finding.
Special Tests & Provisions – Return of Title IV (R2T4) Responses 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; CSN added additional resources to the R2T4 program by hiring a Senior Specialist to ensure R2T4 queries are frequently run, and accounts are reviewed on a weekly basis. CSN also contracted the services of a PeopleSoft consultant to assess, streamline, and automate R2T4 queries. Additionally, R2T4 staff, PeopleSoft Consultant and third-party vendor meet on an ongoing basis and implement necessary changes to meet compliance requirements. CSN is also providing professional development opportunities to staff through our trade organizations. ● How compliance and performance will be measured and documented for future audit, management and performance review. Under the direction of the Assistant Director, the newly hired Senior Specialist position runs queries and assigns identified files to staff twice a week to ensure accounts are reviewed within the federally mandated timeframe. CSN also continues to train staff on the processing of R2T4 and schedule regular team meetings to ensure updates and changes are communicated in real time and R2T4 procedures are applied accurately and consistently. CSN continues to perform quality control through the review of processed R2T4 files. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Director of Financial Aid will be responsible. Official Contact: 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
2024-011
Change in enrollment status was not reported accurately or timely. Cause: The College of Southern Nevada (CSN) did not have adequate internal controls to ensure changes in a student’s enrollment status were correctly reported to the National Student Clearinghouse. The Nevada State University (NSU) did not have adequate internal controls to ensure timely reporting of the change in enrollment status. Effect: Non-timely and inaccurate reporting to the NSLDS could potentially impact future eligibility determinations and repayment provisions. Questioned Costs: None Context/Sampling: For CSN, a nonstatistical sample of 60 out of a population of 3,506 students who had a change in their enrollment status was selected for testing. We noted the date of change for one student was not reported accurately. School records did not agree to the NSLDS by 53 days for the one student. For NSU, a nonstatistical sample of 60 out of a population of 748 students who had a change in their enrollment status was selected for testing. We noted two enrollment status changes were not reported timely. One change was reported after 68 days and the other after 155 days. Repeat Finding from Prior Year: Yes – prior year finding 2024-012 (NSU only). Recommendation: We recommend CSN enhance internal controls to ensure accurate reporting of the change in enrollment status. We recommend NSU enhance internal controls to ensure timely reporting of the change in enrollment status. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. The Nevada State University agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education and U.S. Department of Health and Human Services Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Special Tests & Provisions – Enrollment Reporting Material Weakness in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included in the Student Financial Assistance Cluster for CSN and NSU on the Schedule of Expenditures of Federal Awards. Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statues, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. Condition: Change in enrollment status was not reported accurately or timely. Cause: The College of Southern Nevada (CSN) did not have adequate internal controls to ensure changes in a student’s enrollment status were correctly reported to the National Student Clearinghouse. The Nevada State University (NSU) did not have adequate internal controls to ensure timely reporting of the change in enrollment status. Effect: Non-timely and inaccurate reporting to the NSLDS could potentially impact future eligibility determinations and repayment provisions. Questioned Costs: None Context/Sampling: For CSN, a nonstatistical sample of 60 out of a population of 3,506 students who had a change in their enrollment status was selected for testing. We noted the date of change for one student was not reported accurately. School records did not agree to the NSLDS by 53 days for the one student. For NSU, a nonstatistical sample of 60 out of a population of 748 students who had a change in their enrollment status was selected for testing. We noted two enrollment status changes were not reported timely. One change was reported after 68 days and the other after 155 days. Repeat Finding from Prior Year: Yes – prior year finding 2024-012 (NSU only). Recommendation: We recommend CSN enhance internal controls to ensure accurate reporting of the change in enrollment status. We recommend NSU enhance internal controls to ensure timely reporting of the change in enrollment status. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. The Nevada State University agrees with this finding.
Special Tests & Provisions – Enrollment Reporting Responses 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; CSN is implementing additional validation steps in the monthly learinghouse report submission process to ensure all required information is accurate and complete. In addition, a monthly quality control review will be conducted on submitted data. Ongoing professional development will also be provided through scheduled monthly and annual trainings, as well as on an ad hoc basis as needed. ● How compliance and performance will be measured and documented for future audit, management and performance review. Under the direction of the Assistant Registrar, the Program Officer II responsible for processing enrollment reporting submissions will distribute error report data. The Assistant Registrar will also conduct a monthly validation by reviewing a random sample of files on the Clearinghouse website to ensure accurate submissions. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Registrar will be responsible. NSU – 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; NSU has reviewed the finding and continues to monitor measures that have been put in place to ensure compliance. Also, some additional procedures have been identified and others further refined. All processes will be fully in place within the next 30 to 45 days. o Continue bi-weekly enrollment reporting schedule to the National Student Clearinghouse (NSC). o Maintain bi-weekly calendar reminders to ensure timely submission of enrollment updates, supplementing NSC notifications. o Establish end-of-term calendar reminders to ensure prompt reporting of graduated statuses. o Continue coordination with NSC to identify students included in submitted enrollment reports whose statuses were not updated. o Review NSC response and reject files following each submission to identify discrepancies. Address any identified discrepancies promptly, even if students do not appear in the reject file. Confirm that updated enrollment statuses are reflected within the National Student Loan Data System (NSLDS). o Maintain documentation of submission dates and communications with NSC. ● How compliance and performance will be measured and documented for future audit, management and performance review. To ensure compliance and strengthened performance in reporting changes in student enrollment status, Nevada State University (NSU) will continue and enhance the following tracking, monitoring, and documentation measures: o NSU will conduct documented monthly reconciliations of enrollment status reports to verify the accuracy, completeness, and timeliness of submissions to the National Student Clearinghouse (NSC). These reviews will include confirmation of submission dates, validation of reported status changes, and resolution of any identified discrepancies prior to the next reporting cycle. o Detailed logs of all enrollment status submissions and NSC notifications will be maintained and centrally retained. Documentation will include timestamps, submission confirmations, reconciliation records, exception reports, and evidence of follow-up actions to ensure a clear and complete audit trail. o Periodic internal compliance reviews will be conducted to assess adherence to the bi-weekly and end-of-term reporting schedule. Review results will be formally documented and provided to management to support oversight and continuous process improvement. o Key performance indicators (KPIs) will continue to be tracked and formally reviewed on a quarterly basis. These KPIs will include: Percentage of reports submitted within required timelines Accuracy rate of enrollment status updates Timeliness of discrepancy resolution o Any discrepancies identified during monthly reconciliations or internal reviews will be addressed promptly, with documented corrective actions, assigned responsible parties, and established resolution timelines. o NSU will compile an annual compliance summary outlining monitoring activities, audit results, corrective actions implemented, and overall performance metrics. This report will be maintained for executive oversight and future audit and management review. o Beginning in March 2026, these measures outlined above will be formally documented and maintained to ensure ongoing compliance. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Student Information and Scheduling Systems Analyst is primarily responsible for ensuring accurate and timely enrollment status reporting. A new Registrar assumed the role at the start of FY2026 and has begun overseeing compliance with established internal controls, including bi-weekly and end-of-term reporting requirements. Official Contact: 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
2024-012
The GLBA Information Security Program did not address some of the required safeguards. Cause: Updates were made to the UNLV’s written information security program. However, UNLV did not have adequate internal controls to ensure all required elements under the GLBA were addressed within the updated program. Effect: Certain elements of security required by the GLBA may not be adhered to. Questioned Costs: None Context/Sampling: No sampling was performed. The GLBA Information Security Program for UNLV was reviewed for compliance in its entirety. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV enhance internal controls to ensure all required Gramm-Leach-Bliley Act provisions are included within the written information security program. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education and U.S. Department of Health and Human Services Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Special Tests & Provisions – Gramm-Leach-Bliley Act – Student Information Security Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included in the Student Financial Assistance Cluster for UNLV on the Schedule of Expenditures of Federal Awards. Criteria: The Gramm-Leach Bliley Act (Public Law 106-102) (GLBA) requires financial institutions to explain their information-sharing practices to their customers and to safeguard sensitive data (16 CFR 314). The Federal Trade Commission considers Title IV-eligible institutions that participate in Tile IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi). Under an institution’s Program Participation Agreement with the Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial assistance information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs (16 CFR 314.3; HEA 483(a)(3)(E) and HEA 485B(d)(2)). The GLBA requires, in part, the following safeguards to be addressed in the written information security program: • Encryption of customer information on the institution’s system and when it’s in transit • Implementation of multi-factor authentication for anyone accessing customer information on the institution’s system • Disposition of customer information securely • Maintenance of a log of authorized users’ activity and unauthorized access Condition: The GLBA Information Security Program did not address some of the required safeguards. Cause: Updates were made to the UNLV’s written information security program. However, UNLV did not have adequate internal controls to ensure all required elements under the GLBA were addressed within the updated program. Effect: Certain elements of security required by the GLBA may not be adhered to. Questioned Costs: None Context/Sampling: No sampling was performed. The GLBA Information Security Program for UNLV was reviewed for compliance in its entirety. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV enhance internal controls to ensure all required Gramm-Leach-Bliley Act provisions are included within the written information security program. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Special Tests & Provisions – Gramm-Leach-Bliley Act – Student Information Security Responses UNLV 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; UNLV Office of Information Technology (OIT) notes that all safeguards noted within the finding are in place and operating effectively. The action necessary relates to an update within the written information security program. This corrective action was taken immediately at the beginning of the current fiscal year, with the updated UNLV written information security program effective July 2025. ● How compliance and performance will be measured and documented for future audit, management and performance review. The UNLV Chief Information Security Officer will review the written information security program at least annually, to occur by the end of each fiscal year, to ensure documentation matches the control environment in practice. Additionally, UNLV engages a third party to perform a robust review of the overall GLBA environment to ensure the institution is appropriately addressing risk areas (most recently in FY25). ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The GLBA regulation requires designation of a Qualified Individual within the organization who is responsible for overseeing and implementing the Information Security Program. At UNLV, this is the Chief Information Security Officer and this individual is the responsible party to exercise oversight and accountability in this area. Official Contact: 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
Certain costs claimed under cost sharing were not adequately documented or verifiable. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure costs claimed for cost share were adequately documented and verifiable. Effect: Unallowable costs may be used to meet cost sharing requirements. Questioned Costs: $133,988 (cost-sharing) Context/Sampling: A nonstatistical sample of eight ($23,751) cost-share expenditure transactions out of a population of 48 ($144,572) cost-share expenditures were selected for testing at UNLV. Five of the eight transactions consisted of payroll costs that were used for cost share. There was no time and effort documentation to support the actual time spent on the activities to ensure the payroll allocated to cost share was appropriate. We received a summary in the aggregate, noting $110,143 in total payroll was used as cost share. For one transaction, a shared facility in-kind cost at the subrecipient was used for cost sharing, but support to determine the appropriateness of the in-kind valuation was not maintained. We received a summary in the aggregate, noting $23,845 in total for this in-kind valuation was used as cost share. Repeat Finding from Prior Year: No Recommendation: We recommend that UNLV enhance internal controls to ensure costs claimed for cost share are adequately documented and verifiable. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Commerce Direct and Pass-through Nevadaworks as listed in the Schedule of Expenditures of Federal Awards Economic Development Cluster, 11.307 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Affects grant award 077907854 included under assistance listing 11.307 as a direct award for UNLV 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 200.306 requires, in part, that: Cost sharing funds must: • Be verifiable in the recipient's records • Be necessary and reasonable for achieving objectives of the Federal award • Be allowable under subpart E, which requires costs to be: o Consistent with policies and procedures that apply uniformly to federally financed and other activities o Adequately documented o For personnel expenses, documentation must support the distribution of the employee’s salary or wages Condition: Certain costs claimed under cost sharing were not adequately documented or verifiable. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure costs claimed for cost share were adequately documented and verifiable. Effect: Unallowable costs may be used to meet cost sharing requirements. Questioned Costs: $133,988 (cost-sharing) Context/Sampling: A nonstatistical sample of eight ($23,751) cost-share expenditure transactions out of a population of 48 ($144,572) cost-share expenditures were selected for testing at UNLV. Five of the eight transactions consisted of payroll costs that were used for cost share. There was no time and effort documentation to support the actual time spent on the activities to ensure the payroll allocated to cost share was appropriate. We received a summary in the aggregate, noting $110,143 in total payroll was used as cost share. For one transaction, a shared facility in-kind cost at the subrecipient was used for cost sharing, but support to determine the appropriateness of the in-kind valuation was not maintained. We received a summary in the aggregate, noting $23,845 in total for this in-kind valuation was used as cost share. Repeat Finding from Prior Year: No Recommendation: We recommend that UNLV enhance internal controls to ensure costs claimed for cost share are adequately documented and verifiable. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Matching, Level of Effort, and Earmarking Responses UNLV agrees with this 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 UNLV OSP has mandated a required cost share form to be completed and will require that the documentation be attached and verified before submission to the sponsor. For effort identified as cost share, a new process is currently being tested to capture it in the financial system. The cost share policy will be updated before the end of spring semester and disseminated to the campus community for immediate implementation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Verifiable documentation will be required upon review/submission to be uploaded with the financial report in Workday. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with Principal Investigator’s documentation. Official Contact: 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
There was no evidence of review and approval (segregation of duties) between preparer and reviewer. Cause: The following institutions at the Nevada System of Higher Education did not have adequate internal controls to provide for the documented review and approval of reports submitted to the pass-through entity or federal agency: • Western Nevada College (WNC) • Truckee Meadows Community College (TMCC) • University of Nevada, Las Vegas (UNLV) Effect: Inaccurate information may be reported and not detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 14 Requests for Reimbursement out of a population of 96 across the Nevada System of Higher Education was selected for testing. The entire population of one subaward report required by FFATA submitted during the year was selected for testing. The following errors are noted by institution: Western Nevada College Four of the 14 Requests for Reimbursement were applicable to WNC. We noted that there was no evidence of review on one (the August 2024 submission) of the four Requests for Reimbursement that were tested. Truckee Meadows Community College Five of the 14 Requests for Reimbursement were applicable to TMCC. We noted that there was no evidence of review on one (January 2025 submission) of the five Requests for Reimbursement that were tested. University of Nevada, Las Vegas We noted there was no evidence of review for the one subaward report required by the FFATA. Repeat Finding from Prior Year: No Recommendation: We recommend the Nevada System of Higher Education institutions listed above enhance internal controls to provide for the documented review and approval of reports submitted to grantors. Views of Responsible Officials: The Western Nevada College agrees with this finding. The Truckee Meadows Community College agrees with this finding. The University of Nevada, Las Vegas agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Commerce Direct and Pass-through Nevadaworks as listed in the Schedule of Expenditures of Federal Awards Economic Development Cluster, 11.307 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 11.307 for WNC, UNLV, and TMCC 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. The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information. The pass-through entity requires the submission of Requests for Reimbursement. Condition: There was no evidence of review and approval (segregation of duties) between preparer and reviewer. Cause: The following institutions at the Nevada System of Higher Education did not have adequate internal controls to provide for the documented review and approval of reports submitted to the pass-through entity or federal agency: • Western Nevada College (WNC) • Truckee Meadows Community College (TMCC) • University of Nevada, Las Vegas (UNLV) Effect: Inaccurate information may be reported and not detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 14 Requests for Reimbursement out of a population of 96 across the Nevada System of Higher Education was selected for testing. The entire population of one subaward report required by FFATA submitted during the year was selected for testing. The following errors are noted by institution: Western Nevada College Four of the 14 Requests for Reimbursement were applicable to WNC. We noted that there was no evidence of review on one (the August 2024 submission) of the four Requests for Reimbursement that were tested. Truckee Meadows Community College Five of the 14 Requests for Reimbursement were applicable to TMCC. We noted that there was no evidence of review on one (January 2025 submission) of the five Requests for Reimbursement that were tested. University of Nevada, Las Vegas We noted there was no evidence of review for the one subaward report required by the FFATA. Repeat Finding from Prior Year: No Recommendation: We recommend the Nevada System of Higher Education institutions listed above enhance internal controls to provide for the documented review and approval of reports submitted to grantors. Views of Responsible Officials: The Western Nevada College agrees with this finding. The Truckee Meadows Community College agrees with this finding. The University of Nevada, Las Vegas agrees with this finding.
Reporting Responses TMCC – 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; Two additional layers of review have been added to ensure that every RFR/Invoice is reviewed. On 4/14/25 an extra invoice review was added to Workday ensuring that they have to go through a review by someone other than the creator. During this step, the attachments including RFR and the approval email by the controller is also reviewed for accuracy. The Grant Accountant also established a log in August of 2025 that includes the Due Date, Date sent to the Controller for Approval, the Approval date and the submission date. ● How compliance and performance will be measured and documented for future audit, management and performance review. Emails documenting the review of the RFRs are kept as proof of review and saved in our files as well as Workday. The tracking document will also be made available for future review. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Grant Accountants will be responsible for ensuring that we are in compliance with the corrective actions UNLV agrees with this 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; UNLV OSP does have separation of duties from the originator of the subaward to the review of the subaward agreement in entering all of the data points into Sam.gov for FFATA reporting; however, UNLV OSP will create a process document that explicitly notes this for future documentation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Cross checking of the issued subaward (originator) is reviewed and entered into the federal portal by the submitter. As the federal portal requires one party to enter and submit, OSP management perceives this to be very low risk but will ensure reviews occur. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. 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 implemented the practice of invoice review (proper segregation of duties) in October 2024, in which all invoices are reviewed from an individual separate from the preparer. This practice has been in place since our October 2024 grant billing period and has continued ever since. This audit finding resulted from the auditor selecting a transaction prior to WNC implementing the new procedure. All other transactions selected by the auditor were in compliance. ● How compliance and performance will be measured and documented for future audit, management and performance review. All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Vice President of Finance & Administration may be held accountable in the future if repeat or similar observations are noted. Official Contact: 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
Subrecipient monitoring policies are not documented and subrecipient audit reports were not reviewed or confirmed to not be required. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls in place to ensure subrecipients obtained required single audits or confirmed they were not required to have one. Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: No sampling was used; there is only one subrecipient applicable to this program. UNLV does not have risk-based monitoring policies for its subrecipients. In addition, for the one subrecipient tested, an inquiry was performed by UNLV to receive the single audit from the subrecipient. There was no documentation available that the subrecipient ever responded to the inquiry or that UNLV concluded the inquiry with whether a single audit was required or not. Repeat Finding from Prior Year: No Recommendation: We recommend that UNLV establish subrecipient monitoring policies and enhance internal controls to ensure subrecipients obtain a required single audit or confirm they are not required to have one. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Commerce Direct and Pass-through Nevadaworks as listed in the Schedule of Expenditures of Federal Awards Economic Development Cluster, 11.307 Subrecipient Monitoring Material Weakness in Internal Controls of Compliance Grant Award Number: Affects grant award 077907854 included under assistance listing 11.307 as a direct award for UNLV 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 200.332 requires that: • Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. • Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented and subrecipient audit reports were not reviewed or confirmed to not be required. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls in place to ensure subrecipients obtained required single audits or confirmed they were not required to have one. Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: No sampling was used; there is only one subrecipient applicable to this program. UNLV does not have risk-based monitoring policies for its subrecipients. In addition, for the one subrecipient tested, an inquiry was performed by UNLV to receive the single audit from the subrecipient. There was no documentation available that the subrecipient ever responded to the inquiry or that UNLV concluded the inquiry with whether a single audit was required or not. Repeat Finding from Prior Year: No Recommendation: We recommend that UNLV establish subrecipient monitoring policies and enhance internal controls to ensure subrecipients obtain a required single audit or confirm they are not required to have one. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Subrecipient Monitoring Responses UNLV agrees with this 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; UNLV OSP has implemented a comprehensive policies and procedures document covering the entire subrecipient lifecycle, which includes internal controls such as a checklist, review of risk before issuance, a biannual sub monitoring review of financial audit, and authorized purposes review. ● How compliance and performance will be measured and documented for future audit, management and performance review. The internal controls within the annual audit review process will require a response and escalation, as needed, for multiple follow-ups to enhance sub monitoring. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: 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
Expenditures charged to the grant were incurred outside of the period of performance. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure that costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($38,351) out of a population of 833 ($309,363) non-payroll expenditures at UNR was selected for testing. We noted two transactions, totaling $642, that were charged to the grant for costs incurred between January 2024 and May 2024, which was prior to the period of performance. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of the Interior BLM Fuels Management and Community Fire Assistance Program Activities, 15.228 Period of Performance Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant awards L25AC00118-00 and L24AC00252 included under assistance listing 15.228 as direct awards for UNR 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) provides that a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The terms and conditions of the grant agreements specified that the period of performance began on January 1, 2025 for award L25AC00118-00 and July 1, 2024 for award L24AC00252. Condition: Expenditures charged to the grant were incurred outside of the period of performance. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure that costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($38,351) out of a population of 833 ($309,363) non-payroll expenditures at UNR was selected for testing. We noted two transactions, totaling $642, that were charged to the grant for costs incurred between January 2024 and May 2024, which was prior to the period of performance. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Period of Performance Responses UNR – 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; Training will be provided to all relevant staff on cost allowability and period of performance requirements. This training will reinforce that costs must be incurred within approved project period. ● How compliance and performance will be measured and documented for future audit, management and performance review. Completion of staff training will be tracked and documented. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: 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
There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure the documented review and approval of subaward information required under the Federal Funding Accountability and Transparency Act (FFATA). Effect: Inaccurate information may be reported and not detected. Questioned Costs: None Context/Sampling: The entire population of one subaward report submitted during the year was selected for testing. We noted there was no evidence of review for the one subaward report required by the FFATA. Repeat Finding from Prior Year: No Recommendation: We recommend that UNR enhance internal controls to ensure the documented review and approval of subaward information required under FFATA. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of the Interior BLM Fuels Management and Community Fire Assistance Program Activities, 15.228 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award L24AC00252 included under assistance listing 15.228 as a direct award for UNR 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. The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure the documented review and approval of subaward information required under the Federal Funding Accountability and Transparency Act (FFATA). Effect: Inaccurate information may be reported and not detected. Questioned Costs: None Context/Sampling: The entire population of one subaward report submitted during the year was selected for testing. We noted there was no evidence of review for the one subaward report required by the FFATA. Repeat Finding from Prior Year: No Recommendation: We recommend that UNR enhance internal controls to ensure the documented review and approval of subaward information required under FFATA. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Reporting Responses UNR – 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; Management Staff, independent of preparer, will review each subaward report required. The review process will include verifying that all subaward information required by FFATA is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify the information in each report is accurate. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Pre Award Official Contact: 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
There was no evidence of review and approval (segregation of duties) between the prepare and reviewer. Information reported to the pass‑through entity did not agree with the underlying supporting records. Cause: The following institutions of the Nevada System of Higher Education did not have adequate internal controls to provide for the documented review and approval of reports submitted to the pass-through entity: • University of Nevada, Reno (UNR) • University of Nevada, Las Vegas (UNLV) Effect: Inaccurate information was reported to the pass-through entity by UNLV and inaccurate information may be reported to the pass-through entity by UNR and not detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine Quarterly Progress Reports out of a population of 54 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2025 The following errors were noted by institution: University of Nevada, Las Vegas Four of the nine Quarterly Progress Reports were applicable to UNLV. For all four reports sampled, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer.University of Nevada, Reno Four of the nine Quarterly Progress Reports were applicable to UNR. We noted there was no evidence of review for one of the four Quarterly Progress Reports. Repeat Finding from Prior Year: Yes – prior year finding 2024-014. Recommendation: We recommend UNR and UNLV enhance internal controls to provide for documented review and approval of reports submitted to the pass-through entities and ensure amounts are supported by underlying records. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Treasury Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Coronavirus State and Local Fiscal Recovery Fund, 21.027 Reporting Material Weakness in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 21.027 for UNLV and UNR as reported in 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. The OMB Compliance Supplement provides that reporting requirements for subrecipients are as specified by the pass-through entity. The pass-through entities required the submission of Quarterly Progress Reports. Condition: There was no evidence of review and approval (segregation of duties) between the prepare and reviewer. Information reported to the pass‑through entity did not agree with the underlying supporting records. Cause: The following institutions of the Nevada System of Higher Education did not have adequate internal controls to provide for the documented review and approval of reports submitted to the pass-through entity: • University of Nevada, Reno (UNR) • University of Nevada, Las Vegas (UNLV) Effect: Inaccurate information was reported to the pass-through entity by UNLV and inaccurate information may be reported to the pass-through entity by UNR and not detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of nine Quarterly Progress Reports out of a population of 54 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2025 The following errors were noted by institution: University of Nevada, Las Vegas Four of the nine Quarterly Progress Reports were applicable to UNLV. For all four reports sampled, there was no evidence of review and approval (segregation of duties) between the preparer and the reviewer.University of Nevada, Reno Four of the nine Quarterly Progress Reports were applicable to UNR. We noted there was no evidence of review for one of the four Quarterly Progress Reports. Repeat Finding from Prior Year: Yes – prior year finding 2024-014. Recommendation: We recommend UNR and UNLV enhance internal controls to provide for documented review and approval of reports submitted to the pass-through entities and ensure amounts are supported by underlying records. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
Reporting Responses UNLV agrees with this 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 UNLV OSP will continue to work with PIs to ensure there is a documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. Additionally, if reports require financial expenditures, OSP will require validation before submission. Communication dissemination will occur twice within the academic year. ● How compliance and performance will be measured and documented for future audit, management and performance review. UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with the applicable Deans. UNR – 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; Management staff, independent of preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: 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
2024-014
There was no evidence of review and approval (segregation of duties) of certain payroll expenditures charged to the grant. Cause: The Great Basin College (GBC) did not have adequate internal controls to provide for documented review and approval of payroll costs for terminated employees charged to the grant program. Effect: Inaccurate payroll expenses may be recorded to the federal grant and remain undetected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 ($299,78) out of a population of 402 ($1,245,527) payroll expenditures across the Nevada System of Higher Education was selected for testing. GBC payroll expenditures were 15 ($115,473) of the 60 selected for testing. There were two payroll charges ($10,704) for one terminated employee that did not have evidence of review and approval. Repeat Finding from Prior Year: No Recommendation: We recommend GBC enhance internal controls to provide for documented review and approval for terminated employees charged to the grant program. Views of Responsible Officials: The Great Basin College agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Career and Technical Education - Basic Grants to States, 84.048 Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 84.048 for GBC as reported in 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: There was no evidence of review and approval (segregation of duties) of certain payroll expenditures charged to the grant. Cause: The Great Basin College (GBC) did not have adequate internal controls to provide for documented review and approval of payroll costs for terminated employees charged to the grant program. Effect: Inaccurate payroll expenses may be recorded to the federal grant and remain undetected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 ($299,78) out of a population of 402 ($1,245,527) payroll expenditures across the Nevada System of Higher Education was selected for testing. GBC payroll expenditures were 15 ($115,473) of the 60 selected for testing. There were two payroll charges ($10,704) for one terminated employee that did not have evidence of review and approval. Repeat Finding from Prior Year: No Recommendation: We recommend GBC enhance internal controls to provide for documented review and approval for terminated employees charged to the grant program. Views of Responsible Officials: The Great Basin College agrees with this finding.
Allowable Costs/Cost Principles Responses GBC accepts 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; o GBC maintains evidence of review and approval of the payroll expenses in question. GBC is very willing to enhance internal controls to provide for documented review and approval for terminated employees charged to the grant program. o GBC has strengthened internal controls over payroll expenditures charged to federal grants to ensure documented review and segregation of duties, particularly for terminated employees. o Documented evidence of review and approval will be retained within the payroll/grants file to ensure a clear audit trail. o Human Resources and Grants Accounting staff have been reminded of federal documentation requirements specific to grant-funded payroll expenditures. ● How compliance and performance will be measured and documented for future audit, management and performance review. o Quarterly internal reviews of payroll expenditures charged to federal grants, with specific review of terminated employees. o Retention of documented approval evidence in electronic grant files. o Review during annual fiscal year-end grant reconciliations. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. o The Grants Director and Director of Business Operations are responsible for oversight of grant compliance. Official Contact: 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
There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: Western Nevada College (WNC) did not have adequate internal controls to provide for the documented review and approval of Requests for Reimbursement submitted to the pass-through entity. Effect: Funds may not be drawn on a reimbursement basis, for immediate cash needs, or an error may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 16 Requests for Reimbursement out of a population of 102 across the Nevada System of Higher Education was selected for testing. WNC had four Requests for Reimbursement selected for testing of the sample of 16. We noted there was no evidence of review by an individual independent of the preparer for one of the four requests. Repeat Finding from Prior Year: No Recommendation: We recommend WNC enhance internal controls to provide for the documented review and approval of Requests for Reimbursement. Views of Responsible Officials: The Western Nevada College agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Career and Technical Education - Basic Grants to States, 84.048 Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 84.048 for WNC as reported in 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. Grantors require submission of Requests for Reimbursement. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: Western Nevada College (WNC) did not have adequate internal controls to provide for the documented review and approval of Requests for Reimbursement submitted to the pass-through entity. Effect: Funds may not be drawn on a reimbursement basis, for immediate cash needs, or an error may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 16 Requests for Reimbursement out of a population of 102 across the Nevada System of Higher Education was selected for testing. WNC had four Requests for Reimbursement selected for testing of the sample of 16. We noted there was no evidence of review by an individual independent of the preparer for one of the four requests. Repeat Finding from Prior Year: No Recommendation: We recommend WNC enhance internal controls to provide for the documented review and approval of Requests for Reimbursement. Views of Responsible Officials: The Western Nevada College agrees with this finding.
Cash Management Responses 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 implemented the practice of invoice review (proper segregation of duties) in October 2024, in which all invoices are reviewed from an individual separate from the preparer. This practice has been in place since our October 2024 grant billing period and has continued ever since. This audit finding resulted from the auditor selecting a transaction prior to WNC implementing the new procedure. All other transactions selected by the auditor were in compliance. ● How compliance and performance will be measured and documented for future audit, management and performance review. All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Vice President of Finance & Administration may be held accountable in the future if repeat or similar observations are noted. Official Contact: 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
Certain costs claimed under cost sharing were not adequately documented or verifiable. Cause: The following institutions did not have adequate internal controls to ensure costs claimed for cost share were adequately documented and verifiable: • College of Southern Nevada (CSN) • Great Basin College (GBC) • System Administration (SA) • University of Nevada, Las Vegas (UNLV) • University of Nevada, Reno (UNR) • Western Nevada College (WNC) Effect: Unallowable costs may be used to meet cost sharing requirements. Questioned Costs: None, several individual institutions did not meet cost sharing requirements; however, the Nevada System of Higher Education met cost share as a whole. Context/Sampling: A nonstatistical sample of 40 ($64,311) cost-share expenditure transactions out of a population of 939 ($1,124,401) cost-share expenditures across the Nevada System of Higher Education were selected for testing. Errors identified by institution are summarized below: College of Southern Nevada Four out of the 40 transactions sampled were for CSN. For 2 of the 4 samples tested, office space usage and facility‑related expenses were included both in the total direct expenses and again recovered through the unrecovered F&A rate. This resulted in unallowable cost share expenses of $5,365. Great Basin College Two out of the 40 transactions sampled were for GBC. For one of the two samples tested, an incorrect annual salary amount was used in the calculation, resulting in unallowable cost share expenses of $60. System Administration Ten out of the 40 transactions sampled were for SA. For three of the ten samples, an incorrect fringe rate was used, resulting in unallowable cost share expenses of $824. University of Nevada, Las Vegas 11 out of the 40 transactions sampled were for UNLV. There was no time and effort documentation to support the actual time spent on the grant activities to ensure the payroll allocated to cost share was appropriate (except for one transaction tested where budgeted hours were utilized when actual time spent was available). In addition, for two of the transactions, the incorrect salary was used. We reviewed the aggregate payroll expenditures claimed noting unallowable cost share of $196,288. University of Nevada, Reno Nine out of 40 transactions sampled were for UNR. For one of the 9 samples, time and effort documentation to support the actual time spent on the grant activities to ensure the payroll allocated to cost share was appropriate was not available. We noted this time and effort was not available for the employee’s allocated annual amount. This resulted in unallowable cost share of $63,300. Western Nevada College One out of the 40 transactions sampled were for WNC. For the one transaction tested, an incorrect fringe rate was used, resulting in unallowable cost share expenses of $188. In the aggregate, we noted $266,025 in questioned costs related to cost share for a lack of supporting documentation. However, the Nevada System of Higher Education as a whole had other allowable expenditures that, in the aggregate, exceeded the overall cost share requirement. Repeat Finding from Prior Year: No Recommendation: We recommend the Nevada System of Higher Education institutions listed above enhance internal controls to ensure amounts used for cost share are adequately documented and verifiable. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. The Great Basin College agrees with this finding. The System Administration agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding. The Western Nevada College agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Direct and pass through State of Nevada as listed in the Schedule of Expenditures of Federal Awards Gaining Early Awareness and Readiness for Undergraduate Programs, 84.334 Matching, Level of Effort, and Earmarking Material Weakness in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 84.334 for CSN, GBC, SA, UNLV, UNR, and WNC 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 200.306 requires, in part, that: Cost sharing funds must: • Be verifiable in the recipient's records • Be necessary and reasonable for achieving objectives of the Federal award • Be allowable under subpart E, which requires costs to be: o Consistent with policies and procedures that apply uniformly to federally financed and other activities o Adequately documented o For personnel expenses, documentation must support the distribution of the employee’s salary or wages Condition: Certain costs claimed under cost sharing were not adequately documented or verifiable. Cause: The following institutions did not have adequate internal controls to ensure costs claimed for cost share were adequately documented and verifiable: • College of Southern Nevada (CSN) • Great Basin College (GBC) • System Administration (SA) • University of Nevada, Las Vegas (UNLV) • University of Nevada, Reno (UNR) • Western Nevada College (WNC) Effect: Unallowable costs may be used to meet cost sharing requirements. Questioned Costs: None, several individual institutions did not meet cost sharing requirements; however, the Nevada System of Higher Education met cost share as a whole. Context/Sampling: A nonstatistical sample of 40 ($64,311) cost-share expenditure transactions out of a population of 939 ($1,124,401) cost-share expenditures across the Nevada System of Higher Education were selected for testing. Errors identified by institution are summarized below: College of Southern Nevada Four out of the 40 transactions sampled were for CSN. For 2 of the 4 samples tested, office space usage and facility‑related expenses were included both in the total direct expenses and again recovered through the unrecovered F&A rate. This resulted in unallowable cost share expenses of $5,365. Great Basin College Two out of the 40 transactions sampled were for GBC. For one of the two samples tested, an incorrect annual salary amount was used in the calculation, resulting in unallowable cost share expenses of $60. System Administration Ten out of the 40 transactions sampled were for SA. For three of the ten samples, an incorrect fringe rate was used, resulting in unallowable cost share expenses of $824. University of Nevada, Las Vegas 11 out of the 40 transactions sampled were for UNLV. There was no time and effort documentation to support the actual time spent on the grant activities to ensure the payroll allocated to cost share was appropriate (except for one transaction tested where budgeted hours were utilized when actual time spent was available). In addition, for two of the transactions, the incorrect salary was used. We reviewed the aggregate payroll expenditures claimed noting unallowable cost share of $196,288. University of Nevada, Reno Nine out of 40 transactions sampled were for UNR. For one of the 9 samples, time and effort documentation to support the actual time spent on the grant activities to ensure the payroll allocated to cost share was appropriate was not available. We noted this time and effort was not available for the employee’s allocated annual amount. This resulted in unallowable cost share of $63,300. Western Nevada College One out of the 40 transactions sampled were for WNC. For the one transaction tested, an incorrect fringe rate was used, resulting in unallowable cost share expenses of $188. In the aggregate, we noted $266,025 in questioned costs related to cost share for a lack of supporting documentation. However, the Nevada System of Higher Education as a whole had other allowable expenditures that, in the aggregate, exceeded the overall cost share requirement. Repeat Finding from Prior Year: No Recommendation: We recommend the Nevada System of Higher Education institutions listed above enhance internal controls to ensure amounts used for cost share are adequately documented and verifiable. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. The Great Basin College agrees with this finding. The System Administration agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding. The Western Nevada College agrees with this finding.
Matching, Level of Effort, and Earmarking Responses 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; CSN Office of Grants and Contracts Post-Award Management received approval from the award sponsor to perform a budget revision to remove office space usage from the cost share. The Office of Grants and Contracts Post-Award Management also advised the Office of Sponsored Projects to avoid using unallowable cost share expenses in award applications. ● How compliance and performance will be measured and documented for future audit, management and performance review. CSN Office of Grants and Contracts Post-Award Management will continue to monitor award budgets to avoid using unallowable cost share expenses. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Office of Grants and Contracts Post-Award manager is accountable for exercising oversight and responsibility. GBC – 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; o GBC will standardize a cost share calculation workflow between the Grants and Business Operations departments to ensure proper calculation and review against payroll records. o GBC also will formalize written internal procedures for cost share calculation and documentation and distribute to relevant staff. o All corrective actions were implemented immediately upon identification of the finding and will be fully in place within 30 days of notification. The revised procedures are now standard practice for all grants requiring cost share. ● How compliance and performance will be measured and documented for future audit, management and performance review. o A cost share verification checklist will accompany each cost share transaction and will be retained in each year’s grant file. This internal review will confirm: (1) use of current salary data; (2) mathematical accuracy; and, (3) proper documentation support. o Grant financial reports will include documented evidence of secondary review prior to submission. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. o The Grants Director and the Director of Business Operations are responsible for oversight of grant compliance. UNLV agrees with this 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 UNLV OSP has enforced a required cost share form to be completed, and will require that documentation be attached and verified before submission to the sponsor. For effort identified as cost share, a new process is currently being tested to capture it in the financial system. The cost share policy will be updated before the end of spring semester and disseminated to the campus community for immediate implementation. ● How compliance and performance will be measured and documented for future audit, management and performance review. Verifiable documentation will be required upon review/submission to be uploaded with the financial report in Workday. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with the Principal Investigator’s documentation. UNR – 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; Management will implement quarterly review of all gift accounts used for cost share to ensure that they are properly established and correctly linked to the award through a GR cost share line, which will generate the required effort certification process. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through a review and confirmation that all cost share transactions are accurately recorded, supported, and associated with the appropriate worktags. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award 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; WNC will continue its FY26 adopted internal control processes by implementing a two-step review process for all invoicing, including match verification and reporting. The assistant controller creates the invoice packet and submits it to the grant administrator for review and approval. The packet then has a secondary and final review and approval by the vice president of finance and administration. The sampled transaction occurred before internal controls were in place. Internal controls were implemented in October 2025. ● How compliance and performance will be measured and documented for future audit, management and performance review. The grant administrator maintains records of monthly invoicing reviews, including time-stamped email receipts, internal tracking spreadsheets, and Workday transactions. Workday transactions provide actuals for each invoice period, which are compared to the internal tracking spreadsheet to determine the totals to be invoiced/reported. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Final responsibility and accountability fall on the grants administrator. SA – 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 spreadsheet that System Administration uses to track in-kind cost share was not correctly updated when the fringe rate changed at the beginning of the fiscal year. The Post-Award Manager will update the spreadsheet each July when the fringe rate is confirmed and run effort reports using the current salary and fringe rates. ● How compliance and performance will be measured and documented for future audit, management and performance review. The Office of Sponsored Programs will document that the fringe rate for the new fiscal year has been reviewed, and that the in-kind cost share spreadsheet was updated each July. Documentation will be included in the cost share file. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The System Administration Office of Sponsored Programs Director is accountable for exercising oversight and responsibility. Official Contact: 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
Information reported to the federal agency and the pass-through entity did not agree with the underlying supporting records. Cause: The following institutions at the Nevada System of Higher Education (NSHE) did not have adequate internal controls to ensure that amounts reported to the federal agency and pass-through entity were supported by underlying documentation: • College of Southern Nevada (CSN) • Great Basin College (GBC) • Nevada State University (NSU) • Truckee Meadows Community College (TMCC) • University of Nevada, Las Vegas (UNLV) • University of Nevada, Reno (UNR) • Western Nevada College (WNC) Effect: Inaccurate information was reported to the pass-through entity. Questioned Costs: None Context/Sampling: A nonstatistical sample of was selected across the Nevada System of Higher Education as follows: • Interim Progress Reports: Three sampled from a population of ten • Final Progress Reports: Three sampled from a population of ten • Direct Award Progress Reports: All reports out of a population of 3 tested Repeat Finding from Prior Year: No Recommendation: We recommend that the Nevada System of Higher Education institutions listed above enhance their internal controls to ensure that all reports submitted to pass‑through entities are subject to appropriate review and approval, and that all reported amounts are fully supported by the underlying records. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. The Great Basin College agrees with this finding. The Nevada State University agrees with this finding. The Truckee Meadows Community College agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding. The Western Nevada College agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Direct and pass through State of Nevada as listed in the Schedule of Expenditures of Federal Awards Gaining Early Awareness and Readiness for Undergraduate Programs, 84.334 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards included under assistance listing 84.334 for CSN, GBC, NSU, TMCC, UNLV, UNR, and WNC, as reported in 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. US Department of Education requires the submission of Annual Performance Reports from direct recipients. The OMB Compliance Supplement provides that reporting requirements for subrecipients are as specified by the pass-through entity. The pass-through entities required the submission of Interim and Final Progress Reports. Condition: Information reported to the federal agency and the pass-through entity did not agree with the underlying supporting records. Cause: The following institutions at the Nevada System of Higher Education (NSHE) did not have adequate internal controls to ensure that amounts reported to the federal agency and pass-through entity were supported by underlying documentation: • College of Southern Nevada (CSN) • Great Basin College (GBC) • Nevada State University (NSU) • Truckee Meadows Community College (TMCC) • University of Nevada, Las Vegas (UNLV) • University of Nevada, Reno (UNR) • Western Nevada College (WNC) Effect: Inaccurate information was reported to the pass-through entity. Questioned Costs: None Context/Sampling: A nonstatistical sample of was selected across the Nevada System of Higher Education as follows: • Interim Progress Reports: Three sampled from a population of ten • Final Progress Reports: Three sampled from a population of ten • Direct Award Progress Reports: All reports out of a population of 3 tested Repeat Finding from Prior Year: No Recommendation: We recommend that the Nevada System of Higher Education institutions listed above enhance their internal controls to ensure that all reports submitted to pass‑through entities are subject to appropriate review and approval, and that all reported amounts are fully supported by the underlying records. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. The Great Basin College agrees with this finding. The Nevada State University agrees with this finding. The Truckee Meadows Community College agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding. The Western Nevada College agrees with this finding.
Reporting Responses 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; CSN Office of Grants and Contracts Post-Award Management has advised the grant’s principal investigator (PI) that underlying documentations must match the data reported on the Annual Performance Reports submitted to the award sponsor. The CSN GEAR UP PI and GEAR UP First Year College Advisor have refined the reporting and record keeping process to ensure accurate reporting and supporting documentation is kept in compliance with the grant. The Senior Accountant of Grants and Contracts also reviews the data before each report is submitted to the sponsor. ● How compliance and performance will be measured and documented for future audit, management and performance review. CSN GEAR UP PI and GEAR UP First Year College Advisor will continue to ensure accurate reporting and supporting documentation is kept in compliance. CSN Office of Grants and Contracts Post-Award Management will continue to communicate with PIs to ensure all reports have been reviewed for adequate and accurate supporting documentation prior to submission to the sponsor. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Program Director, who is the Gaining Early Awareness and Readiness for Undergraduate Programs (GEAR UP) Principal Investigator (PI), is accountable for exercising oversight and responsibility. GBC – 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; o Establishment of a formal review and approval workflow requiring secondary review by the Grants Office of participants numbers prior to submission of any financial or performance report. This will require: (1) Identification of the reporting period; (2) Review of all source documents supporting reported totals; and, (3) Mathematical reconciliation of reported figures o Training provided to grant program staff and administrative personnel on documentation standards and reporting accuracy expectations. o All corrective actions were implemented immediately upon identification of the finding and will be fully in place within 30 days of notification. The revised procedures are now standard practice for all grants reporting participant numbers. ● How compliance and performance will be measured and documented for future audit, management and performance review. o Reports may not be submitted to the pass-through entity without documented secondary review and written approval from the Grants Director or the Grant and Asset Coordinator. o Interim and final program reports will be reviewed to ensure: (1) Participant totals match underlying documentation; (2) Source documentation is retained and accessible; and, (3) Approval signatures are present prior to submission. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. o The Grants Director and the Director of Business Operations are responsible for oversight of grant compliance. NSU – 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; NSU has reviewed the finding and has put additional measures in place to ensure compliance. Staff responsible for preparing reports were retrained and multi-layered quality checks have been implemented to safeguard integrity of data entered in shared databases. NSU’s multi-layered quality checks include written confirmations from staff involved in service activities and backup of documentation within NSU’s local storage to support the numbers being reported. The latter represents a move away from using a database that is accessible to multiple institutions to a centrally controlled location within NSU. This process outlined herein was implemented in August 2025 and ensures that the source documentation reconciles with reports and is available for auditing purposes. ● How compliance and performance will be measured and documented for future audit, management and performance review. To ensure compliance, NSU staff who are responsible for the program and technical reporting have reviewed and updated internal policies and procedures relating to reporting. Performance targets and benchmarks have been reestablished and will be measured at set intervals. Any errors detected will be documented and remedied. Additionally, errors will serve as the basis for continuous improvement processes and retraining as needed. These will be documented in performance reviews. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The NSU GEAR UP Principal Investigator and First-Year College Advisor Supervisor are responsible and accountable for ensuring reporting is supported by underlying records. TMCC – 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; TMCC reports on the number of participants for all services rendered under the GEAR UP grant through both the Interim Progress Report (IPR) and the Final Progress Report (FPR). The identified issue concerns a discrepancy between the reported participant count on the IPR and the underlying supporting records. To ensure data accuracy going forward, TMCC will implement an additional review of participant reporting. Prior to the submission of progress reports, a second technical reviewer within the GEAR UP team would verify the participant counts entered into GEARS (GEAR UP’s designated data-reporting platform) against the supporting documentation (the attendance sheet). Should a discrepancy be identified, the GEAR UP team will follow up with the individual responsible for the data entry on GEARS to reconcile the difference. This may include requesting correction of data entry errors or obtaining additional documentation to support the reported participant count, as appropriate. Additionally, attendance sign-in sheets will be collected and retained by TMCC staff to allow for direct verification prior to reporting. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured by the implementation of a second reviewer for the participant data reported through GEARS and included in the progress reporting. This review can be documented through an internal checklist, internal communication, or other appropriate records demonstrating that the participant data was reviewed and validated prior to the submission of progress reports. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Primary responsibility for accurate participant reporting will remain with the TMCC First Year College Advisor (FYCA) or other designated staff responsible for preparing grant performance reports. Responsibility for completing the secondary verification review will be assigned to a designated GEAR UP technical reviewer or program staff member who is independent of the initial data entry and report preparation. If repeat or similar observations occur, program leadership will evaluate adherence to established procedures and implement additional corrective actions, which may include staff retraining, revision of internal procedures, or reassignment of reporting responsibilities, as appropriate. UNLV agrees with this 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 UNLV OSP will continue to work with PIs to ensure there is a documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. Additionally, if reports require financial expenditures, the Office of Sponsored Programs will require validation before submission. Communication dissemination will occur twice within the academic year. ● How compliance and performance will be measured and documented for future audit, management and performance review. UNLV OSP will continue communications through Research Weekly (an internal communication newsletter) to remind PIs to ensure timely submission of progress reports and retention of records such as, lab notes, testing, populations served, activities performed, etc. to demonstrate activities supported by the grant. UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility along with the applicable Deans. UNR – 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; All participant counts reported in Interim Progress Reports will be supported by retained underlying source documentation that directly reconcile to the reported totals. Standard documentation expectations and retention requirements will be communicated to program staff. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance will be measured through pre-submission review of reported participant data against underlying records and through post-submission spot checks conducted by Program Director. Documentation supporting reported counts will be retained in the official project file and made available for future audit, management review, and internal monitoring. Evidence of reconciliation will be documented via checklists or certifications retained with the report. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Program Director 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; Sponsors have determined grant practices and required reporting documentation, which have not been consistently required or expected of subrecipients. WNC will maintain its own sign-in sheets and documentation for all grant-sponsored activities to ensure compliance with overall grant requirements. The corrective action was implemented in July 2025. ● How compliance and performance will be measured and documented for future audit, management and performance review. The GEAR Up coordinator will create and maintain sign-in sheets or other documentation for every grant-sponsored activity. The coordinator will maintain records in accordance with federal and state guidance and will ensure that supporting documentation is sufficient to support the reported figures. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Final responsibility and accountability fall on the GEAR Up coordinator and grant administrator. Official Contact: 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
An expenditure was not necessary or reasonable for the performance of the award and was charged against the program. Cause: The College of Southern Nevada (CSN) did not have adequate internal controls to ensure only necessary and reasonable costs were charged to the grant. Effect: Expenditures that were not related to the federal program were charged to the federal program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($41,027) non-payroll transactions out of a population of 1,265 ($432,891) non-payroll transactions across the Nevada System of Higher Education were selected for testing. CSN non-payroll transactions were 6 ($19,816) of the 60 selected for testing. A flight and related travel agent fee was originally charged to the grant. However, it was later determined by CSN that this was an error and the flight had been booked erroneously as the employee was not attending the training. The flight was refunded and removed from the expenditures charged to the grant. However, the non-refundable travel agent fee ($25) was not adjusted and still charged to the grant. Since the travel was booked in error, the directly associated expense (travel agent fee) is not necessary and reasonable for the program. Repeat Finding from Prior Year: No Recommendation: We recommend CSN enhance internal controls to ensure only necessary and reasonable costs are charged to the grant. Views of Responsible Officials: The College of Southern Nevada agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Direct and Pass-through State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Substance Abuse and Mental Health Services Projects of Regional and National Significance, 93.243 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award 1H79SM084442-01 included as a direct award under assistance listing 93.243 for CSN on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 of U.S. Code of Federal Regulation (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that costs must be, in part: • Necessary and reasonable for the performance of the award • Consistent with policies and procedures that apply uniformly to federally financed and other activities • Adequately documented Condition: An expenditure was not necessary or reasonable for the performance of the award and was charged against the program. Cause: The College of Southern Nevada (CSN) did not have adequate internal controls to ensure only necessary and reasonable costs were charged to the grant. Effect: Expenditures that were not related to the federal program were charged to the federal program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($41,027) non-payroll transactions out of a population of 1,265 ($432,891) non-payroll transactions across the Nevada System of Higher Education were selected for testing. CSN non-payroll transactions were 6 ($19,816) of the 60 selected for testing. A flight and related travel agent fee was originally charged to the grant. However, it was later determined by CSN that this was an error and the flight had been booked erroneously as the employee was not attending the training. The flight was refunded and removed from the expenditures charged to the grant. However, the non-refundable travel agent fee ($25) was not adjusted and still charged to the grant. Since the travel was booked in error, the directly associated expense (travel agent fee) is not necessary and reasonable for the program. Repeat Finding from Prior Year: No Recommendation: We recommend CSN enhance internal controls to ensure only necessary and reasonable costs are charged to the grant. Views of Responsible Officials: The College of Southern Nevada agrees with this finding.
Activities Allowed or Unallowed and Allowable Costs/Cost Principles Responses 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; CSN’s Office of Grants and Contracts Post-Award Management has advised the grant’s principal investigator (PI) to review expenses and avoid this issue in the future. CSN Office of Grants & Contracts Post-Award Management will continue to advise the departments that expenses associated with canceled events will be removed from the grant, unless the sponsor allows the costs to remain on the grant. ● How compliance and performance will be measured and documented for future audit, management and performance review. CSN Office of Grants and Contracts Post-Award Management will maintain communication with PIs and employees to identify any costs associated with canceled events and ensure only necessary and reasonable costs are charged to the grant. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN Office of Grants and Contracts Post-Award manager is accountable for exercising oversight and responsibility. Official Contact: 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
There was no evidence of review and approval (segregation of duties) between the preparer and the reviewer. Information reported to the pass-through entity did not agree to underlying supporting records. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to provide for the documented review and approval of quarterly progress reports or subaward information required by the FFATA. In addition, UNR did not have adequate internal controls to ensure amounts reported to the pass-through entity were supported by the underlying records. Effect: Inaccurate information may be reported. Questioned Costs: None Context/Sampling: A nonstatistical sample of two Quarterly Progress Reports was selected from a population of five across the Nevada System of Higher Education. Repeat Finding from Prior Year: No Recommendation: We recommend the UNR enhance internal controls to provide for the documented review and approval of reports submitted to pass-through entities and subaward information required by the FFATA. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Direct and Pass-through State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Substance Abuse and Mental Health Services Projects of Regional and National Significance, 93.243 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards passed-through to UNR under assistance listing 93.243 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. The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information. The OMB Compliance Supplement provides that reporting requirements for subrecipients are as specified by the pass-through entity. The pass-through entities required the submission of Quarterly Progress Reports. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and the reviewer. Information reported to the pass-through entity did not agree to underlying supporting records. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to provide for the documented review and approval of quarterly progress reports or subaward information required by the FFATA. In addition, UNR did not have adequate internal controls to ensure amounts reported to the pass-through entity were supported by the underlying records. Effect: Inaccurate information may be reported. Questioned Costs: None Context/Sampling: A nonstatistical sample of two Quarterly Progress Reports was selected from a population of five across the Nevada System of Higher Education. Repeat Finding from Prior Year: No Recommendation: We recommend the UNR enhance internal controls to provide for the documented review and approval of reports submitted to pass-through entities and subaward information required by the FFATA. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Reporting Responses UNR – 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; Management staff, independent of preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: 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
An incorrect time and effort percentage was used to allocate longevity pay to the grant. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to longevity pay was allocated based on actual time and effort. Effect: Unallowable costs were charged to the program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($283,923) payroll expenditures was selected from a population of 279 ($1,039,323) across the Nevada System of Higher Education was selected for testing. UNR payroll expenditures were 47 ($247,438) out of the 60 selected for testing. We noted one payroll transaction totaling $825 was charged to the grant based on budget estimates rather than the actual time and effort percentage. The amount over-allocated was $46. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure longevity pay is allocated based on actual time and effort. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Epidemiology and Laboratory Capacity for Infectious Diseases, 93.323 Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant awards SG-2025-00557 included under assistance listing 93.323 for UNR on the Schedule of Expenditures of Federal Awards. Criteria: Title 2 of U.S. Code of Federal Regulation (CFR) Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) provides that costs must be, in part: • Necessary and reasonable for the performance of the award • Consistent with policies and procedures that apply uniformly to federally financed and other activities • Adequately documented Condition: An incorrect time and effort percentage was used to allocate longevity pay to the grant. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to longevity pay was allocated based on actual time and effort. Effect: Unallowable costs were charged to the program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($283,923) payroll expenditures was selected from a population of 279 ($1,039,323) across the Nevada System of Higher Education was selected for testing. UNR payroll expenditures were 47 ($247,438) out of the 60 selected for testing. We noted one payroll transaction totaling $825 was charged to the grant based on budget estimates rather than the actual time and effort percentage. The amount over-allocated was $46. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure longevity pay is allocated based on actual time and effort. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Allowable Costs/Cost Principles Responses UNR – 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; All relevant staff will complete targeted training on payroll cost transfer requirements and proper process to ensure payroll adjustments are completed accurately. ● How compliance and performance will be measured and documented for future audit, management and performance review. Completion of staff training will be tracked and documented. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: 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
Expenditures charged to the grant were incurred outside of the period of performance. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($200,390) non-payroll transactions out of a population of 698 ($1,483,710) across the Nevada System of Higher Education was selected for testing. UNR non-payroll transactions represented for 55 ($184,639) of the 60 transactions selected for testing. We noted two transactions totaling $951 were charged to the grant for services in July 2024. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Epidemiology and Laboratory Capacity for Infectious Diseases, 93.323 Period of Performance Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award SG-2025-00809 included under assistance listing 93.323 for UNR 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) provides that a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The terms and conditions of the grant agreements specified that the period of performance began on August 1, 2024. Condition: Expenditures charged to the grant were incurred outside of the period of performance. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($200,390) non-payroll transactions out of a population of 698 ($1,483,710) across the Nevada System of Higher Education was selected for testing. UNR non-payroll transactions represented for 55 ($184,639) of the 60 transactions selected for testing. We noted two transactions totaling $951 were charged to the grant for services in July 2024. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Period of Performance Responses UNR – 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; Training will be provided to all relevant staff on cost allowability and period of performance requirements. This training will reinforce that costs must be incurred within approved project period. ● How compliance and performance will be measured and documented for future audit, management and performance review. Completion of staff training will be tracked and documented. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: 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
There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to provide for the documented review and approval of reports submitted to the pass-through entity. Effect: Inaccurate information may be reported to the pass-through entity and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 6 Monthly Activity Reports was selected from a population of 36 at UNR were selected for testing. We noted there was no evidence of review on any of the 6 Monthly Activity Reports tested. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to provide for the documented review and approval of reports submitted to pass-through entities. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Epidemiology and Laboratory Capacity for Infectious Diseases, 93.323 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 93.323 for UNR 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 controls that provide 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. The OMB Compliance Supplement provides that reporting requirements for subrecipients are as specified by the pass-through entity. The pass-through entity requires the submission of Monthly Activity Reports. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to provide for the documented review and approval of reports submitted to the pass-through entity. Effect: Inaccurate information may be reported to the pass-through entity and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 6 Monthly Activity Reports was selected from a population of 36 at UNR were selected for testing. We noted there was no evidence of review on any of the 6 Monthly Activity Reports tested. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to provide for the documented review and approval of reports submitted to pass-through entities. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Reporting Responses UNR – 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; Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. ● How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Associate Director of Post Award Official Contact: 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
Subrecipient monitoring policies are not documented and risk assessment was not performed. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure subrecipient monitoring policies were established and to ensure risk assessments were performed. Effect: Noncompliance may occur at a subrecipient and not be detected by UNLV. Questioned Costs: None Context/Sampling: No sampling was performed, the one subrecipient applicable to the grant was tested. We noted UNLV does not have documented subrecipient monitoring policies and a risk assessment was not performed for the subrecipient. Repeat Finding from Prior Year: No Recommendation: We recommend that UNLV establish subrecipient monitoring policies and enhance internal controls to ensure risk assessments are performed. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Epidemiology and Laboratory Capacity for Infectious Diseases, 93.323 Subrecipient Monitoring Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects award SG26176 included under assistance listing 93.323 for UNLV 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 200.332 requires that: • Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. • Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. Condition: Subrecipient monitoring policies are not documented and risk assessment was not performed. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure subrecipient monitoring policies were established and to ensure risk assessments were performed. Effect: Noncompliance may occur at a subrecipient and not be detected by UNLV. Questioned Costs: None Context/Sampling: No sampling was performed, the one subrecipient applicable to the grant was tested. We noted UNLV does not have documented subrecipient monitoring policies and a risk assessment was not performed for the subrecipient. Repeat Finding from Prior Year: No Recommendation: We recommend that UNLV establish subrecipient monitoring policies and enhance internal controls to ensure risk assessments are performed. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Subrecipient Monitoring Responses UNLV agrees with this 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; UNLV OSP has implemented a comprehensive policies and procedures document covering the entire subrecipient lifecycle, which includes internal controls such as a checklist, review of risk before issuance, a biannual sub monitoring review of financial audit, and authorized purposes review. ● How compliance and performance will be measured and documented for future audit, management and performance review. Per the UNLV OSP policy, documentation is required throughout the lifecycle and will be used for future audits. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: 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
Payroll was charged to the grant based on budget estimates for employees that are not 100% funded by the grant. Cause: The System Related Organization of Nevada System of Higher Education – UNLV Health (UNLV Health) did not have adequate internal controls to ensure payroll costs incurred were allocated to the grant based on actual time spent for employees who were only partially charged to the program. Effect: Unallowable costs were charged to the program. Questioned Costs: $63,660 Context/Sampling: A nonstatistical sample of 14 ($41,745) payroll transactions out of a population of 83 ($308,370) at UNLV Health was selected for testing. We noted 11 payroll transactions were allocated based on budget rather than actual time spent. We obtained the aggregate payroll charged to the grant for these employees, noting $63,660 in annual payroll related costs charged to the grant for these specific employees. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV Health enhance internal controls to ensure payroll costs incurred are appropriately allocated to the grant. Views of Responsible Officials: The System Related Organization of Nevada System of Higher Education – UNLV Health agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Block Grant for Community Mental Health Services, 93.958 Allowable Costs/Cost Principles Material Weakness in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.958 for System-Related Organizations on the Schedule of Expenditures of Federal Awards. Criteria: State cost principle requirements apply to this federal program as it is exempt from the provisions of OMB cost principles. Per the subaward from the State of Nevada, expenditures must comply with any statutory guidelines, the DHHS Grant Instructions and Requirements, and the State Administrative Manual. The subaward indicates that reimbursement is based on actual expenditures incurred during the period being reported. In addition, the DHHS Grant Instructions and Requirements indicates that source documentation for personnel costs includes activity-based timesheets and/or the actual pay stubs that show all the deductions and hours worked by the employee. If the employee is not a 100% funded position, the notations must identify what other funds are paying the additional hours. Condition: Payroll was charged to the grant based on budget estimates for employees that are not 100% funded by the grant. Cause: The System Related Organization of Nevada System of Higher Education – UNLV Health (UNLV Health) did not have adequate internal controls to ensure payroll costs incurred were allocated to the grant based on actual time spent for employees who were only partially charged to the program. Effect: Unallowable costs were charged to the program. Questioned Costs: $63,660 Context/Sampling: A nonstatistical sample of 14 ($41,745) payroll transactions out of a population of 83 ($308,370) at UNLV Health was selected for testing. We noted 11 payroll transactions were allocated based on budget rather than actual time spent. We obtained the aggregate payroll charged to the grant for these employees, noting $63,660 in annual payroll related costs charged to the grant for these specific employees. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV Health enhance internal controls to ensure payroll costs incurred are appropriately allocated to the grant. Views of Responsible Officials: The System Related Organization of Nevada System of Higher Education – UNLV Health agrees with this finding.
Allowable Costs/Cost Principles Responses UNLV Health 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; UNLV Health is implementing a process to require employees to certify time spent working on a grant. They will sign a timesheet at the end of the month. UNLV Health will then true-up the payroll costs allocated to the grant with the actual time spent for employees charged to the program on a quarterly basis. ● How compliance and performance will be measured and documented for future audit, management and performance review. Program administrators will provide the UNLV Health Finance Administrator and Accounting department with the support documentation from the EMR system. UNLV Health Finance Administrators and accounting will continue to review all support documentation for compliance and performance. The grant expenditures details are maintained and tracked via spreadsheet. Additionally, the State also conducts independent audits and UNLV Health received a clean audit from the State for this specific grant in FY24. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV Health Accounting department is accountable for maintaining and approving documents. Official Contact: 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
Expenditures charged to the grant were incurred outside of the period of performance. Cause: The System Related Organization of Nevada System of Higher Education – UNLV Health (UNLV Health) did not have adequate internal controls to ensure costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 14 ($41,745) payroll transactions out of a population of 83 ($308,370) at UNLV Health was selected for testing. We noted one payroll transaction that occurred in November and December 2024. The November pay was not excluded from the grant. Therefore, $722 was charged to the grant for service in November 2024. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV Health enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The System Related Organization of Nevada System of Higher Education – UNLV Health agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Block Grant for Community Mental Health Services, 93.958 Period of Performance Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects all grant awards included under assistance listing 93.958 for System-Related Organizations 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) provides that a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The terms and conditions of the grant agreements specified that the period of performance began on December 1, 2024. Condition: Expenditures charged to the grant were incurred outside of the period of performance. Cause: The System Related Organization of Nevada System of Higher Education – UNLV Health (UNLV Health) did not have adequate internal controls to ensure costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: Known and projected questioned costs are less than $25,000. Context/Sampling: A nonstatistical sample of 14 ($41,745) payroll transactions out of a population of 83 ($308,370) at UNLV Health was selected for testing. We noted one payroll transaction that occurred in November and December 2024. The November pay was not excluded from the grant. Therefore, $722 was charged to the grant for service in November 2024. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV Health enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The System Related Organization of Nevada System of Higher Education – UNLV Health agrees with this finding.
Period of Performance Responses UNLV Health 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; Prospectively, UNLV Health will ensure that expenditures are charged to the grant within the correct period. UNLV Health will be updating the template for payroll hours to ensure only time from the invoiced month is captured. ● How compliance and performance will be measured and documented for future audit, management and performance review. The UNLV Health Finance Administrator and Accounting department will continue to review and approve the completed template along with supporting documentation, including ADP reports. Signed invoices will serve as the documentation that these were reviewed and approved. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV Health Accounting department is accountable for maintaining and approving documents. Official Contact: 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
Subrecipient monitoring policies are not documented and monitoring of activities was not performed. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure required subrecipient monitoring policies were established and perform monitoring activities. Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: The entire population of three subrecipients/subawards was selected for testing across both UNLV (one) and UNR (two). The following error was noted: University of Nevada, Las Vegas • UNLV does not have written subrecipient monitoring policies. • Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. Repeat Finding from Prior Year: Yes – prior year finding 2024-023. Recommendation: We recommend UNLV establish subrecipient monitoring policies and enhance internal controls to ensure subrecipients are monitored for compliance with award terms and conditions. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Block Grant for Community Mental Health Services, 93.958 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Grant Award Number: Affects grant award SG-2025-00677, SG-2025-00820, and SG-26361 included under the under assistance listing 93.958 for UNLV 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 200.332 requires that: • Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. • Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. Condition: Subrecipient monitoring policies are not documented and monitoring of activities was not performed. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure required subrecipient monitoring policies were established and perform monitoring activities. Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: The entire population of three subrecipients/subawards was selected for testing across both UNLV (one) and UNR (two). The following error was noted: University of Nevada, Las Vegas • UNLV does not have written subrecipient monitoring policies. • Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. Repeat Finding from Prior Year: Yes – prior year finding 2024-023. Recommendation: We recommend UNLV establish subrecipient monitoring policies and enhance internal controls to ensure subrecipients are monitored for compliance with award terms and conditions. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Subrecipient Monitoring Responses UNLV agrees with this 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; UNLV OSP has implemented a comprehensive policies and procedures document covering the entire subrecipient lifecycle, which includes internal controls such as a checklist, review of risk before issuance, a biannual sub monitoring review of financial audit, and authorized purposes review. ● How compliance and performance will be measured and documented for future audit, management and performance review. The internal controls will be added by OSP to enhance sub monitoring to include a review of the budget-to-actuals for subrecipients' invoices for alignment to the project. Additional guidelines will be included in the invoice review process for the principal investigators as well. ● Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The UNLV OSP Executive Director is accountable for exercising oversight and responsibility. Official Contact: 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
2024-023
FAC accepted this audit on November 22, 2024 — management decision was due May 22, 2025.
There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. In addition, indirect costs were unintentionally charged at a lower rate than approved. Cause: Desert Research Institute (DRI), University of Nevada, Reno (UNR), and Western Nevada College (WNC) did not have adequate internal controls to provide for the documented review and approval of Requests for Reimbursement submitted to the grantor. Effect: Inaccurate information may be reported to the grantor and funds may not be drawn on a reimbursement basis or for immediate cash needs and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 62 Requests for Reimbursement out of a population of 453 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute DRI had 12 requests selected for testing of the sample of 62. We noted there was no evidence of review by an individual independent of the preparer on any of the 12 requests. University of Nevada, Reno UNR had 23 requests selected for testing of the sample of 62. We noted that one request was not reviewed by an individual independent of the preparer. In addition, we noted two requests included indirect costs at a rate lower than the approved rate in the grant agreement, which caused a total under- reimbursement of $4,286. Western Nevada College WNC had one request selected for testing of the sample of 62. We noted there was no evidence of review by an individual independent of the preparer for the one request. Repeat Finding from Prior Year: No Recommendation: We recommend DRI, UNR, and WNC enhance internal controls to provide for the documented review and approval of Requests for Reimbursement. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The University of Nevada, Reno agrees with this finding. The Western Nevada College agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under the Research and Development Cluster for DRI, UNR, and WNC 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 effect 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. Grantors require the submission of Requests for Reimbursement. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. In addition, indirect costs were unintentionally charged at a lower rate than approved. Cause: Desert Research Institute (DRI), University of Nevada, Reno (UNR), and Western Nevada College (WNC) did not have adequate internal controls to provide for the documented review and approval of Requests for Reimbursement submitted to the grantor. Effect: Inaccurate information may be reported to the grantor and funds may not be drawn on a reimbursement basis or for immediate cash needs and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 62 Requests for Reimbursement out of a population of 453 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute DRI had 12 requests selected for testing of the sample of 62. We noted there was no evidence of review by an individual independent of the preparer on any of the 12 requests. University of Nevada, Reno UNR had 23 requests selected for testing of the sample of 62. We noted that one request was not reviewed by an individual independent of the preparer. In addition, we noted two requests included indirect costs at a rate lower than the approved rate in the grant agreement, which caused a total under- reimbursement of $4,286. Western Nevada College WNC had one request selected for testing of the sample of 62. We noted there was no evidence of review by an individual independent of the preparer for the one request. Repeat Finding from Prior Year: No Recommendation: We recommend DRI, UNR, and WNC enhance internal controls to provide for the documented review and approval of Requests for Reimbursement. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The University of Nevada, Reno agrees with this finding. The Western Nevada College agrees with this finding.
DRI – 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: DRI will implement controls that require the documentation of review and approval on the invoice process. With the current limited resources available in DRI’s Financial Services team, a position will be recruited as soon as possible with an anticipated start date in early spring 2025. It is expected that this position will support the full implementation of review procedures once on board. • How compliance and performance will be measured and documented for future audit, management and performance review: Once the position is filled, all invoices will be reviewed prior to drawing down or requesting reimbursement of funds. Documentation will occur either through the business process in the accounting system or manually as needed. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. UNR – 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: Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered, including the proper application of the indirect cost rate as outlined in the grant agreement. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. 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 will require that all grant invoices, effective with the October 2024 billing cycle, require a level of review. The finding for 2024 was due to vacancies in the Controller’s Office and inadequate staffing. WNC has since upgraded the vacant position and posted a recruitment to help mitigate this in the future. • How compliance and performance will be measured and documented for future audit, management and performance review: All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation will be compiled for each grant invoice that will indicate that a second level of review has been obtained. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future 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
An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR 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 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR 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 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR 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 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
Show full finding ▾Hide full finding ▴U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR 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 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all direct grant awards included under assistance listing 93.866 as part of the Research and Development Cluster for UNR 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 200.305(b)(1) provides that pass-through entities must monitor cash drawdowns by their subrecipients to ensure that the time elapsing between the transfer of federal funds to the subrecipient and their disbursement for program purposes is minimized. Condition: An advance payment was made to a subrecipient in excess of immediate cash needs. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure advance payments to subrecipients would be disbursed for program purposes timely. Effect: Unspent funds were retained by the subrecipient for a period beyond the subaward’s period of performance and liquidation period. Questioned Costs: Undetermined as a final reconciliation of unspent funds to be returned has not been finalized with the subrecipient. Context/Sampling: A nonstatistical sample of 60 pass-through payments out of a population of 636 across the Nevada System of Higher Education was selected for testing. UNR had 25 pass-through payments selected of the 60 in the sample. We noted procedures were not performed to minimize the time elapsing between the transfer of federal funds and disbursement for program purposes for one pass- through payment. The total originally advanced to the subrecipient was $40,000. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure advance payments to subrecipients are disbursed for program purposes timely. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR 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 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. Nevada System of Higher Education Schedule of Findings and Questioned Costs Year Ended June 30, 2024 2024-009: U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR 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 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing.
UNR – 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: Assigned staff will document all advance payments in the Notes section of the Award in Workday. Federal funds reimbursed in advance will be separated into an interest-bearing account. Additionally, staff will compare subrecipient expenses with advance payments on a monthly basis and follow up with the subrecipient as needed to ensure timely use of the funds. • How compliance and performance will be measured and documented for future audit, management and performance review: Staff will document advance payments in Workday's Notes section. The use of an interest-bearing account for advance funds will also be tracked. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. 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
Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Departments and Pass-Through Programs with various assistance listings as listed in the Schedule of Expenditures for the Research and Development Cluster Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards with pass-through payments included under the Research and Development Cluster for DRI, NSU, UNLV, and UNR 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 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities evaluate the risk of noncompliance with a subaward to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities monitor the activities of a subrecipient as necessary to ensure that the subaward is used for authorized purposes, complies with the terms and conditions of the subaward, and achieves performance goals. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, risk assessment was not performed, subawards were missing required information, monitoring of activities was not performed, and subrecipient audit reports were not monitored or reviewed. Cause: Adequate internal controls were not in place to ensure compliance with subrecipient monitoring requirements for the following institutions: o Desert Research Institute (DRI) o Nevada State University (NSU) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 61 subrecipients out of a population greater than 250 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: Desert Research Institute: DRI had six subrecipients selected for testing out of the sample of 61. o Risk assessment was not performed for the six subrecipients selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that five of the subrecipients were using the award for authorized purposes and meeting performance objectives. Nevada State University: NSU had one subrecipient selected for testing out of the sample of 61. o NSU does not have written subrecipient monitoring policies. o Risk assessment was not performed for the subrecipient selected for testing. o Monitoring activities were not documented adequately to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o NSU did not have a mechanism in place to verify and monitor subrecipient audit reports timely. NSU did not review the subrecipient audit report or ensure an audit was not required. University of Nevada, Las Vegas: UNLV had 29 subrecipients selected for testing out of the sample of 61. o UNLV does not have written subrecipient monitoring policies. o Risk assessment was not performed for 15 of the subrecipients selected for testing. o Subawards were missing required information for 13 of the subawards to subrecipients selected for testing. o Monitoring activities were not documented adequately for 28 subrecipients to provide for reasonable assurance that the subrecipient was using the award for authorized purposes and meeting performance objectives. o UNLV did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNLV did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. University of Nevada, Reno: UNR had 25 subrecipients selected for testing out of the sample of 61. o Subawards were missing required information for two of the subawards to subrecipients selected for testing. o UNR did not have a mechanism in place to verify and monitor subrecipient audit reports timely. UNR did not review the subrecipient audit report or ensure an audit was not required for 23 subrecipients. Repeat Finding from Prior Year: No Recommendation: We recommend NSU and UNLV establish subrecipient monitoring policies. In addition, we recommend DRI, NSU, UNLV, and UNR enhance internal controls to ensure compliance with subrecipient monitoring requirements. Views of Responsible Officials: The Desert Research Institute agrees with this finding. The Nevada State University agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
DRI – 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: DRI will implement controls that require the documentation of risk assessment with respect to the subaward process. Depending on the results of the risk assessment, monitoring procedures will be designed to ensure compliance. With the current limited resources available in DRI’s Financial Services team, a position will be recruited as soon as possible with an anticipated start date in early spring 2025. It is expected that this position will support the full development and implementation of new procedures once on board. • How compliance and performance will be measured and documented for future audit, management and performance review: Documentation will be maintained in DRI’s pre-award system or in the accounting system, as appropriate to ensure compliance. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. NSU – 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: Nevada State University (NSU) has developed procedures to ensure the necessary reviews of all subrecipients’ transactions including risk assessment and determination, and financial statement review. Procedures will include the following: documentation of subrecipient risk assessment and risk-level determination and documentation of monitoring activities at regular intervals to ensure subrecipients are complying and making progress on performance objectives. NSU will proactively request subrecipients’ annual financial statements and audit reports. Upon review, NSU may modify monitoring as needed. • How compliance and performance will be measured and documented for future audit, management and performance review: NSU will perform risk assessment via a checklist prior to issuance of subaward. Subrecipient technical/progress reports will be requested periodically to monitor activities and progress. NSU will proactively request subrecipients’ annual financial statements and audit reports. Upon review, NSU will modify monitoring as may be needed. All reviews will be documented and maintained in the subrecipients’ files. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Director of Grants Award Services will be responsible with additional oversight by the Associate Vice President of Fiscal Services. UNLV – 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 UNLV Office of Sponsored Programs will implement required controls for subrecipient risk assessment immediately. Additionally, UNLV OSP will enhance our current tools using the guidance of the Federal Demonstration Partnership for national standardized forms for subrecipient monitoring. Policies and procedures will be in place by the end of the calendar year 2024, and monitoring will be performed annually. • How compliance and performance will be measured and documented for future audit, management and performance review: Materials–to include the risk assessment, degree of sub monitoring required, and training for all OSP personnel–will be completed within 60 days. The risk assessment will be attached to each fully executed subrecipient agreement and, as applicable, annual risk assessments will be completed. Policies and procedures are being developed and are expected to be in place by the end of the calendar year 2024. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility. UNR – 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: All required subaward documents will be retained in a centralized funding database for easy access and compliance tracking. Subaward specialists will review subrecipient audit reports at least once a year, rather than only when processing amendments. • How compliance and performance will be measured and documented for future audit, management and performance review: All required subaward documents, including subrecipient letters of certification, will be uploaded to Workday and maintained in a centralized funding database. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of PreAward is responsible for remediation of this finding. 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
Credit balances were not remitted timely. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure credit balances were remitted timely after a hold had been placed on the student’s account. Effect: Students do not receive their money timely. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 out of a population of 1,589 students who had Title IV disbursements was selected for testing. One student had a credit balance that was generated for their Spring 2023 term and had not cashed the check. A hold was placed on the student’s account until the student eventually cashed the check. However, the hold was not removed and the credit balance from the Fall 2023 term was not removed until April 2024. Therefore, the refund was 218 days after the credit balance occurred (204 days late). Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure credit balances are remitted timely after a hold has been placed on a student’s account. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Special Tests & Provisions – Disbursements to or on Behalf of Students Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included in the Student Financial Assistance Cluster for UNR on the Schedule of Expenditures of Federal Awards. Criteria: 34 CFR 668.164(h) states that a Title IV credit balance occurs whenever the amount of Title IV program funds credited to a student's ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period. A Title IV credit balance must be paid directly to the student or parent as soon as possible, but no later than (i) Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Condition: Credit balances were not remitted timely. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure credit balances were remitted timely after a hold had been placed on the student’s account. Effect: Students do not receive their money timely. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 out of a population of 1,589 students who had Title IV disbursements was selected for testing. One student had a credit balance that was generated for their Spring 2023 term and had not cashed the check. A hold was placed on the student’s account until the student eventually cashed the check. However, the hold was not removed and the credit balance from the Fall 2023 term was not removed until April 2024. Therefore, the refund was 218 days after the credit balance occurred (204 days late). Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure credit balances are remitted timely after a hold has been placed on a student’s account. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
UNR – 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 Financial Aid Office and the Cashiers Office have implemented procedures to ensure that refund holds are reviewed twice a week (Tuesdays, Thursdays). Automatic reports have been implemented to check for students with credit balances who have holds on their accounts. Assigned FA advisors review the reports and work with the Cashiers Office to resolve any hold issues to ensure that the student receives their refund promptly but no later than 14 days after funds are disbursed to the student account. • How compliance and performance will be measured and documented for future audit, management and performance review: The Data Manager is running weekly quality assurance reports to check that the FA advisors are reviewing theirs list and that there are no students on the lists that need attention. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The assigned financial advisors who review refund holds and the Financial Aid Director will be responsible. 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
There were instances where the calculation of returns was not calculated correctly or were not returned within the required allotted time. Cause: The following institutions did not have adequate internal controls to ensure R2T4 was calculated correct, and funds returned within the required time: o College of Southern Nevada (CSN) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: The U.S. Department of Education did not receive returns timely or accurately. Questioned Costs: None Context/Sampling: We noted the following for each institution: College of Southern Nevada A nonstatistical sample of 60 out of a population of 1,953 student returns was selected for testing. o Two of the returns were not calculated correctly. One return was calculated as $870 but should have been $1,180. The other return was calculated as $579 but should have been $381. o Two of the returns were not timely. One was 12 days late and the other was 35 days late. University of Nevada, Las Vegas A nonstatistical sample of 60 out of a population of 857 student returns was selected for testing. o One return was not calculated correctly. It was calculated as $2,270 but should have been $1,975. o For one student who did not re-enroll in the Spring 2024 term, their Pell Grant was appropriately cancelled; however, the student’s Fall 2023 Pell Grant was also returned, even though the student had completed 100% of the term. Therefore, $1,555 was returned when it should not have been. University of Nevada, Reno A nonstatistical sample of 60 out of a population of 421 student returns was selected for testing. o Two of the returns were not calculated correctly. One return was calculated as $2,443 but should have been $2,438. One return was calculated as $2,243 but should have been $2,235. o Three of the returns were not timely. The three returns were 3 days, 4 days, and 10 days late, respectively. Repeat Finding from Prior Year: Yes, prior year finding 2023-003. Recommendation: We recommend CSN, UNLV, and UNR enhance internal controls to ensure R2T4 is calculated correctly and timely. In particular, to enhance internal controls to ensure the appropriate days in the term are being used and that the appropriate amount of institution charges is used. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Special Tests & Provisions – Return of Title IV (R2T4) Material Weakness in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included in the Student Financial Assistance Cluster for CSN, UNLV, and UNR on the Schedule of Expenditures of Federal Awards. Criteria: In accordance with 34 CFR 668.173(b) and 34 CFR 668.22(e), when a student ceases attendance during a payment period or period of enrollment, drops, takes a leave of absence, or never begins attendance, institutions are required to calculate the percentage of Title IV aid earned following the guidance of the calculation worksheets in Appendix to Volume 5 of the FSA Handbook. When a return of Title IV aid is required, an institution has 45 days (or 30 days for students that never began attendance) to return the funds to Ed. Condition: There were instances where the calculation of returns was not calculated correctly or were not returned within the required allotted time. Cause: The following institutions did not have adequate internal controls to ensure R2T4 was calculated correct, and funds returned within the required time: o College of Southern Nevada (CSN) o University of Nevada, Las Vegas (UNLV) o University of Nevada, Reno (UNR) Effect: The U.S. Department of Education did not receive returns timely or accurately. Questioned Costs: None Context/Sampling: We noted the following for each institution: College of Southern Nevada A nonstatistical sample of 60 out of a population of 1,953 student returns was selected for testing. o Two of the returns were not calculated correctly. One return was calculated as $870 but should have been $1,180. The other return was calculated as $579 but should have been $381. o Two of the returns were not timely. One was 12 days late and the other was 35 days late. University of Nevada, Las Vegas A nonstatistical sample of 60 out of a population of 857 student returns was selected for testing. o One return was not calculated correctly. It was calculated as $2,270 but should have been $1,975. o For one student who did not re-enroll in the Spring 2024 term, their Pell Grant was appropriately cancelled; however, the student’s Fall 2023 Pell Grant was also returned, even though the student had completed 100% of the term. Therefore, $1,555 was returned when it should not have been. University of Nevada, Reno A nonstatistical sample of 60 out of a population of 421 student returns was selected for testing. o Two of the returns were not calculated correctly. One return was calculated as $2,443 but should have been $2,438. One return was calculated as $2,243 but should have been $2,235. o Three of the returns were not timely. The three returns were 3 days, 4 days, and 10 days late, respectively. Repeat Finding from Prior Year: Yes, prior year finding 2023-003. Recommendation: We recommend CSN, UNLV, and UNR enhance internal controls to ensure R2T4 is calculated correctly and timely. In particular, to enhance internal controls to ensure the appropriate days in the term are being used and that the appropriate amount of institution charges is used. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
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: CSN has contracted with a third-party vendor to help review and process R2T4 accounts within the federally mandated timeframe. CSN is currently in the training phase and expects to have the vendor begin reviewing R2T4 file in the next several weeks. In addition, regular monthly training will be provided to CSN staff and the third-party vendor. Quality control through the review of processed R2T4 files will be performed twice a month. • How compliance and performance will be measured and documented for future audit, management and performance review: In collaboration with the third-party vendor, CSN will run R2T4 queries twice a month to ensure all files are reviewed within the federally mandated timeframe. The vendor will also review internally selected files for accuracy. CSN will also randomly select processed files review to meet compliance requirements. CSN will meet with the vendor on a monthly basis and maintain communication throughout the year to ensure consistency and compliance. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Assistant Director of Processing in the Office of Financial Aid will be responsible for repeat or similar observations. UNLV – Agrees with the finding. There were two findings at the conclusion of the audit. Corrective action plans as well as measurements of compliance and performance correspond with the following two findings: 1. A return was calculated as $2,270, but should have been $1,975. 2. The second finding was regarding an improper return. UNLV’s calculation was correct at $0, as documented for the audit team. Months after the R2T4 calculation was performed, the student did not return to UNLV. At that time, their Pell Grant was appropriately canceled, but due to a system error, their Pell Grant for the entire year was canceled instead of just for subsequent semesters. Through our internal controls we found this error, but did so beyond the permissible 180-day late disbursement period. The error was unrelated to the R2T4 process and had no bearing on the correctly performed calculation. Since the Pell Grant could not be reinstated, we made the student whole with institutional funds. • 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: 1. Since the late disbursement period had passed, and the student had no balance due, there was no immediate corrective action that could be taken. The calculation error related to a withdrawal date incorrectly reported by a faculty member during spring break. The PeopleSoft system is set up to prevent the entry of such spring break withdrawal dates, and we were unable to replicate the error. The issue has therefore been escalated to our technical team for investigation and for prevention in future years. Even if this proves successful, we will ensure that at least two staff responsible for oversight of the R2T4 function will sign off each spring that no calculations are based on a withdrawal date that occurs during spring break. The signoff will occur within seven days of the end of spring break, so that if any error is identified we may still correct it while remaining within the appropriate R2T4 timelines. 2. The erroneous retroactive cancellation of Pell Grants for unenrolled students is now a known PeopleSoft issue. Beginning in fall 2024, we have established programming that packages Pell Grants on a semester-by-semester basis so that any changes to a current-term grant do not impact a prior-term grant. • How compliance and performance will be measured and documented for future audit, management and performance review: 1. A report exists in PeopleSoft that documents the withdrawal date of each student for whom an R2T4 calculation is performed. This report will be used to collect signoffs by two UNLV staff with R2T4 oversight that no calculations are based on a withdrawal date occurring during spring break, and will serve as the basis for that signoff. 2. Pell recipients' accounts will be reviewed in spring 2025 to ensure our packaging approach was effective in preventing retroactive grant cancellations. The team will review monthly to ensure we stay within the 180-day late disbursement time frame, which will allow us to reinstate Pell Grants retroactively, should our original solution prove ineffective. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: If similar errors around spring break R2T4 calculations and/or retroactive Pell Grant cancellations occur in the future, of primary accountability will be the Assistant Director of Processing, the Associate Director of Operations, the Associate Director of Processing and Client Services (currently vacant), the Director, and the Executive Director. UNR – Agrees with the finding. The Financial Aid office recognizes a shortfall in this area due to unexpected changes in staffing. • 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: New R2T4 staff is currently undergoing in-depth calculation training which includes internal trainings, NASFAA workshops, and Federal Student Aid provided trainings. In addition, starting this fall, 100% of R2T4 files are being reviewed by a staff member who was not responsible for the initial calculation. To prevent late returns, our office is calculating returns within 15 days of the withdrawal date and return funds within 30 days of the withdrawal. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance with the above corrective action will be monitored by the Data Manager, who will be reviewing weekly R2T4 reports completed by R2T4 staff. Reports with return data will be compiled in one centralized location to ensure transparency of current return status, and a physical audit trail documented on the R2T4 coversheet detailing initial calculation date, audit check date, and return to COD date. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The R2T4 staff and the Financial Aid Director will be responsible. 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
2023-003
Change in enrollment status was not reported accurately or timely. Cause: The Nevada State University (NSU) did not have adequate internal controls to ensure changes in a student’s enrollment status was correctly reported to the National Student Clearinghouse. In addition, NSU did not have adequate internal controls to ensure timely reporting of the change in enrollment status. Effect: Non-timely and inaccurate reporting to the NSLDS could potentially impact future eligibility determinations and repayment provisions. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 out of a population of 772 students who had a change in their enrollment status was selected for testing. We noted four student’s enrollment status changes were not reported accurately. In addition, we noted 20 enrollment status changes were not reported timely. These twenty instances ranged from 2 days late to 62 days late with an average of 31 days late. Repeat Finding from Prior Year: No Recommendation: We recommend NSU enhance internal controls to ensure changes in a student’s enrollment status is correctly reported to the National Student Clearinghouse. In addition, we recommend NSU enhance internal controls to ensure timely reporting of the change in enrollment status. Views of Responsible Officials: The Nevada State University agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Student Financial Assistance Cluster: Federal Supplemental Educational Opportunity Grants, 84.007 Federal Work-Study Program, 84.033 Federal Perkins Loan Program, 84.038 Federal Pell Grant Program, 84.063 Federal Direct Student Loans, 84.268 Teacher Education Assistance for College and Higher Education Grants, 84.379 Nurse Faculty Loan Program, 93.264 Health Professions Student Loans, Including Primary Care Loans and Loans for Disadvantaged Students, 93.342 Nursing Student Loans, 93.364 Special Tests & Provisions – Enrollment Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Grant Award Number: Potentially affects all grant awards included in the Student Financial Assistance Cluster for NSU on the Schedule of Expenditures of Federal Awards. Criteria: 34 CFR 690.83(b)(2) and 34 CFR 685.309 states that institutions are responsible for timely and accurate reporting of a student’s enrollment status and changes in those enrollment statues, whether they report directly or via a third-party servicer. When an Institution is made aware of a change in a student’s enrollment status, the Institution has 60 days to update the change in enrollment status via NSLDS. Condition: Change in enrollment status was not reported accurately or timely. Cause: The Nevada State University (NSU) did not have adequate internal controls to ensure changes in a student’s enrollment status was correctly reported to the National Student Clearinghouse. In addition, NSU did not have adequate internal controls to ensure timely reporting of the change in enrollment status. Effect: Non-timely and inaccurate reporting to the NSLDS could potentially impact future eligibility determinations and repayment provisions. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 out of a population of 772 students who had a change in their enrollment status was selected for testing. We noted four student’s enrollment status changes were not reported accurately. In addition, we noted 20 enrollment status changes were not reported timely. These twenty instances ranged from 2 days late to 62 days late with an average of 31 days late. Repeat Finding from Prior Year: No Recommendation: We recommend NSU enhance internal controls to ensure changes in a student’s enrollment status is correctly reported to the National Student Clearinghouse. In addition, we recommend NSU enhance internal controls to ensure timely reporting of the change in enrollment status. Views of Responsible Officials: The Nevada State University agrees with this finding.
NSU – 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: To ensure accurate and timely reporting of changes in student enrollment status to the National Student Clearinghouse (NSC), Nevada State University (NSU) will enhance its internal controls by implementing the following measures: o Continue the current bi-weekly enrollment reporting schedule. o Set bi-weekly calendar reminders to ensure timely reporting, supplementing NSC notifications. o Establish end-of-term calendar reminders specifically for reporting graduated statuses promptly. o Work closely with the NSC to identify any students included in submitted enrollment reports whose statuses were not updated within the NSC or National Student Loan Data System (NSLDS), ensuring they are addressed even if they do not appear in the reject file. • How compliance and performance will be measured and documented for future audit, management and performance review: To ensure ongoing compliance and performance in reporting changes in student enrollment status, Nevada State University (NSU) will implement the following measures for tracking and documentation: o NSU will conduct monthly reviews of enrollment status reports to verify the accuracy and timeliness of submissions to the National Student Clearinghouse (NSC). o Detailed logs of all enrollment status submissions and NSC notifications will be maintained, including timestamps and submission confirmations, to serve as an audit trail for internal and external reviews. o Periodic internal audits will be scheduled to assess adherence to the bi-weekly and end-of-term reporting schedule, with results documented for management review. o Key performance indicators (KPIs) will be established, such as the percentage of on-time reports and the accuracy rate of enrollment status updates. These metrics will be reviewed quarterly by management. o Any discrepancies identified during audits will be addressed promptly, and corrective actions will be documented for future reference and performance evaluations. o NSU will compile annual compliance reports summarizing audit results, corrective actions, and performance metrics, which will be available for future audits and management reviews. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Registrar's Office holds primary responsibility for accurate and timely enrollment status reporting. The Registrar will oversee compliance with internal controls including the bi-weekly and end-of-term reporting schedules. Additional oversight will be conducted by the Provost and Vice President of Academic Affairs. 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
Expenditures charged to the grant were incurred outside of the period of performance. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: Less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($114,650) out of a population of 1,363 ($2,526,658) payroll expenditures across the Nevada System of Higher Education was selected for testing. UNLV payroll expenditures were 26 ($59,191) of the 60 selected for testing. We noted one payroll transaction totaling $303 was charged to the grant and incurred in February 2024. Subsequently we reviewed a summary of payroll expenditures, and we noted $8,021 in payroll expenditures charged to the grant that were incurred after December 31, 2023. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Treasury Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Coronavirus State and Local Fiscal Recovery Fund, 21.027 Allowable Costs/Cost Principles and Period of Performance Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award 22-1308.033 included under assistance listing 21.027 for UNLV 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) provides that a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The terms and conditions of the grant agreement specified that the term of the agreement was to expire on December 31, 2023. Condition: Expenditures charged to the grant were incurred outside of the period of performance. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: Less than $25,000. Context/Sampling: A nonstatistical sample of 60 ($114,650) out of a population of 1,363 ($2,526,658) payroll expenditures across the Nevada System of Higher Education was selected for testing. UNLV payroll expenditures were 26 ($59,191) of the 60 selected for testing. We noted one payroll transaction totaling $303 was charged to the grant and incurred in February 2024. Subsequently we reviewed a summary of payroll expenditures, and we noted $8,021 in payroll expenditures charged to the grant that were incurred after December 31, 2023. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
UNLV – 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 UNLV Office of Sponsored Programs will collaborate with payroll and budget offices to develop a procedure to ensure costing allocations assigned by colleges/departments are within the period of performance. We expect this procedure to be vetted and implemented by spring 2025. • How compliance and performance will be measured and documented for future audit, management and performance review: UNLV OSP will monitor costing allocations and efficiently communicate to colleges/departments to identify allocations beyond the period of performance. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsible for communicating the importance of enhanced review of accounts and payroll costing allocations to monitoring accounts. 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
There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Information reported to the pass-through entity did not agree to underlying supporting records. Cause: The following institutions of the Nevada System of Higher Education did not have adequate internal controls to provide for the documented review and approval of reports submitted to the pass-through entity: o University of Nevada, Reno (UNR) o University of Nevada, Las Vegas (UNLV) o Desert Research Institute (DRI) o System Administration (SA) In addition, UNR, UNLV, and SA did not have adequate internal controls to ensure amounts reported to the pass-through entity were supported by the underlying records. Effect: Inaccurate information was reported to the pass-through entity by UNR, UNLV, and SA. Inaccurate information may be reported to the pass-through entity by UNR, UNLV, SA, and DRI and not detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of eight Quarterly Progress Reports out of a population of 52 across the Nevada System of Higher Education was selected for testing. A nonstatistical sample of 27 Requests for Reimbursement out of a population of 176 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: University of Nevada, Reno Three of the eight Quarterly Progress Reports were applicable to UNR. We noted that there was no evidence of review on any of the three Quarterly Progress Reports. In addition, for the quarter ended December 31, 2023 report for grant award #22UNRDN01, amounts were not supported by the underlying records: Key Line Item Amount Reported Amount Supported Households Served 2,492 7,455 University of Nevada, Las Vegas Four of the eight Quarterly Progress Reports were applicable to UNLV. For the quarter ended December 31, 2023 and March 31, 2024 reports for grant award #23UNLVF01, amounts were not supported by the underlying records as follows: Quarter Ended December 31, 2023 Key Line Item Amounted Reported Amount Supported Previously Expended 129,249 128,141 Households Served 575 966 Individuals Served 1,740 2,893 Quarter Ended March 31, 2024 Key Line Item Amount Reported Amount Supported Previously Expended 155,327 137,600 Households Served 2,797 2,827 Desert Research Institute One of the 27 Requests for Reimbursement were applicable to DRI. We noted that there was no evidence of review on the one Request for Reimbursement selected for testing. System Administration One of the eight Quarterly Progress Reports was applicable to SA. We noted that there was no evidence of review on the one Quarterly Progress Report selected for testing. In addition, for the quarter ended March 31, 2024 report for grant award #23CCWIG01, amounts were not supported by the underlying records as follows: Key Line Item Amount Reported Amount Supported CSN students served 971 1,451 GBC students served 120 160 TMCC students served 282 343 WNC students served 114 170 Repeat Finding from Prior Year: No Recommendation: We recommend the Nevada System of Higher Education institutions listed above enhance internal controls to provide for the documented review and approval of reports submitted to pass-through entities and ensure amounts are supported by the underlying records. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The Desert Research Institute agrees with this finding. System Administration agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Treasury Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Coronavirus State and Local Fiscal Recovery Fund, 21.027 Reporting Material Weakness in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 21.027 for UNR, UNLV, DRI, and SA 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 effect 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. The OMB Compliance Supplement provides that reporting requirements for subrecipients are as specified by the pass-through entity. The pass-through entities required the submission of Quarterly Progress Reports and/or Requests for Reimbursement. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Information reported to the pass-through entity did not agree to underlying supporting records. Cause: The following institutions of the Nevada System of Higher Education did not have adequate internal controls to provide for the documented review and approval of reports submitted to the pass-through entity: o University of Nevada, Reno (UNR) o University of Nevada, Las Vegas (UNLV) o Desert Research Institute (DRI) o System Administration (SA) In addition, UNR, UNLV, and SA did not have adequate internal controls to ensure amounts reported to the pass-through entity were supported by the underlying records. Effect: Inaccurate information was reported to the pass-through entity by UNR, UNLV, and SA. Inaccurate information may be reported to the pass-through entity by UNR, UNLV, SA, and DRI and not detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of eight Quarterly Progress Reports out of a population of 52 across the Nevada System of Higher Education was selected for testing. A nonstatistical sample of 27 Requests for Reimbursement out of a population of 176 across the Nevada System of Higher Education was selected for testing. The following errors were noted by institution: University of Nevada, Reno Three of the eight Quarterly Progress Reports were applicable to UNR. We noted that there was no evidence of review on any of the three Quarterly Progress Reports. In addition, for the quarter ended December 31, 2023 report for grant award #22UNRDN01, amounts were not supported by the underlying records: Key Line Item Amount Reported Amount Supported Households Served 2,492 7,455 University of Nevada, Las Vegas Four of the eight Quarterly Progress Reports were applicable to UNLV. For the quarter ended December 31, 2023 and March 31, 2024 reports for grant award #23UNLVF01, amounts were not supported by the underlying records as follows: Quarter Ended December 31, 2023 Key Line Item Amounted Reported Amount Supported Previously Expended 129,249 128,141 Households Served 575 966 Individuals Served 1,740 2,893 Quarter Ended March 31, 2024 Key Line Item Amount Reported Amount Supported Previously Expended 155,327 137,600 Households Served 2,797 2,827 Desert Research Institute One of the 27 Requests for Reimbursement were applicable to DRI. We noted that there was no evidence of review on the one Request for Reimbursement selected for testing. System Administration One of the eight Quarterly Progress Reports was applicable to SA. We noted that there was no evidence of review on the one Quarterly Progress Report selected for testing. In addition, for the quarter ended March 31, 2024 report for grant award #23CCWIG01, amounts were not supported by the underlying records as follows: Key Line Item Amount Reported Amount Supported CSN students served 971 1,451 GBC students served 120 160 TMCC students served 282 343 WNC students served 114 170 Repeat Finding from Prior Year: No Recommendation: We recommend the Nevada System of Higher Education institutions listed above enhance internal controls to provide for the documented review and approval of reports submitted to pass-through entities and ensure amounts are supported by the underlying records. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding. The University of Nevada, Las Vegas agrees with this finding. The Desert Research Institute agrees with this finding. System Administration agrees with this finding.
UNR – 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: Management staff, independent of the preparer, will review and sign off on each report. This review process will include verifying that all information is correctly entered. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance and performance will be measured through the independent review process, where management will verify and sign off on each report to ensure accuracy. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. UNLV – 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: UNLV Office of Sponsored Programs will work with PIs to ensure there is properly documented review of progress reports. PIs will be expected to demonstrate review of progress reports and provide supporting documentation for data. • How compliance and performance will be measured and documented for future audit, management and performance review: Effective immediately, UNLV OSP will maintain communications with PIs to perform monitoring throughout the life of the award. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility along with applicable Deans. DRI – 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: DRI will implement controls that require the documentation of review and approval on the invoice process. With the current limited resources available in DRI’s Financial Services team, a position will be recruited as soon as possible with an anticipated start date in early spring 2025. It is expected that this position will support the full implementation of review procedures once on board. • How compliance and performance will be measured and documented for future audit, management and performance review: Once the position is filled, all invoices will be reviewed prior to drawing down or requesting reimbursement of funds. Documentation will occur either through the business process in the accounting system or manually as needed. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future if repeat or similar observations are noted. SA – 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: Future progress reports will require a review from a Director or higher supervisory approval prior to submission of reports to awarding sponsor/agency. • How compliance and performance will be measured and documented for future audit, management and performance review: Preparing department will provide either a signed version and/or email approval of progress report to the NSHE System Sponsored Programs to be filed with the award in Workday. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The NSHE System Sponsored Programs Director is responsible for remediation of this finding. 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
There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: Western Nevada College (WNC) did not have adequate internal controls to provide for the documented review and approval of Requests for Reimbursement submitted to the pass-through entity. Effect: Inaccurate information may be reported to the pass-through entity and funds may not be drawn on a reimbursement basis and not detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 12 Requests for Reimbursement out of a population of 76 across the Nevada System of Higher Education was selected for testing. Three of the Requests for Reimbursement were applicable to WNC. We noted that there was no evidence of review on any of the three Requests for Reimbursement. Repeat Finding from Prior Year: No Recommendation: We recommend WNC enhance internal controls to provide for the documented review and approval of Requests for Reimbursement. Views of Responsible Officials: The Western Nevada College agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Direct and Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Adult Education – Basic Grants to States, 84.002 Cash Management Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 84.002 for WNC 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 effect 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. The pass-through entity requires the submission of Requests for Reimbursement. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Cause: Western Nevada College (WNC) did not have adequate internal controls to provide for the documented review and approval of Requests for Reimbursement submitted to the pass-through entity. Effect: Inaccurate information may be reported to the pass-through entity and funds may not be drawn on a reimbursement basis and not detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 12 Requests for Reimbursement out of a population of 76 across the Nevada System of Higher Education was selected for testing. Three of the Requests for Reimbursement were applicable to WNC. We noted that there was no evidence of review on any of the three Requests for Reimbursement. Repeat Finding from Prior Year: No Recommendation: We recommend WNC enhance internal controls to provide for the documented review and approval of Requests for Reimbursement. Views of Responsible Officials: The Western Nevada College agrees with this finding.
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 will require that all grant invoices, effective with the October 2024 billing cycle, require a level of review. The finding for 2024 was due to vacancies in the Controller’s Office and inadequate staffing. WNC has since upgraded the vacant position and posted a recruitment to help mitigate this in the future. • How compliance and performance will be measured and documented for future audit, management and performance review: All grant invoices going forward will have a second level of review prior to drawing down or requesting reimbursement of funds. Documentation (such as email approval, Workday approval or hard copy signature) will be compiled for each grant invoice to provide evidence that a second level of review has been obtained. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Chief Financial Officer may be held accountable in the future 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
There was no evidence of reviewing budget to actual expenditures to ensure compliance with the earmarking requirement. In addition, spending on non-instructional costs exceeded the maximum limit negotiated with the state eligible agency. Cause: The College of Southern Nevada (CSN) and Western Nevada College (WNC) did not have adequate internal controls to ensure non-instructional costs did not exceed the maximum proportional limit negotiated with the state eligible agency. Effect: Administrative non-instructional costs exceeded the allowable amount and may subsequently exceed the allowable amount and not be detected. Questioned Costs: Less than $25,000 Context/Sampling: A nonstatistical sample of 12 monthly budget to actual expense reconciliations out of a population of 48 across the Nevada System of Higher Education was selected for testing. In addition, the instructional earmark was tested as a whole for each applicable institution. The following errors were noted by each institution: College of Southern Nevada CSN exceeded the maximum spending for non-instructional expenditures as follows: Program Allowable Non-Instructional % Actual Non-Instructional % Questioned Costs Basic 22.40% 22.77% $6,363 Western Nevada College Three monthly budget to actual expense reconciliations were applicable to WNC. We noted that there was no evidence of review on any of the three reconciliations. WNC exceeded the maximum spending for non-instructional expenditures as follows: Program Allowable Non-Instructional % Actual Non-Instructional % Questioned Costs IEL and Civics 10.00% 16.84% $17,308 Repeat Finding from Prior Year: No Recommendation: We recommend CSN and WNC enhance internal controls to ensure non-instructional costs do not exceed the maximum proportional limit negotiated with the state eligible agency. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. Western Nevada College agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Direct and Pass-through the State of Nevada as listed in the Schedule of Expenditures of Federal Awards Adult Education – Basic Grants to States, 84.002 Earmarking Material Weakness in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 84.002 for WNC and CSN 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 effect 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. Section 121(b)(1)(A) of WIOA provides that eligible providers must use at least 95 percent of the funds received from the state eligible agency to carry out adult education and literacy activities unless a lower limit has been agreed to by the state eligible agency. Eligible providers may use up to five percent of their funds for noninstructional costs, including planning, administration, professional development, providing services in alignment with the local workforce development plan and fulfilling certain one-stop partner responsibilities. The state eligible agency agreed to lower adult education and literacy limits and higher maximum noninstructional limits for the College of Southern Nevada and Western Nevada College as follows: o College of Southern Nevada Basic Instruction: Instructional – 77.6% / Non-instructional 22.40% Integrated English Literacy and Civics Instruction: Instructional – 88% / Non-instructional 12% o Western Nevada College Basic Instruction: Instructional – 74.83% / Non-instructional 15.27% Integrated English Literacy and Civics Instruction: Instructional – 90% / Non-instructional 10% Condition: There was no evidence of reviewing budget to actual expenditures to ensure compliance with the earmarking requirement. In addition, spending on non-instructional costs exceeded the maximum limit negotiated with the state eligible agency. Cause: The College of Southern Nevada (CSN) and Western Nevada College (WNC) did not have adequate internal controls to ensure non-instructional costs did not exceed the maximum proportional limit negotiated with the state eligible agency. Effect: Administrative non-instructional costs exceeded the allowable amount and may subsequently exceed the allowable amount and not be detected. Questioned Costs: Less than $25,000 Context/Sampling: A nonstatistical sample of 12 monthly budget to actual expense reconciliations out of a population of 48 across the Nevada System of Higher Education was selected for testing. In addition, the instructional earmark was tested as a whole for each applicable institution. The following errors were noted by each institution: College of Southern Nevada CSN exceeded the maximum spending for non-instructional expenditures as follows: Program Allowable Non-Instructional % Actual Non-Instructional % Questioned Costs Basic 22.40% 22.77% $6,363 Western Nevada College Three monthly budget to actual expense reconciliations were applicable to WNC. We noted that there was no evidence of review on any of the three reconciliations. WNC exceeded the maximum spending for non-instructional expenditures as follows: Program Allowable Non-Instructional % Actual Non-Instructional % Questioned Costs IEL and Civics 10.00% 16.84% $17,308 Repeat Finding from Prior Year: No Recommendation: We recommend CSN and WNC enhance internal controls to ensure non-instructional costs do not exceed the maximum proportional limit negotiated with the state eligible agency. Views of Responsible Officials: The College of Southern Nevada agrees with this finding. Western Nevada College agrees with this finding.
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
A documented review of eligibility determinations by an individual independent of the preparer (segregation of duties) was not in place. Cause: The University of Nevada, Reno (UNR) and the University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to provide for a documented review of eligibility determinations by an individual independent of the initial determination. Effect: An incorrect eligibility determination may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 eligibility determinations out of a population of 358 was selected for testing across the Nevada System of Higher Education. The following errors were noted by each institution: University of Nevada, Las Vegas UNLV had 23 eligibility determinations selected for testing of the sample of 60. We noted there was no evidence that eligibility determinations were reviewed by an individual independent of the determination for all 23 determinations. University of Nevada, Reno UNR had 19 eligibility determinations selected for testing of the sample of 60. We noted there was no evidence that eligibility determinations were reviewed by an individual independent of the determination for all 19 determinations. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV and UNR enhance internal controls to provide for a documented review of eligibility determinations by an individual independent of the initial determination. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Education Direct and Pass-through Utah State University as listed in the Schedule of Expenditures of Federal Awards Fund for the Improvement of Postsecondary Education, 84.116 Eligibility Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 84.116 for UNR and UNLV 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 effect 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. The grant terms and conditions specify various eligibility requirements that beneficiaries must meet to participate in the program, such as minimum GPA, academic status, degree seeking opportunities, and other demographic information. Condition: A documented review of eligibility determinations by an individual independent of the preparer (segregation of duties) was not in place. Cause: The University of Nevada, Reno (UNR) and the University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to provide for a documented review of eligibility determinations by an individual independent of the initial determination. Effect: An incorrect eligibility determination may occur and not be detected. Questioned Costs: None Context/Sampling: A nonstatistical sample of 60 eligibility determinations out of a population of 358 was selected for testing across the Nevada System of Higher Education. The following errors were noted by each institution: University of Nevada, Las Vegas UNLV had 23 eligibility determinations selected for testing of the sample of 60. We noted there was no evidence that eligibility determinations were reviewed by an individual independent of the determination for all 23 determinations. University of Nevada, Reno UNR had 19 eligibility determinations selected for testing of the sample of 60. We noted there was no evidence that eligibility determinations were reviewed by an individual independent of the determination for all 19 determinations. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV and UNR enhance internal controls to provide for a documented review of eligibility determinations by an individual independent of the initial determination. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
UNLV – 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: While there were no specific instances noted regarding eligibility issues, the UNLV Office of Sponsored Programs recognizes the importance of documentation through the COSO internal control framework and will ensure the controls are continued, effective immediately. UNLV OSP will continue to enhance the documentation for the administrative management of programs to review and determine eligibility of participants per the requirements of the project, and those employees will be reminded of the importance of evidencing their reviews. • How compliance and performance will be measured and documented for future audit, management and performance review: Verification of eligibility will continue to be performed as required, with enhanced documentation. If escalation is needed, the employee will seek guidance from a supervisor and properly document. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: UNLV Office of Sponsored Programs Executive Director will be responsible for communicating the importance of enhanced documentation to the designated employees responsible for eligibility. UNR – 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: Staff, independent of the preparer, will review and log each eligibility determination. • How compliance and performance will be measured and documented for future audit, management and performance review: A log will be maintained listing the review date and reviewer name for each determination. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Program Director, who is a Head Start Program Principal Investigator (PI), is responsible for remediation of this finding. 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
Expenditures charged to the grant were incurred outside of the period of performance. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: $81,075. Context/Sampling: A nonstatistical sample of 60 ($189,351) out of a population of 1,032 ($2,372,376) payroll expenditures across the Nevada System of Higher Education was selected for testing. UNR payroll expenditures were 44 ($112,139) of the 60 selected for testing. We noted one payroll transaction totaling $778 was charged to the grant and incurred in July 2023. A nonstatistical sample of 60 ($32,118) out of a population of 538 ($242,467) goods and services expenditures across the Nevada System of Higher Education was selected for testing. UNR goods and services expenditures were 49 ($25,743) of the 60 selected for testing. We noted four goods and services transactions totaling $413 were charged to the grant and incurred between July 2023 and December 2023. Subsequently we reviewed a summary of expenditures on the two grant awards noted, and we noted $81,075 in expenditures charged to the grants that were incurred after June 30, 2023. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards CCDF Cluster: Child Care and Development Block Grant, 93.575 Allowable Costs/Cost Principles and Period of Performance Material Weakness in Internal Control over Compliance Grant Award Number: Affects grant awards SP-2300023 and 2300026 included under assistance listing 93.575 for UNR 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) provides that a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The terms and conditions of the grant agreements specified that the period of performance was to expire on June 30, 2023. Condition: Expenditures charged to the grant were incurred outside of the period of performance. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to ensure costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: $81,075. Context/Sampling: A nonstatistical sample of 60 ($189,351) out of a population of 1,032 ($2,372,376) payroll expenditures across the Nevada System of Higher Education was selected for testing. UNR payroll expenditures were 44 ($112,139) of the 60 selected for testing. We noted one payroll transaction totaling $778 was charged to the grant and incurred in July 2023. A nonstatistical sample of 60 ($32,118) out of a population of 538 ($242,467) goods and services expenditures across the Nevada System of Higher Education was selected for testing. UNR goods and services expenditures were 49 ($25,743) of the 60 selected for testing. We noted four goods and services transactions totaling $413 were charged to the grant and incurred between July 2023 and December 2023. Subsequently we reviewed a summary of expenditures on the two grant awards noted, and we noted $81,075 in expenditures charged to the grants that were incurred after June 30, 2023. Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
UNR – 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: All invoices will be reviewed and approved by a manager independent of the preparer. The manager’s review will include verifying the accuracy of the invoice details, such as dates of the costs incurred, to ensure they fall within the period of performance. • How compliance and performance will be measured and documented for future audit, management and performance review: The manager's independent review and approval of each invoice, including verification of cost dates, will be tracked within the system’s business process history. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for remediation of this finding. 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
Subrecipient monitoring policies are not documented and subawards were missing required information. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure required subrecipient monitoring policies were established and ensure subawards included all required information. Effect: Noncompliance may occur at a subrecipient and not be detected by UNLV. Questioned Costs: None Context/Sampling: A nonstatistical sample of three subawards out of a population of eight was selected for testing. All three subawards were missing required communication including: o Access to the subrecipient’s records by UNLV and other auditors o Appropriate terms and conditions concerning the closeout of the subaward In addition, UNLV does not have written subrecipient monitoring policies. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV establish subrecipient monitoring policies and enhance internal controls to ensure subawards include all required information. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards CCDF Cluster: Child Care and Development Block Grant, 93.575 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Grant Award Number: Affects grant award CC2312 included under assistance listing 93.575 for UNLV 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 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. Condition: Subrecipient monitoring policies are not documented and subawards were missing required information. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure required subrecipient monitoring policies were established and ensure subawards included all required information. Effect: Noncompliance may occur at a subrecipient and not be detected by UNLV. Questioned Costs: None Context/Sampling: A nonstatistical sample of three subawards out of a population of eight was selected for testing. All three subawards were missing required communication including: o Access to the subrecipient’s records by UNLV and other auditors o Appropriate terms and conditions concerning the closeout of the subaward In addition, UNLV does not have written subrecipient monitoring policies. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV establish subrecipient monitoring policies and enhance internal controls to ensure subawards include all required information. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
UNLV – 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: UNLV Office of Sponsored Programs will implement the required controls for subrecipient risk assessment immediately. Additionally, UNLV OSP will enhance our current tools using the guidance of the Federal Demonstration Partnership for national standardized forms for subrecipient monitoring. Policies and procedures will be in place by the end of the calendar year 2024, and monitoring will be performed annually. • How compliance and performance will be measured and documented for future audit, management and performance review: Materials–to include the risk assessment, degree of sub monitoring required, and training for all OSP personnel–will be completed within 60 days. The risk assessment will be attached to each fully executed subrecipient agreement and, as applicable, annual risk assessments will be completed. Policies and procedures are being developed and are expected to be in place by the end of the calendar year 2024. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility. 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
There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Information reported to the pass-through entity did not agree to underlying supporting records. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to provide for the documented review and approval of SF-425 reports or subaward information required by the FFATA. Effect: Inaccurate information was reported to the federal agency on the SF-425 and may be reported to the federal agency for the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and not detected. Questioned Costs: None Context/Sampling: The entire population of six SF-425 reports submitted during the year was selected for testing. We noted that there was no evidence of review on any of the six SF-425 reports. The entire population of one subaward report submitted during the year was selected for testing. We noted that there was no evidence of review for the one subaward report required by the FFATA. The following errors were noted by report: December 31, 2023 SF-425 Key Line Item Amount Reported Amount Supported Direct Costs $46,048 $45,892 Indirect costs $8,126 $8,077 July 31, 2023 SF-425 Final Key Line Item Amount Reported Amount Supported Direct Costs $2,006,888 $2,006,935 Indirect costs $160,551 $160,555 Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to provide for the documented review and approval of SF-425 reports and subaward information required by the FFATA. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Head Start, 93.600 Reporting Significant Deficiency in Internal Control over Compliance Grant Award Number: Potentially affects all grant awards included under assistance listing 93.600 for UNR 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 effect 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. The OMB Compliance Supplement provides that grant recipients are required to submit a Federal Financial Report (SF-425). The Federal Funding Accountability and Transparency Act (FFATA) requires direct recipients of certain federal awards to report subaward information. Condition: There was no evidence of review and approval (segregation of duties) between the preparer and reviewer. Information reported to the pass-through entity did not agree to underlying supporting records. Cause: The University of Nevada, Reno (UNR) did not have adequate internal controls to provide for the documented review and approval of SF-425 reports or subaward information required by the FFATA. Effect: Inaccurate information was reported to the federal agency on the SF-425 and may be reported to the federal agency for the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and not detected. Questioned Costs: None Context/Sampling: The entire population of six SF-425 reports submitted during the year was selected for testing. We noted that there was no evidence of review on any of the six SF-425 reports. The entire population of one subaward report submitted during the year was selected for testing. We noted that there was no evidence of review for the one subaward report required by the FFATA. The following errors were noted by report: December 31, 2023 SF-425 Key Line Item Amount Reported Amount Supported Direct Costs $46,048 $45,892 Indirect costs $8,126 $8,077 July 31, 2023 SF-425 Final Key Line Item Amount Reported Amount Supported Direct Costs $2,006,888 $2,006,935 Indirect costs $160,551 $160,555 Repeat Finding from Prior Year: No Recommendation: We recommend UNR enhance internal controls to provide for the documented review and approval of SF-425 reports and subaward information required by the FFATA. Views of Responsible Officials: The University of Nevada, Reno agrees with this finding.
UNR – 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: Management staff, independent of the preparer, will review and sign off on each report, ensuring all information is correctly entered. Staff will also verify that all required FFATA (Federal Funding Accountability and Transparency Act) reporting is accurately completed and submitted in a timely manner. • How compliance and performance will be measured and documented for future audit, management and performance review: Compliance and performance will be measured and documented through the independent review process, where management, independent of the preparer will verify and sign off on each report to ensure accuracy. These reviews will be tracked in Workday, with approvals and date stamps. A FFATA Entry Log will be maintained, documenting each submission. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of Post Award is responsible for the reports. The Associate Director of PreAward is responsible for the FFATA. 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
Expenditures charged to the grant were not included within the budget narrative included in the grant’s terms and conditions. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure allowable costs were charged to the grant. Effect: Unallowable costs were charged to the program. Questioned Costs: $602 Context/Sampling: A nonstatistical sample of 60 ($38,218) out of a population of 573 ($326,835) goods and services expenditures across the Nevada System of Higher Education was selected for testing. UNLV goods and services expenditures were 31 ($24,615) of the 60 selected for testing. We noted one goods and services transaction totaling $602 for a catered dinner for employees, students, partnering individuals, and the UNLV practice clinic to celebrate the year’s developments within related programs was charged to the grant. This charge while otherwise reasonable, was not included within the grant’s budget narrative and justification. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV enhance internal controls to ensure allowable costs are charged to the grant. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Block Grants for Community Mental Health Services, 93.958 Activities Allowed or Unallowed and Allowable Costs/Cost Principles Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award SG25656 included under assistance listing 93.958 for UNLV on the Schedule of Expenditures of Federal Awards. Criteria: The OMB Compliance Supplement provides that state cost principle requirements apply to the mental health block grant. Therefore, the allowable activities and costs are included within the grant terms and conditions as passed-through the State of Nevada. The grant terms and conditions provide a budget and justification for various expenditure types. These expenditure types included: personnel, travel, operating, equipment, and contractual direct costs. The operating costs included more specific justification for: website design, software, testing supplies, marketing materials, client transportation, translation services, medical equipment, and peer support group supplies. Condition: Expenditures charged to the grant were not included within the budget narrative included in the grant’s terms and conditions. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure allowable costs were charged to the grant. Effect: Unallowable costs were charged to the program. Questioned Costs: $602 Context/Sampling: A nonstatistical sample of 60 ($38,218) out of a population of 573 ($326,835) goods and services expenditures across the Nevada System of Higher Education was selected for testing. UNLV goods and services expenditures were 31 ($24,615) of the 60 selected for testing. We noted one goods and services transaction totaling $602 for a catered dinner for employees, students, partnering individuals, and the UNLV practice clinic to celebrate the year’s developments within related programs was charged to the grant. This charge while otherwise reasonable, was not included within the grant’s budget narrative and justification. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV enhance internal controls to ensure allowable costs are charged to the grant. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
UNLV – 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: UNLV will review business processes related to routing and approval of expenditures under specific categories (i.e.: hosting, participant support, etc.) as it relates to grants. If the review dictates that business processes need to be revised, this will be completed by spring 2025 to incorporate any necessary changes. • How compliance and performance will be measured and documented for future audit, management and performance review: The Office of Sponsored Programs and the applicable departments will collaborate to ensure oversight of expenditures to determine allowability. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility, and will communicate regularly with the Deans and business managers. 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
Expenditures charged to the grant were incurred outside of the period of performance. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: $28,231 Context/Sampling: A nonstatistical sample of 60 ($38,218) out of a population of 573 ($326,835) goods and services expenditures across the Nevada System of Higher Education was selected for testing. UNLV goods and services expenditures were 31 ($24,615) of the 60 selected for testing. We noted one goods and services transaction for $33 was charged to the grant and incurred in March 2024. Subsequently, we reviewed a summary of expenditures, and we noted $28,231 in expenditures charged to the grant that were incurred after February 28, 2024. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Block Grants for Community Mental Health Services, 93.958 Allowable Costs/Cost Principles and Period of Performance Significant Deficiency in Internal Control over Compliance Grant Award Number: Affects grant award SG25656 included under assistance listing 93.958 for UNLV 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) provides that a non-federal entity may charge only allowable costs incurred during the approved budget period of a federal award’s period of performance. The terms and conditions of the grant agreement specified that the subaward period of performance was to expire on February 28, 2024. Condition: Expenditures charged to the grant were incurred outside of the period of performance. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure costs were incurred within the period of performance. Effect: Unallowable costs were charged to the program. Questioned Costs: $28,231 Context/Sampling: A nonstatistical sample of 60 ($38,218) out of a population of 573 ($326,835) goods and services expenditures across the Nevada System of Higher Education was selected for testing. UNLV goods and services expenditures were 31 ($24,615) of the 60 selected for testing. We noted one goods and services transaction for $33 was charged to the grant and incurred in March 2024. Subsequently, we reviewed a summary of expenditures, and we noted $28,231 in expenditures charged to the grant that were incurred after February 28, 2024. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV enhance internal controls to ensure costs are incurred within the period of performance. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding.
UNLV – 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: UNLV Office of Sponsored Programs will collaborate with the Controller’s Office to ensure expenditure postings are within the period of performance. This review and any applicable changes will go into effect by the end of the calendar year 2024. • How compliance and performance will be measured and documented for future audit, management and performance review: UNLV Office of Sponsored Programs will monitor expenditures within the period of performance and efficiently communicate to colleges/departments to identify transactions that are deemed unallowable. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility. 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
Subrecipient monitoring policies are not documented, subawards were missing required information, and subrecipient audit reports were not monitored or reviewed. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure required subrecipient monitoring policies were established, ensure subawards included all required information, and monitor subrecipient audit reports. The University of Nevada, Reno (UNR) did not have adequate internal controls to monitor subrecipient audit reports. Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: The entire population of three subrecipients/subawards was selected for testing across both UNLV (one) and UNR (two). The following errors were noted: University of Nevada, Las Vegas The subaward was missing required communication including: o Access to the subrecipient’s records by UNLV and other auditors o Appropriate terms and conditions concerning the closeout of the subaward In addition, UNLV does not have written subrecipient monitoring policies. Lastly, there was no mechanism in place to verify the subrecipient was audited, if required, or to monitor and review the audit report for audit findings that would require UNLV to issue a management decision and ensure timely corrective action. University of Nevada, Reno There was no mechanism in place to verify that one of the two subrecipients was audited, if required, or to monitor and review the audit report for audit findings that would require UNR to issue a management decision and ensure timely corrective action. The audit report for the second subrecipient was not applicable for testing as it was the first year of the subaward. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV establish subrecipient monitoring policies and enhance internal controls to ensure subawards include all required information. In addition, we recommend UNLV and UNR enhance internal controls to monitor subrecipient audit reports to ensure management decisions would be issued timely and subrecipients take timely corrective action, if applicable. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
Show full finding ▾Hide full finding ▴U.S. Department of Health and Human Services Pass-through the State of Nevada and others as listed in the Schedule of Expenditures of Federal Awards Block Grants for Community Mental Health Services, 93.958 Subrecipient Monitoring Material Weakness in Internal Control over Compliance Grant Award Number: Affects grant awards SG26221, SG25959, and SG26361 included under assistance listing 93.958 for UNLV and UNR, as applicable, 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 200.332 requires that: o Pass-through entities establish policies for subrecipient monitoring that have a risk-based approach to determine the appropriate monitoring. o Pass-through entities ensure that every subaward includes certain information at the time of the subaward. o Pass-through entities verify every subrecipient is audited as required by Uniform Guidance, issue management decisions for audit findings, as applicable, and ensure the subrecipient take timely corrective action on all audit findings, as applicable. Condition: Subrecipient monitoring policies are not documented, subawards were missing required information, and subrecipient audit reports were not monitored or reviewed. Cause: The University of Nevada, Las Vegas (UNLV) did not have adequate internal controls to ensure required subrecipient monitoring policies were established, ensure subawards included all required information, and monitor subrecipient audit reports. The University of Nevada, Reno (UNR) did not have adequate internal controls to monitor subrecipient audit reports. Effect: Noncompliance may occur at a subrecipient and not be detected. Questioned Costs: None Context/Sampling: The entire population of three subrecipients/subawards was selected for testing across both UNLV (one) and UNR (two). The following errors were noted: University of Nevada, Las Vegas The subaward was missing required communication including: o Access to the subrecipient’s records by UNLV and other auditors o Appropriate terms and conditions concerning the closeout of the subaward In addition, UNLV does not have written subrecipient monitoring policies. Lastly, there was no mechanism in place to verify the subrecipient was audited, if required, or to monitor and review the audit report for audit findings that would require UNLV to issue a management decision and ensure timely corrective action. University of Nevada, Reno There was no mechanism in place to verify that one of the two subrecipients was audited, if required, or to monitor and review the audit report for audit findings that would require UNR to issue a management decision and ensure timely corrective action. The audit report for the second subrecipient was not applicable for testing as it was the first year of the subaward. Repeat Finding from Prior Year: No Recommendation: We recommend UNLV establish subrecipient monitoring policies and enhance internal controls to ensure subawards include all required information. In addition, we recommend UNLV and UNR enhance internal controls to monitor subrecipient audit reports to ensure management decisions would be issued timely and subrecipients take timely corrective action, if applicable. Views of Responsible Officials: The University of Nevada, Las Vegas agrees with this finding. The University of Nevada, Reno agrees with this finding.
UNLV – 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: UNLV Office of Sponsored Programs will leverage applicable controls and establish subrecipient policy to ensure complete information is included in the subaward agreements. Subrecipient risk will be analyzed through a required assessment. Continued monitoring will be performed throughout the life of the project and will include review of audit reports and timely invoicing. The implementation of the policy, risk assessment and sub monitoring will be completed by the end of the calendar year 2024. • How compliance and performance will be measured and documented for future audit, management and performance review: The related materials and required communications will be attached to each fully executed subrecipient agreement. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The UNLV Office of Sponsored Programs Executive Director is accountable for exercising oversight and responsibility. UNR – 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: Subaward specialists will review subrecipient audit reports at least once a year, rather than only when processing amendments. • How compliance and performance will be measured and documented for future audit, management and performance review: All required subaward documents, including subrecipient letters of certification, will be uploaded and maintained in a centralized funding database. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: The Associate Director of PreAward is responsible for remediation of this finding. 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
FAC accepted this audit on May 29, 2024 — management decision was due November 29, 2024.
At the University of Nevada, Reno (“UNR”), University of Nevada, Las Vegas (“UNLV”), and System Computing Services (“SCS”), we noted deficiencies in security administration related to the information technology general controls (“ITGCs”) in the PeopleSoft application. Specifically, controls were lacking around restriction of elevated access, user access reviews, termination of access and segregation of duties as it relates to the PeopleSoft application over the student financial assistance program. Context: During our testing of the ITGCs in the PeopleSoft application, we noted the following segregation of duties issues: (1) At UNLV, UNR and SCS, several users have both PeopleSoft Administrator rights within the Production and Development Environment. (2) At UNLV, four users have both Production and Development environment access which allows them to modify PS objects and perform change management duties. (3) At UNR, three users have both Production and Development environment access which allows them to modify PS objects and perform change management duties. (4) At SCS, UNR and UNLV, no appropriate level of review of the activities performed by users with access to modify production during the audit period. (5) At SCS, four users have both Production and Development environment access which allows them to modify PS objects and perform change management duties. (6) At SCS, UNR and UNLV, activity performed by users with segregation of duties conflicts (see 1-3, 5 above), are not formally reviewed on a periodic basis for appropriateness. The deficiencies in security administration controls could impact compliance requirements related to determining eligibility, disbursements, return of Title IV funds and verification. Questioned Costs: $0 Effect: 1. Security Administration (#4) and Change Management (#1-3, #5 & #6)-Student data within the PeopleSoft application may be affected by users having conflicting roles or access levels, and accountability may not be established. Student data may be affected by unauthorized, inappropriate, or untested changes to the system. This could impact eligibility, disbursements, return of Title IV funds and verification. Cause: The issues identified are part of the lack of effective ITGCs in the PeopleSoft application for the majority of the fiscal year. Recommendation: 1. Security Administration (#4) - Management should perform a formally documented periodic review of user activities. 2. Change Management(#1-3, #5-6) - Management should segregate duties and remove users with access to both the Development and Production environments (limiting them to be able to access just one environment) or implement a formal review process over the activities performed by those responsible for program maintenance on a periodic basis. As of 4/28/2023, management has reported to us findings #1-3, #5 were remediated as the segregation of duties (“SOD”) access was revoked. However, due to the timing of remediation, management should perform a formally documented review of users activities for the period of 7/1/2022-4/7/2023. Views of Responsible Officials (unaudited): Management concurs. In addition, as of 4/28/2023, management has taken action to remove access which was causing SOD conflicts to address findings #1-3, #5.
Show full finding ▾Hide full finding ▴Internal Control over Compliance (Repeat Finding 2022-003, 2021-003, 2020-001, 2019-002, 2018-003, 2017-002, 2015-002, 2014-008) Federal Programs Departments of Education and Department of Health and Human Services Student Financial Assistance Cluster (Various Assistance Listing numbers) Award year ended June 30, 2023 Department of Education Education Stabilization Fund (COVID-19) (Assistance Listing number 84.425E) Award year ended June 30, 2023 Criteria: 2 CFR 200.303(a) requires that non-Federal entities receiving Federal awards establish and maintain effective internal control over the Federal award to provide reasonable assurance that they are managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: At the University of Nevada, Reno (“UNR”), University of Nevada, Las Vegas (“UNLV”), and System Computing Services (“SCS”), we noted deficiencies in security administration related to the information technology general controls (“ITGCs”) in the PeopleSoft application. Specifically, controls were lacking around restriction of elevated access, user access reviews, termination of access and segregation of duties as it relates to the PeopleSoft application over the student financial assistance program. Context: During our testing of the ITGCs in the PeopleSoft application, we noted the following segregation of duties issues: (1) At UNLV, UNR and SCS, several users have both PeopleSoft Administrator rights within the Production and Development Environment. (2) At UNLV, four users have both Production and Development environment access which allows them to modify PS objects and perform change management duties. (3) At UNR, three users have both Production and Development environment access which allows them to modify PS objects and perform change management duties. (4) At SCS, UNR and UNLV, no appropriate level of review of the activities performed by users with access to modify production during the audit period. (5) At SCS, four users have both Production and Development environment access which allows them to modify PS objects and perform change management duties. (6) At SCS, UNR and UNLV, activity performed by users with segregation of duties conflicts (see 1-3, 5 above), are not formally reviewed on a periodic basis for appropriateness. The deficiencies in security administration controls could impact compliance requirements related to determining eligibility, disbursements, return of Title IV funds and verification. Questioned Costs: $0 Effect: 1. Security Administration (#4) and Change Management (#1-3, #5 & #6)-Student data within the PeopleSoft application may be affected by users having conflicting roles or access levels, and accountability may not be established. Student data may be affected by unauthorized, inappropriate, or untested changes to the system. This could impact eligibility, disbursements, return of Title IV funds and verification. Cause: The issues identified are part of the lack of effective ITGCs in the PeopleSoft application for the majority of the fiscal year. Recommendation: 1. Security Administration (#4) - Management should perform a formally documented periodic review of user activities. 2. Change Management(#1-3, #5-6) - Management should segregate duties and remove users with access to both the Development and Production environments (limiting them to be able to access just one environment) or implement a formal review process over the activities performed by those responsible for program maintenance on a periodic basis. As of 4/28/2023, management has reported to us findings #1-3, #5 were remediated as the segregation of duties (“SOD”) access was revoked. However, due to the timing of remediation, management should perform a formally documented review of users activities for the period of 7/1/2022-4/7/2023. Views of Responsible Officials (unaudited): Management concurs. In addition, as of 4/28/2023, management has taken action to remove access which was causing SOD conflicts to address findings #1-3, #5.
Internal Control over Compliance (Repeat Finding 2022-001, 2021-003, 2020-001, 2019-002, 2018-003, 2017-002, 2015-002, 2014-008) 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 Responses UNR agrees with the findings • 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 technical staff can only have the PeopleSoft Administrator (PSA) role in either development or production, but not both. There is an approval process in place to ensure that access is removed from either development or production when a PSA needs to be moved across to the other environment. This process became effective March 1, 2023. There is a quarterly security review of the PeopleSoft Administrator role in PeopleSoft. The first quarterly review was performed in FY16 Q1 and has been performed each quarter since. The reviews are documented and approved. There is a quarterly security review of the PeopleSoft Administrator activities in PeopleSoft. The first quarterly review was performed in FY22 Q4 and has been performed each quarter since. The reviews are documented and approved. There is a quarterly security review of the PeopleSoft Oracle database and user access. The first quarterly review was performed in FY20 Q2 and has been performed each quarter since. The reviews are documented and approved. • How compliance and performance will be measured and documented for future audit, management and performance review. Compliance and performance can be measured by the documented quarterly reviews. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The PeopleSoft Manager will be responsible for ensuring the corrective actions plans are implemented and followed. The Vice President of Information Technology will be accountable for the department’s compliance. UNLV 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; UNLV understands the importance of adequate segregation of duties within the PeopleSoft environments and applications. The PeopleSoft Administrator (PSA) position that is the subject of the finding is responsible for the installation, configuration, upgrades, and troubleshooting of all the application environments. The PeopleSoft Administrators are not programmers/developers, and their access to the production environments is periodically required to perform the needed activities required to provide timely support of the application within the scope of their job duties. UNLV has implemented the following controls to mitigate the risks associated with the elevated access required for the administrators to perform their required support activities. 1. UNLV has removed all persistent assignment of the PeopleSoft Administrator role from all PSAs in all environments. 2. The PeopleSoft Administrator role is temporarily assigned only when elevated actions are required. All assignments are of a limited duration and include a justification detailing the need and actions to be performed. All assignments trigger the follow actions: a. An immediate notification to the Director of Business Continuity & Resiliency and the Interim Senior Associate Vice Provost for Digital Strategy and Transformation. b. Removal is automatic but can be initiated by PSA if work is completed sooner than expected. c. All details around the assignment are captured in a tracking table. d. A review of all assignments and activities is performed monthly. 3. UNLV will continue to review access, activities, and assigned privileges monthly for the PeopleSoft Administrators. 4. UNLV will continue researching and implementing other control methods that may strengthen the segregation of duties or the monitoring capabilities that are available. • How compliance and performance will be measured and documented for future audit, management and performance review. The PeopleSoft Administrator role is no longer persistently assigned to the PSA position. It is only assigned upon request with the knowledge and approval of approving authorities. UNLV performs monthly reviews of the access and activities to determine if the PeopleSoft Administrators' activities align with the necessary support. Additionally, UNLV will continue to research other control methods that will address the segregation of duties while providing appropriate service and support. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Director of Business Continuity & Resiliency will be responsible for performing the activity reviews and access needs of the PeopleSoft Administrators. The Director will complete the reviews and is also accountable if repeat or similar observations are noted. The Chief Information Security Officer will verify that reviews are conducted on a monthly basis per audit practices. SCS agrees with the findings • 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; In addition to the compensating controls (a) to (d), that have been operating since prior to FY23 the segregation of PeopleSoft Administrators (PSA) is enforced through a “locked account” process. Only two employees have PSA access in both the Production and Development environment. Each employee can only have access to the Production or Development environment at any one time, i.e., the PSA account in the other environment remains locked. A JIRA ticket must be opened for an account to be unlocked. The request is approved by management and the account is unlocked by a member of the IT Security Team. The controls listed below should also mitigate the segregation of duties risk and support a review of “user activities” in the absence of an appropriate user activities audit log function. (a) STAT for PeopleSoft – Code control and internal modification tracking provides visibility over PSA activities that are processed via this tool. These object changes are reviewed and approved by the Director of Information and Application Services. (b) JIRA ‐ Change control management and project tracking software. Change requests and projects related to the PeopleSoft shared instance are tracked and approved. This would include user access modifications and system updates for example. (c) Security e‐mail alerts – The SCS security team are alerted via automated e‐mails when key events are triggered. For example, an elevated role is assigned to a user. (d) User Access Reviews – On an annual basis an independent user access review is performed incorporating SCS/SA privileged users and all shared instance security coordinators. • How compliance and performance will be measured and documented for future audit, management and performance review. The PeopleSoft Administrators will have persistent unlocked access to either the Production or Development environments only. Their corresponding account in the other environment will remain locked. In the event that access is needed to the locked environment, a ticket will be created requesting access which will document the rationale and approvals. In addition, PSA activities are monitored via the change control process through STAT for PeopleSoft. Object changes within the Production environment for example, are approved along with the associated workflows. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The SCS Director of Information and Application Services, and SCS Security Group are responsible for locking/unlocking PSA accounts. The SCS Security Group monitor PeopleSoft e-mail alerts. The IT Audit Manager is performing annual SCS/SA privileged user access reviews.
2022-003
During our testing at CSN, we identified the following instance: the Institution did not complete the return of Title IV funds as calculated within the 45-day requirement as noted in the Federal Regulations. Context: For two out of sixty students tested at CSN, the funds to be returned were not returned within the 45-day timeframe. Questioned Costs: CSN - $0 Effect: CSN was not compliant with the timeliness rules for two students in our sample. Cause: Lack of oversight. Recommendation: We recommend that CSN adhere to its established controls to ensure the timely return of funds. Views of Responsible Officials (unaudited): Management concurs.
Show full finding ▾Hide full finding ▴Special Tests and Provisions: Return of Title IV funds for withdrawn students (Repeat finding 2021-004, 2020-002, 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011) Federal Programs: Department of Education Student Financial Assistance Cluster (Various Assistance Listing numbers) Award year ended June 30, 2023 Criteria: Pursuant to the 34 CFR 668.22(j)(2), an institution is required to determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew to allow for the timely calculation and return of Title IV funds as required. Pursuant to the 34 CFR 668.22(e), an institution is required to calculate the amount of Title IV assistance earned by the student once the institution has determined the withdrawal date in accordance with the 34 CFR 668.22(j), and pursuant to the 34 CFR 668.22(g), an institution is required to calculate and return unearned aid in the order as required: the lesser of the total amount of unearned Title IV assistance to be returned as calculated under 34 CFR 668.22(e)(4); or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student, as described in 34 CFR 668.22(e)(3). Pursuant to the 34 CFR 690.83(b)(2) an institution shall submit, in accordance with deadline dates established by the U.S. Department of Education (Secretary), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Pursuant to 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as, but no later than 45 days, after the date of the institution's determination that the student withdrew. 34 CFR 668.22(d) requires that an institution does not have to treat a leave of absence as a withdrawal if it is an approved leave of absence. A leave of absence is an approved leave of absence if - (i) The institution has a formal policy regarding leaves of absence; (ii) The student followed the institution's policy in requesting the leave of absence; (iii) The institution determines that there is a reasonable expectation that the student will return to the school; (iv) The institution approved the student's request in accordance with the institution's policy; (v) The leave of absence does not involve additional charges by the institution; (vi) The number of days in the approved leave of absence, when added to the number of days in all other approved leaves of absence, does not exceed 180 days in any 12-month period; (vii) Except for a clock hour or nonterm credit hour program, upon the student's return from the leave of absence, the student is permitted to complete the coursework he or she began prior to the leave of absence; and (viii) If the student is a title IV, HEA program loan recipient, the institution explains to the student, prior to granting the leave of absence, the effects that the student's failure to return from a leave of absence may have on the student's loan repayment terms, including the exhaustion of some or all of the student's grace period. Condition: During our testing at CSN, we identified the following instance: the Institution did not complete the return of Title IV funds as calculated within the 45-day requirement as noted in the Federal Regulations. Context: For two out of sixty students tested at CSN, the funds to be returned were not returned within the 45-day timeframe. Questioned Costs: CSN - $0 Effect: CSN was not compliant with the timeliness rules for two students in our sample. Cause: Lack of oversight. Recommendation: We recommend that CSN adhere to its established controls to ensure the timely return of funds. Views of Responsible Officials (unaudited): Management concurs.
Special Tests and Provisions: Return of Title IV funds for withdrawn students (Repeat finding 2021-004, 2020-002, 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011) 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 Responses CSN agrees with the findings. • 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; CSN has started to select additional team members to cross train with seasoned R2T4 team members on the processing of R2T4 files. This will ensure that files are processed in a timely manner and meet compliance requirements. Additionally, training opportunities will be assessed and offered to the team members who are processing R2T4 records on an ongoing basis. Additionally, CSN is currently assessing a potential 3rd party vendor to assist with the processing of R2T4s as needed on an ongoing basis. • How compliance and performance will be measured and documented for future audit, management and performance review. Cross training and workshop opportunities will be provided to ensure knowledge and compliance for the R2T4 team and any staff member assisting with processing of R2T4 records. Queries will be utilized to track R2T4 files to ensure timely processing. • Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Assistant Director of Financial Aid will be responsible and may be held accountable.
2022-004
FAC accepted this audit on May 3, 2023 — management decision was due November 3, 2023.
STUDENT FINANCIAL ASSISTANCE CLUSTER FINDINGSFINDING 2022-003 - Internal Control over Compliance (Repeat Finding 2021-003, 2020-001, 2019-002, 2018-003, 2017-002,2015-002, 2014-008)Federal ProgramsDepartments of Education and Department of Health and Human ServicesStudent Financial Assistance Cluster (Various Assistance Listing numbers)Award year ended June 30, 2022Department of EducationEducation Stabilization Fund (COVID-19) (Assistance Listing number 84.425E)Award year ended June 30, 2022Criteria2 CFR 200.303(a) requires that non-Federal entities receiving Federal awards establish and maintain effective internalcontrol over the Federal award to provide reasonable assurance that they are managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federal award.ConditionAt the University of Nevada, Reno (?UNR?), University of Nevada, Las Vegas (?UNLV?), and System ComputingServices (?SCS?), we noted deficiencies in security administration related to the information technology general controls(?ITGCs?) in the PeopleSoft application. Specifically, controls were lacking around restriction of elevated access, useraccess reviews, termination of access and segregation of duties as it relates to the PeopleSoft application over thestudent financial assistance program.ContextDuring our testing of the ITGCs in the PeopleSoft application, we noted the following segregation of duties issues: (1)At UNLV, UNR and SCS, several users have both PeopleSoft Administrator rights within the Production and DevelopmentEnvironment. (2) At UNLV, four users have both Production and Development environment access which allows them tomodify PS objects and perform change management duties. (3) At UNR, three users have both Production and Developmentenvironment access which allows them to modify PS objects and perform change management duties. (4) At SCS, UNR andUNLV, no appropriate level of review of the activities performed by users with access to modify production during the auditperiod. (5) At SCS, four users have both Production and Development environment access which allows them to modify PSobjects and perform change management duties. (6) At SCS, UNR and UNLV, activity performed by users with segregationof duties conflicts (see 1-3, 5 above), are not formally reviewed on a periodic basis for appropriateness.The deficiencies in security administration controls could impact compliance requirements related to determiningeligibility, disbursements, return of Title IV funds and verification.Questioned Costs$0Effect1. Security Administration (#4) and Change Management (#1-3, #5 & #6)-Student data within the PeopleSoft applicationmay be affected by users having conflicting roles or access levels, and accountability may not be established. Studentdata may be affected by unauthorized, inappropriate, or untested changes to the system. This could impact eligibility,disbursements, return of Title IV funds and verification.CauseThe issues identified are part of the lack of effective ITGCs in the PeopleSoft application. Recommendation1. Security Administration (#4) - Management should perform a formally documented periodic review of user activities.2. Change Management(#1-3, #5-6 & #7) - Management should segregate duties and remove users with access toboth the Development and Production environments (limiting them to be able to access just one environment) orimplement a formal review process over the activities performed by those responsible for program maintenance on aperiodic basis.Views of Responsible Officials (unaudited)Management concurs.
Show full finding ▾Hide full finding ▴STUDENT FINANCIAL ASSISTANCE CLUSTER FINDINGSFINDING 2022-003 - Internal Control over Compliance (Repeat Finding 2021-003, 2020-001, 2019-002, 2018-003, 2017-002,2015-002, 2014-008)Federal ProgramsDepartments of Education and Department of Health and Human ServicesStudent Financial Assistance Cluster (Various Assistance Listing numbers)Award year ended June 30, 2022Department of EducationEducation Stabilization Fund (COVID-19) (Assistance Listing number 84.425E)Award year ended June 30, 2022Criteria2 CFR 200.303(a) requires that non-Federal entities receiving Federal awards establish and maintain effective internalcontrol over the Federal award to provide reasonable assurance that they are managing the Federal award incompliance with Federal statutes, regulations, and the terms and conditions of the Federal award.ConditionAt the University of Nevada, Reno (?UNR?), University of Nevada, Las Vegas (?UNLV?), and System ComputingServices (?SCS?), we noted deficiencies in security administration related to the information technology general controls(?ITGCs?) in the PeopleSoft application. Specifically, controls were lacking around restriction of elevated access, useraccess reviews, termination of access and segregation of duties as it relates to the PeopleSoft application over thestudent financial assistance program.ContextDuring our testing of the ITGCs in the PeopleSoft application, we noted the following segregation of duties issues: (1)At UNLV, UNR and SCS, several users have both PeopleSoft Administrator rights within the Production and DevelopmentEnvironment. (2) At UNLV, four users have both Production and Development environment access which allows them tomodify PS objects and perform change management duties. (3) At UNR, three users have both Production and Developmentenvironment access which allows them to modify PS objects and perform change management duties. (4) At SCS, UNR andUNLV, no appropriate level of review of the activities performed by users with access to modify production during the auditperiod. (5) At SCS, four users have both Production and Development environment access which allows them to modify PSobjects and perform change management duties. (6) At SCS, UNR and UNLV, activity performed by users with segregationof duties conflicts (see 1-3, 5 above), are not formally reviewed on a periodic basis for appropriateness.The deficiencies in security administration controls could impact compliance requirements related to determiningeligibility, disbursements, return of Title IV funds and verification.Questioned Costs$0Effect1. Security Administration (#4) and Change Management (#1-3, #5 & #6)-Student data within the PeopleSoft applicationmay be affected by users having conflicting roles or access levels, and accountability may not be established. Studentdata may be affected by unauthorized, inappropriate, or untested changes to the system. This could impact eligibility,disbursements, return of Title IV funds and verification.CauseThe issues identified are part of the lack of effective ITGCs in the PeopleSoft application. Recommendation1. Security Administration (#4) - Management should perform a formally documented periodic review of user activities.2. Change Management(#1-3, #5-6 & #7) - Management should segregate duties and remove users with access toboth the Development and Production environments (limiting them to be able to access just one environment) orimplement a formal review process over the activities performed by those responsible for program maintenance on aperiodic basis.Views of Responsible Officials (unaudited)Management concurs.
STUDENT FINANCIAL ASSISTANCE CLUSTER FINDINGSFINDING 2022-003 - Internal Control over Compliance (Repeat Finding 2021-003, 2020-001, 2019-002, 2018-003, 2017-002, 2015-002, 2014-008)ResponsesNSHE Overall response/context ?NSHE increased its dialogue amongst the three instances of the student information system throughout fiscalyear 2022. The results of this robust dialogue led to additional controls to reduce related IT risks, enhancedmonitoring of activities, and targeted periodic reviews, highlighted in each instance?s response below. Theseenhanced techniques operating throughout the entire fiscal year ahead, should provide a stronger overall controlenvironment and lower associated risks.UNR ?? Detailed corrective action taken, including what will be done to avoid the identified issues inthe future, and when these measures will be in place;UNR has implemented controls to address the risk associated with the PeopleSoft Administrators(PSA?s) access to the production and development environments. The controls include:1. The University will remove the PSA role for the three individuals that are identified as not havingthe appropriate segregation of duties. The PSA role is still required of the University and will onlybe granted on a temporary basis when necessary and this access will be, documented, monitored,and deactivated upon completion of the required tasks.a) Approvals ? A PSA role is granted for task specific business needs and when the individualssecurity level does not permit the action to be performed. When justified, the PSA role isgranted by a security administrator.b) Documented ? When the PSA role is granted a notification is triggered to the Associate VicePresident, Planning, Budget and Analysis, the Registrar and the Director of AccountingOperations as to the role assignment and the person assigned.c) Monitored ? The activities performed are documented and monitored in a TeamDynamixticket.d) Deactivated ? The PSA system access is deactivated upon completion of the required activity.The deactivation is documented in the TeamDynamix ticketing system.2. The University will implement a quarterly User Access Review that identifies the incidences ofwhen the PSA role is granted and when the PSA login occurs and compares this to Team Dynamixto establish the activity. The activity can be compared to the system for validity. This will beperformed by the Registrar. 3. The University will continue to explore and research Change Control Systems as options tomonitor activities of the PSA?s.? How compliance and performance will be measured and documented for future audit,management and performance review.The PSA role will not be established for continuous periods of time. When the PSA role is temporarilygranted it is documented and tracked in Team Dynamix. This provides an audit trail of role access,timeframes of logins, and activities.? Who will be responsible and may be held accountable in the future if repeat or similarobservations are noted.The Associate Vice President, Planning, Budget and Analysis will monitor the compliance with thecorrective action plans and will implement new processes as needed to meet the needs of mitigatingthis risk and the system updates and changes.UNLV ?UNLV agrees with this finding.? Detailed corrective action taken, including what will be done to avoid the identified issues inthe future, and when these measures will be in place;UNLV understands the importance of adequate segregation of duties within the PeopleSoftenvironments and applications. The PeopleSoft Administrator (PSA) position that is the subject ofthe finding is responsible for the installation, configuration, upgrades, and troubleshooting of all theapplication environments. The PeopleSoft Administrators are not programmers/developers, andtheir access to the production environments is periodically required to perform the needed activitiesrequired to provide timely support of the application within the scope of their job duties.UNLV has implemented the following controls to mitigate the risks associated with the elevatedaccess required for the administrators to perform their required support activities.a. UNLV will remove the PeopleSoft Administrator role from all PSAs in productionenvironments.b. The PeopleSoft Administrator role will be assigned temporarily when elevated actions arerequired. The assignment will have the following requirements:i. Be limited in duration.ii. Document a justification detailing the need and actions to be performed.iii. Generate notification to the Director of Enterprise Applications.iv. Automatically be removed.v. It is reviewed as part of normal audit activities. c. UNLV will increase their reviews of access, activities, and assigned privileges to monthly forthe PeopleSoft Administrators.d. UNLV will continue researching and implementing other control methods to address thesegregation of duties while providing appropriate service and support.? How compliance and performance will be measured and documented for future audit,management and performance review.The PeopleSoft Administrator role will no longer be a persistent assignment to the PSA position.UNLV will perform monthly reviews of the access and activities to determine if the PeopleSoftAdministrators' current levels require further refinement. Additionally, UNLV will continue toresearch other control methods that will address the segregation of duties while providingappropriate service and support.? Who will be responsible and may be held accountable in the future if repeat or similarobservations are noted.The Director of Enterprise Applications will be responsible for reviewing the access needs of thePeopleSoft Administrators. The Director will complete the reviews and is also accountable if repeat orsimilar observations are noted. The Chief Information Security Officer will verify the reviews are permonthly audit practices.SCS ?? Detailed corrective action taken, including what will be done to avoid the identified issues inthe future, and when these measures will be in place;PeopleSoft Administrator (PSA) access to the Production and Development environments arereviewed on an ongoing basis. Due to the need to develop and perform program changes for all fiveshared-instance Institutions on a frequent basis it was determined that PSA access cannot be reducedany further. However, to address the segregation of duties risk the following compensating controlsare in place:(a) STAT for PeopleSoft ? Code control and internal modification tracking provides visibility over PSAactivities that are processed via this tool. These object changes are reviewed and approved by theDirector of Information and Application Services.(b) JIRA - Change control management and project tracking software. Change requests and projectsrelated to the PeopleSoft shared instance are tracked and approved. This would include user accessmodifications and system updates for example.(c) Security e-mail alerts ? The SCS security team are alerted via automated e-mails when user access(to include PSA roles) is changed.(d) User Access Reviews ? On an annual basis a user access review is performed incorporatingSCS/SA privileged users and all shared instance security coordinators SCS will implement the following additional control from FY22/23 going forward:(e) Splunk reporting and monitoring ? Reporting and trigger events developed incorporating PSAactivity ?anomalies?. For example, PSA after-hour logins reviewed and matched to plannedupdates/activities.(f) Periodic management reviews ? A formal review incorporating, and documenting PSA andassociated exception activities will take place. Where appropriate this will include approvals anddocumented rationale.SCS will continue to explore additional solutions to minimize the segregation of duties risk, especiallyas it relates to the monitoring of PSA activities.? How compliance and performance will be measured and documented for future audit,management and performance review.The periodic management review where appropriate will include documentation and approvals tosupport PSA activities that do not meet established criteria. This review will also document anyfollow-ups required as it relates to similar controls. For example, security e-mail alerts.? Who will be responsible and may be held accountable in the future if repeat or similarobservations are noted.SCS Director of Information and Application Services, SCS Security Group.
2021-003
FINDING 2022-004 - Special Tests and Provisions: Return of Title IV funds for withdrawn students(Repeat finding 2021-004, 2020-002, 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011)Federal ProgramsDepartment of EducationStudent Financial Assistance Cluster (Various Assistance Listing numbers)Award year ended June 30, 2022CriteriaPursuant to the 34 CFR 668.22(j)(2), an institution is required to determine the withdrawal date for a student who withdrawswithout providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period orperiod of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the studentwithdrew to allow for the timely calculation and return of Title IV funds as required. Pursuant to the 34 CFR 668.22(e), aninstitution is required to calculate the amount of Title IV assistance earned by the student once the institution has determinedthe withdrawal date in accordance with the 34 CFR 668.22(j), and pursuant to the 34 CFR 668.22(g), an institution is requiredto calculate and return unearned aid in the order as required: the lesser of the total amount of unearned Title IV assistance tobe returned as calculated under 34 CFR 668.22(e)(4); or an amount equal to the total institutional charges incurred by thestudent for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that hasnot been earned by the student, as described in 34 CFR 668.22(e)(3). Pursuant to the 34 CFR 690.83(b)(2) an institution shallsubmit, in accordance with deadline dates established by the U.S. Department of Education (Secretary), through publication inthe Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretaryfinds necessary to ensure that the reports are correct.Pursuant to 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as,but no later than 45 days, after the date of the institution's determination that the student withdrew.34 CFR 668.22(d) requires that an institution does not have to treat a leave of absence as a withdrawal if it is an approvedleave of absence. A leave of absence is an approved leave of absence if - (i) The institution has a formal policy regarding leavesof absence; (ii) The student followed the institution's policy in requesting the leave of absence; (iii) The institution determinesthat there is a reasonable expectation that the student will return to the school; (iv) The institution approved the student's requestin accordance with the institution's policy; (v) The leave of absence does not involve additional charges by the institution; (vi)The number of days in the approved leave of absence, when added to the number of days in all other approved leaves ofabsence, does not exceed 180 days in any 12-month period; (vii) Except for a clock hour or nonterm credit hour program, uponthe student's return from the leave of absence, the student is permitted to complete the coursework he or she began prior tothe leave of absence; and (viii) If the student is a title IV, HEA program loan recipient, the institution explains to the student,prior to granting the leave of absence, the effects that the student's failure to return from a leave of absence may have on thestudent's loan repayment terms, including the exhaustion of some or all of the student's grace period.ConditionDuring our testing at CSN, we identified the following instance: the Institution did not correctly calculate the return of Title IVfunds for a student because the Institution subtracted 7 days of spring break from the calculation which led to those 7 daysbeing reduced from the total days completed twice since the Institution?s software automatically removes those 7 days tocalculate total days completed.During our testing at UNLV, we identified the following instance: the Institution returned funds more than 45 days after two ofthe students in our sample of 60 withdrew from the Institution.ContextFor one out of sixty students tested at CSN, the Institution did not properly calculate the return of Title IV funds for a studentwhose withdrawal period included a break that lasted 7 days. For two out of sixty students tested at UNLV, the Institutionreturned funds past the 45 day deadline of when those students withdrew from the Institution. Questioned CostsCSN - $388UNLV - $0EffectAt CSN, the return of Title IV funds as calculated and applied to the individual student's account at each Institution was notreported to COD accurately. At UNLV, the return of Title IV funds was not completed in a timely manner for 2 out of 60 studentsin our sample.CauseAt CSN, funds were returned which shouldn?t have been returned due to the return of Title IV Funds being calculated incorrectly.At UNLV, funds were returned later than the 45 day deadline for 2 out of 60 students in our sample.RecommendationWe recommend that CSN enhance the process and internal controls to ensure accurate calculation and reporting to COD. Werecommend that UNLV enhance the process and internal controls to ensure that Title IV Funds are returned in a timely manner.Views of Responsible Officials (unaudited)Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2022-004 - Special Tests and Provisions: Return of Title IV funds for withdrawn students(Repeat finding 2021-004, 2020-002, 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011)Federal ProgramsDepartment of EducationStudent Financial Assistance Cluster (Various Assistance Listing numbers)Award year ended June 30, 2022CriteriaPursuant to the 34 CFR 668.22(j)(2), an institution is required to determine the withdrawal date for a student who withdrawswithout providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period orperiod of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the studentwithdrew to allow for the timely calculation and return of Title IV funds as required. Pursuant to the 34 CFR 668.22(e), aninstitution is required to calculate the amount of Title IV assistance earned by the student once the institution has determinedthe withdrawal date in accordance with the 34 CFR 668.22(j), and pursuant to the 34 CFR 668.22(g), an institution is requiredto calculate and return unearned aid in the order as required: the lesser of the total amount of unearned Title IV assistance tobe returned as calculated under 34 CFR 668.22(e)(4); or an amount equal to the total institutional charges incurred by thestudent for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that hasnot been earned by the student, as described in 34 CFR 668.22(e)(3). Pursuant to the 34 CFR 690.83(b)(2) an institution shallsubmit, in accordance with deadline dates established by the U.S. Department of Education (Secretary), through publication inthe Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretaryfinds necessary to ensure that the reports are correct.Pursuant to 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon as,but no later than 45 days, after the date of the institution's determination that the student withdrew.34 CFR 668.22(d) requires that an institution does not have to treat a leave of absence as a withdrawal if it is an approvedleave of absence. A leave of absence is an approved leave of absence if - (i) The institution has a formal policy regarding leavesof absence; (ii) The student followed the institution's policy in requesting the leave of absence; (iii) The institution determinesthat there is a reasonable expectation that the student will return to the school; (iv) The institution approved the student's requestin accordance with the institution's policy; (v) The leave of absence does not involve additional charges by the institution; (vi)The number of days in the approved leave of absence, when added to the number of days in all other approved leaves ofabsence, does not exceed 180 days in any 12-month period; (vii) Except for a clock hour or nonterm credit hour program, uponthe student's return from the leave of absence, the student is permitted to complete the coursework he or she began prior tothe leave of absence; and (viii) If the student is a title IV, HEA program loan recipient, the institution explains to the student,prior to granting the leave of absence, the effects that the student's failure to return from a leave of absence may have on thestudent's loan repayment terms, including the exhaustion of some or all of the student's grace period.ConditionDuring our testing at CSN, we identified the following instance: the Institution did not correctly calculate the return of Title IVfunds for a student because the Institution subtracted 7 days of spring break from the calculation which led to those 7 daysbeing reduced from the total days completed twice since the Institution?s software automatically removes those 7 days tocalculate total days completed.During our testing at UNLV, we identified the following instance: the Institution returned funds more than 45 days after two ofthe students in our sample of 60 withdrew from the Institution.ContextFor one out of sixty students tested at CSN, the Institution did not properly calculate the return of Title IV funds for a studentwhose withdrawal period included a break that lasted 7 days. For two out of sixty students tested at UNLV, the Institutionreturned funds past the 45 day deadline of when those students withdrew from the Institution. Questioned CostsCSN - $388UNLV - $0EffectAt CSN, the return of Title IV funds as calculated and applied to the individual student's account at each Institution was notreported to COD accurately. At UNLV, the return of Title IV funds was not completed in a timely manner for 2 out of 60 studentsin our sample.CauseAt CSN, funds were returned which shouldn?t have been returned due to the return of Title IV Funds being calculated incorrectly.At UNLV, funds were returned later than the 45 day deadline for 2 out of 60 students in our sample.RecommendationWe recommend that CSN enhance the process and internal controls to ensure accurate calculation and reporting to COD. Werecommend that UNLV enhance the process and internal controls to ensure that Title IV Funds are returned in a timely manner.Views of Responsible Officials (unaudited)Management concurs.
FINDING 2022-004 - Special Tests and Provisions: Return of Title IV funds for withdrawn students(Repeat finding 2021-004, 2020-002, 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011)ResponsesCSN?? Detailed corrective action taken, including what will be done to avoid the identified issues inthe future, and when these measures will be in place.All student accounts needing an R2T4 that require a date adjustment due to a gap between the lastdate of attendance for one course and the start of a new modular course will be reviewed by a secondindividual on the R2T4 processing team. This will ensure that the institution counts the correctnumber of complete days for the calculation when there is a gap in enrollment and a schedule breakof five days or more. These measures will be in place beginning October 15, 2022. Due to the error,the student will be made whole using institutional funds.? How compliance and performance will be measured and documented for future audit,management, and performance review.CSN will notate student accounts that must be reviewed as processors come across them. Who will be responsible and may be held accountable in the future if repeat or similarobservations are noted.The Assistant Director of Financial Aid will be responsible and may be held accountable if repeat orsimilar observations are noted.UNLV?UNLV agrees with this finding.? Detailed corrective action taken, including what will be done to avoid the identified issues inthe future, and when these measures will be in place:For context 1 (summer 2021), the student withdrawal occurred in FY 2021, with funds returned inAugust. This coincides with our 2020-2021 audit review, at which time many of the controlsdescribed in our response to findings for that year were in their early stages. Since summer 2021none of the identified issues that led to late fund returns have recurred.For context 2 (spring 2022), funds were returned one day late due to a failed transmission to theCommon Origination and Disbursement (COD) system. Normally when transmissions occur, anyrejected records are reviewed by the following day, in part to ensure that returns of funds are timely.In this particular instance, the file failed entirely and was never transmitted to COD at all, andtherefore no record was received of a file reject. Fortunately our own internal reconciliation controlsidentified the issue before even more time had passed.We regularly review records of when fund returns are processed in PeopleSoft to ensure reporting toCOD occurs within 45 days. In addition to our record of the PeopleSoft return date, we will nowtrack a second date to mark when the return record is accepted and reflected in COD. Thiscorrective action has been implemented as of October 10, 2022, and a review of fall 2022 R2T4returns to date indicates that all returns have been made within the 45-day timeframe.? How compliance and performance will be measured and documented for future audit,management and performance review:Steps taken in prior years, including expanded training around R2T4, the addition of a staff memberto support the R2T4 process, and increasing internal controls, have been successful in remediatingthe issues that were previously identified. To control for the file transmission issue, the correctiveplan will be monitored by both the Assistant Director for Financial Aid Processing and the ExecutiveDirector of Financial Aid & Scholarships on a weekly basis. Notes from these reviews will berecorded for future audits. Who will be responsible and may be held accountable in the future if repeat or similarobservations are noted:The Assistant Vice President for Admissions & Financial Aid and the Executive Director forFinancial Aid & Scholarships will be responsible for ensuring ongoing compliance.
2021-004
FAC accepted this audit on May 16, 2022 — management decision was due November 16, 2022.
FINDING 2021-003 - Internal Control over Compliance (Repeat Finding 2020-001, 2019-002, 2018-003, 2017-002, 2015-002, 2014-008)Federal ProgramsDepartments of Education and Department of Health and Human ServicesStudent Financial Assistance Cluster (Various Assistance Listing numbers)Award year ended June 30, 2021Department of EducationEducation Stabilization Fund (COVID-19) (Assistance Listing number 84.425E)Award year ended June 30, 2021Criteria2 CFR 200.303(a) requires that non-Federal entities receiving Federal awards establish and maintain effective internal control over the Federal award to provide reasonable assurance that they are managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.ConditionAt the University of Nevada, Reno (?UNR?), University of Nevada, Las Vegas (?UNLV?), and System Computing Services (?SCS?), we noted deficiencies in security administration related to the information technology general controls (?ITGCs?) in the PeopleSoft application. Specifically, controls were lacking around restriction of elevated access, user access reviews, termination of access and segregation of duties as it relates to the PeopleSoft application over the student financial assistance program.ContextDuring our testing of the ITGCs in the PeopleSoft application, we noted the following segregation of duties issues: (1) At UNLV and SCS, several users have both PeopleSoft Administrator rights within the Production and Development environment; (2) At UNLV, five users have both PeopleSoft PeopleTool administrator rights within the Production and Development environment which allows them to modify PS objects and perform change management duties; (3) At UNR, four users have both PeopleSoft Administrator rights within the Production and Development environment; (4) At SCS, no user access reviews were performed during the audit period for the PeopleSoft application or Oracle Database (5) At SCS, two users have both PeopleSoft PeopleTool administrator rights within the Production and Development environment which allows them to modify PS objects and perform change management duties. (6) At SCS, UNR and UNLV, activity performed by users with SOD conflicts (see 1-3, 5 above), are not formally reviewed on a periodic basis for appropriateness.The deficiencies in security administration controls could impact compliance requirements related to determining eligibility, disbursements, return of Title IV funds and verification.Questioned Costs$0Effect1. Security Administration (#4) and Change Management (#1-3, #5 & #6)-Student data within the PeopleSoft application may be affected by users having conflicting roles or access levels, and accountability may not be established. Student data may be affected by unauthorized, inappropriate, or untested changes to the system. This could impact eligibility, disbursements, return of Title IV funds and verification.CauseThe issues identified are part of the lack of effective ITGCs in the PeopleSoft application.Recommendation1. Security Administration (#4)-Management should perform a formally documented periodic review of user access.2.Change Management(#1-3, #5-6 & #7)-Management should segregate duties and remove users with access to both the Development and Production environments (limiting them to be able to access just one environment) or implement a formal review process over the activities performed by those responsible for program maintenance on a periodic basis.Views of Responsible Officials (unaudited)Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2021-003 - Internal Control over Compliance (Repeat Finding 2020-001, 2019-002, 2018-003, 2017-002, 2015-002, 2014-008)Federal ProgramsDepartments of Education and Department of Health and Human ServicesStudent Financial Assistance Cluster (Various Assistance Listing numbers)Award year ended June 30, 2021Department of EducationEducation Stabilization Fund (COVID-19) (Assistance Listing number 84.425E)Award year ended June 30, 2021Criteria2 CFR 200.303(a) requires that non-Federal entities receiving Federal awards establish and maintain effective internal control over the Federal award to provide reasonable assurance that they are managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award.ConditionAt the University of Nevada, Reno (?UNR?), University of Nevada, Las Vegas (?UNLV?), and System Computing Services (?SCS?), we noted deficiencies in security administration related to the information technology general controls (?ITGCs?) in the PeopleSoft application. Specifically, controls were lacking around restriction of elevated access, user access reviews, termination of access and segregation of duties as it relates to the PeopleSoft application over the student financial assistance program.ContextDuring our testing of the ITGCs in the PeopleSoft application, we noted the following segregation of duties issues: (1) At UNLV and SCS, several users have both PeopleSoft Administrator rights within the Production and Development environment; (2) At UNLV, five users have both PeopleSoft PeopleTool administrator rights within the Production and Development environment which allows them to modify PS objects and perform change management duties; (3) At UNR, four users have both PeopleSoft Administrator rights within the Production and Development environment; (4) At SCS, no user access reviews were performed during the audit period for the PeopleSoft application or Oracle Database (5) At SCS, two users have both PeopleSoft PeopleTool administrator rights within the Production and Development environment which allows them to modify PS objects and perform change management duties. (6) At SCS, UNR and UNLV, activity performed by users with SOD conflicts (see 1-3, 5 above), are not formally reviewed on a periodic basis for appropriateness.The deficiencies in security administration controls could impact compliance requirements related to determining eligibility, disbursements, return of Title IV funds and verification.Questioned Costs$0Effect1. Security Administration (#4) and Change Management (#1-3, #5 & #6)-Student data within the PeopleSoft application may be affected by users having conflicting roles or access levels, and accountability may not be established. Student data may be affected by unauthorized, inappropriate, or untested changes to the system. This could impact eligibility, disbursements, return of Title IV funds and verification.CauseThe issues identified are part of the lack of effective ITGCs in the PeopleSoft application.Recommendation1. Security Administration (#4)-Management should perform a formally documented periodic review of user access.2.Change Management(#1-3, #5-6 & #7)-Management should segregate duties and remove users with access to both the Development and Production environments (limiting them to be able to access just one environment) or implement a formal review process over the activities performed by those responsible for program maintenance on a periodic basis.Views of Responsible Officials (unaudited)Management concurs.
FINDING 2021-003 - Internal Control over Compliance (Repeat Finding 2020-001, 2019-002, 2018-003, 2017-002, 2015-002, 2014-008)? Name of contact person responsible for corrective action plan:Rhett R. Vertrees, CPAAssistant Chief Financial Officer2601 Enterprise RoadReno, NV 89512-1666Phone: 775-784-3409Fax: 775-784-1127Email: rvertrees@nshe.nevada.eduResponsesUNR ?? 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; (3) Due to the limited size of the Office of Information Technology staff, the PeopleSoft Administrator role will continue to be necessary for the PeopleSoft Administrator positions in order for them to proactively monitor and take immediate actions to mitigate critical system issues such as cyber security vulnerabilities. One consultant and three staff are currently assigned the PeopleSoft Administrator role. We recognize the risks associated with the role, and the following mitigation strategies are in place to reduce and manage the risk. The Office of Information Technology PeopleSoft Manager oversees the staff and consultants that are assigned the PeopleSoft Administrator role. Changes are documented in security applications and approved by the Manager. An audit trigger also notifies the Registrar, PeopleSoft Manager, Chief Security Officer and the Chief Information Officer when the PeopleSoft Administrator role is granted to users in the production, test, quality assurance or development environments. The consultant is covered under the Master Services Agreement between NSHE and Sierra Cedar, Inc., signed on January 15, 2008, that includes Article 9 ? Data Rights and Confidentiality. The SCI Consultant?s access has since been disabled in all environments except the development environment. The monitoring controls outlined in (6) below are intended to help mitigate this segregation of duties risk, allowing for increased transparency and monitoring of administrator activities. The `STAT for PeopleSoft? tool is the change management system used to track key back-end changes to ensure that only authorized changes are made. (6) Due to the limited size of the Office of Information Technology and a requirement to remain agile and responsive to our users/students, the current allocation of administrator access to production and development is considered necessary in order to perform the required duties in the various environments. As a compensating control, a policy is being developed to require PeopleSoft Administrators use `STAT for PeopleSoft? to document in-scope back-end changes. A system generated report that documents the changes made will be generated quarterly. This will be reviewed by persons independent from the system administrators on a quarterly basis, thus providing additional transparency of activities. Additional monitoring options are also being explored to ensure that this ongoing risk can be appropriately managed.? How compliance and performance will be measured and documented for future audit, management and performance review; (3) Changes made by PeopleSoft Administrators in STAT will be captured in a system generated report and ticket details. Additionally, audit trigger notifications for the addition of the PeopleSoft Administrator (PSA) role ensures management is made aware when the PSA role is granted.(6) A review process of changes made by PeopleSoft Administrators in STAT will be developed, documented, and maintained. This includes a review of the STAT ticket details.? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted; The PeopleSoft Manager will be responsible for compliance with these requirements.UNLV ? UNLV agrees with this 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; For context 1 and 2: The positions that are the subject of the finding, the PeopleSoft and Database Administrators (PSAs and DBAs), require access to the PeopleSoft environments to provide timely support of the application within the scope of their job duties. As part of providing adequate separation of duties, UNLV recognizes the need to track the activity of the PSAs and DBAs. As a compensating control, UNLV continues to develop stronger monitoring processes designed to identify issues that could arise as a result of individuals having access to multiple PeopleSoft environments. Since 2020, UNLV has created a tool to collect logs to monitor access by individuals who have ongoing access to the environments The tool identifies all activity occurring during non-traditional work hours. An independent monitor reviews the logs and follows up to ensure any access outside normal work hours was warranted. Anomalies are investigated. This effort is an extension of the work done to significantly reduce the access of those who propagate program changes in PeopleSoft. Those individuals are granted temporary access that is limited to the time needed to make the program changes. The new tool automatically removes the temporary access once the allotted time for making program changes has ended. These new controls have been added to strengthen an environment where the individuals granting the access are different from the individuals propagating the changes. Additionally, the individual monitoring the logs for those who have elevated access does not propagate changes and cannot set up the security required to provide the access for those that do. Going forward, UNLV will continue to explore ways to restrict access and monitor access wherever possible to ensure anomalies are identified and reviewed quickly. Plans to further restrict the access of security staff so that they only have ongoing access in TST, and are only granted access in PRD when it is needed are under consideration. While these efforts continue, a new set of compensating controls will focus on monitoring the activities of those who have elevated access to the PeopleSoft environments.For context 6: UNLV understands the importance of activity review of all users, especially those with separation of duty conflicts. UNLV will research, develop, and test processes to track user activity associated with program maintenance actions. Efforts include: ? Determining which functions to test when tracking activities for both frontend and backend users. ? Checking projects as they migrate to determine if there is any change in the projects as they move through the PeopleSoft environment stack. ? How compliance and performance will be measured and documented for future audit, management and performance review. For context 1 and 2: UNLV will continue to review the access needs each Fall and Spring term to determine if the current levels of access for the PeopleSoft Administrators and Database Administrators are still required. Additionally, UNLV is considering additional control methods that will address segregation of duties while providing appropriate service and support. While a few staff continue to have access to multiple PeopleSoft environments in order to perform their responsibilities, UNLV will strengthen compensating controls as described under context 6.For context 6: UNLV will review and compare student information system activities in the context of the approved activities as documented within the existing change management process. UNLV will review the reports for elevated access outside normal business hours bi-monthly. The process will be initiated and executed by the Associate Director of Enterprise Applications who is responsible for the appropriateness of change management activities.? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted: For context 1 and 2: The Associate Director of Enterprise Applications will be responsible for ensuring the context 1 and 2 activities are executed. For context 6: The Associate Director of Enterprise Applications will be responsible for ensuring the context 6 activities are executed.Refer to audit report for full response.
2020-001
FINDING 2021-004 - Special Tests and Provisions: Return of Title IV funds for withdrawn students(Repeat finding 2020-002, 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011)Federal ProgramsDepartment of EducationStudent Financial Assistance Cluster (Various Assistance Listing numbers)Award year ended June 30, 2021CriteriaPursuant to the 34 CFR 668.22(j)(2), an institution is required to determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew to allow for the timely calculation and return of Title IV funds as required. Pursuant to the 34CFR 668.22(e), an institution is required to calculate the amount of title IV assistance earned by the student once the institution has determined the withdrawal date in accordance with the 34 CFR 668.22(j), and pursuant to the 34 CFR 668.22(g), an institution is required to calculate and return unearned aid in the order as required: the lesser of the total amount of unearned Title IV assistance to be returned as calculated under 34 CFR 668.22(e)(4); or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student, as described in 34 CFR 668.22(e)(3). Pursuant to the 34 CFR 690.83(b)(2) an institution shall submit, in accordance with deadline dates established by the U.S. Department of Education (Secretary), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.Pursuant to 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon, but no later than 45 days, after the date of the institution's determination that the student withdrew.34 CFR 668.22(d) requires that an institution does not have to treat a leave of absence as a withdrawal if it is an approved leave of absence. A leave of absence is an approved leave of absence if - (i) The institution has a formal policy regarding leaves of absence; (ii) The student followed the institution's policy in requesting the leave of absence; (iii) The institution determines that there is a reasonable expectation that the student will return to the school; (iv) The institution approved the student's request in accordance with the institution's policy; (v) The leave of absence does not involve additional charges by the institution; (vi) The number of days in the approved leave of absence, when added to the number of days in all other approved leaves of absence, does not exceed 180 days in any 12-month period; (vii) Except for a clock hour or nonterm credit hour program, upon the student's return from the leave of absence, the student is permitted to complete the coursework he or she began prior to the leave of absence; and (viii) If the student is a title IV, HEA program loan recipient, the institution explains to the student, prior to granting the leave of absence, the effects that the student's failure to return from a leave of absence may have on the student's loan repayment terms, including the exhaustion of some or all of the student's grace period.ConditionDuring our testing at UNLV, we identified the following instances: the Institution did not complete the return of Title IV funds as calculated within the 45 day requirement as noted in the Federal Regulations; the Institution did not complete a return of title IV calculation for students who were on academic leave of absence or who withdrew before the institutional census date; and the Institution did not complete the return of Title IV funds as calculated funds within 30 days for a student who did not begin attendance.During our testing at UNR, we identified the Institution did not return and report the return of Title IV funds to Common Origination and Disbursement (?COD?) within the 45-day requirement as noted in the Federal Regulations.ContextFor two out of sixty students tested at UNLV, the Institution did not properly calculate the return of title IV funds for the students who withdrew during a scheduled break of five or more days.For two out of sixty students tested at UNLV, the Institution did not calculate a Return to Title IV needed to be performed within the 30-day timeframe for students who withdrew before the Census date.For three of sixty students tested at UNLV, the funds to be returned were not returned and reported within the 45-day timeframe.For two of sixty students tested at UNR, the funds to be returned were not returned and reported within the 45-day timeframe.Questioned CostsUNLV - $261UNR- $0EffectAt UNLV and UNR, the return of Title IV funds as calculated and applied to the individual student's account at each Institution was not reported to COD timely or accurately.CauseAt UNLV, the funds not being timely returned and reported to COD as calculated, was due to oversight by personnel performing the return calculation.At UNR, the funds not being timely returned and reported to COD as calculated, was due to availability of personnel at the time of reporting.RecommendationWe recommend that UNLV enhance internal controls to improve the timing of determining if a student requires a Return to Title IV calculation and enhance the process to ensure the accurate calculation and reporting to COD.We recommend that UNR enhance internal controls and Return of Title IV funds process to ensure timely return and reporting of Return of Title IV.Views of Responsible Officials (unaudited)Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2021-004 - Special Tests and Provisions: Return of Title IV funds for withdrawn students(Repeat finding 2020-002, 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011)Federal ProgramsDepartment of EducationStudent Financial Assistance Cluster (Various Assistance Listing numbers)Award year ended June 30, 2021CriteriaPursuant to the 34 CFR 668.22(j)(2), an institution is required to determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew to allow for the timely calculation and return of Title IV funds as required. Pursuant to the 34CFR 668.22(e), an institution is required to calculate the amount of title IV assistance earned by the student once the institution has determined the withdrawal date in accordance with the 34 CFR 668.22(j), and pursuant to the 34 CFR 668.22(g), an institution is required to calculate and return unearned aid in the order as required: the lesser of the total amount of unearned Title IV assistance to be returned as calculated under 34 CFR 668.22(e)(4); or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student, as described in 34 CFR 668.22(e)(3). Pursuant to the 34 CFR 690.83(b)(2) an institution shall submit, in accordance with deadline dates established by the U.S. Department of Education (Secretary), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct.Pursuant to 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon, but no later than 45 days, after the date of the institution's determination that the student withdrew.34 CFR 668.22(d) requires that an institution does not have to treat a leave of absence as a withdrawal if it is an approved leave of absence. A leave of absence is an approved leave of absence if - (i) The institution has a formal policy regarding leaves of absence; (ii) The student followed the institution's policy in requesting the leave of absence; (iii) The institution determines that there is a reasonable expectation that the student will return to the school; (iv) The institution approved the student's request in accordance with the institution's policy; (v) The leave of absence does not involve additional charges by the institution; (vi) The number of days in the approved leave of absence, when added to the number of days in all other approved leaves of absence, does not exceed 180 days in any 12-month period; (vii) Except for a clock hour or nonterm credit hour program, upon the student's return from the leave of absence, the student is permitted to complete the coursework he or she began prior to the leave of absence; and (viii) If the student is a title IV, HEA program loan recipient, the institution explains to the student, prior to granting the leave of absence, the effects that the student's failure to return from a leave of absence may have on the student's loan repayment terms, including the exhaustion of some or all of the student's grace period.ConditionDuring our testing at UNLV, we identified the following instances: the Institution did not complete the return of Title IV funds as calculated within the 45 day requirement as noted in the Federal Regulations; the Institution did not complete a return of title IV calculation for students who were on academic leave of absence or who withdrew before the institutional census date; and the Institution did not complete the return of Title IV funds as calculated funds within 30 days for a student who did not begin attendance.During our testing at UNR, we identified the Institution did not return and report the return of Title IV funds to Common Origination and Disbursement (?COD?) within the 45-day requirement as noted in the Federal Regulations.ContextFor two out of sixty students tested at UNLV, the Institution did not properly calculate the return of title IV funds for the students who withdrew during a scheduled break of five or more days.For two out of sixty students tested at UNLV, the Institution did not calculate a Return to Title IV needed to be performed within the 30-day timeframe for students who withdrew before the Census date.For three of sixty students tested at UNLV, the funds to be returned were not returned and reported within the 45-day timeframe.For two of sixty students tested at UNR, the funds to be returned were not returned and reported within the 45-day timeframe.Questioned CostsUNLV - $261UNR- $0EffectAt UNLV and UNR, the return of Title IV funds as calculated and applied to the individual student's account at each Institution was not reported to COD timely or accurately.CauseAt UNLV, the funds not being timely returned and reported to COD as calculated, was due to oversight by personnel performing the return calculation.At UNR, the funds not being timely returned and reported to COD as calculated, was due to availability of personnel at the time of reporting.RecommendationWe recommend that UNLV enhance internal controls to improve the timing of determining if a student requires a Return to Title IV calculation and enhance the process to ensure the accurate calculation and reporting to COD.We recommend that UNR enhance internal controls and Return of Title IV funds process to ensure timely return and reporting of Return of Title IV.Views of Responsible Officials (unaudited)Management concurs.
FINDING 2021-004 - Special Tests and Provisions: Return of Title IV funds for withdrawn students(Repeat finding 2020-002, 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011)? Name of contact person responsible for corrective action plan:Rhett R. Vertrees, CPAAssistant Chief Financial Officer2601 Enterprise RoadReno, NV 89512-1666Phone: 775-784-3409Fax: 775-784-1127Email: rvertrees@nshe.nevada.eduInstitution ResponsesUNLV?UNLV agrees with this 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;For context 1, due to a configuration error for the spring 2021 term, the automated R2T4 calculation did not properly account for days within the scheduled break in spring 2021. This setup has also been reviewed for accuracy for the spring 2022 term (current academic year) and will be part of the routine term configuration review annually. The calculation error for these two students has been corrected and all spring 2021 R2T4 records were reviewed to ensure this error did not impact other records.For context 2, the system configuration led to the cancellation of aid for any student who withdrew prior to the census date. As a result, the process of identifying these students, then determining whether they began attendance prior to withdrawal, was largely manual and time-consuming, leading to delays. This setup issue has already been improved in 2021-2022, wherein only Pell Grants are automatically impacted by withdrawals before census. Other aid remains intact until the students? attendance is confirmed. This reduces the volume of manual work so that the process can be completed timely. In addition, an additional staff member has been made available to support the R2T4 function.For context 3, the timeliness of R2T4 processing has been addressed by assigning an additional staff member to these processes as noted above. In addition to adding a staff member, the Executive Director and/or the Assistant Director for processing track biweekly the current turnaround time for R2T4 returns to ensure processing is being completed timely.? How compliance and performance will be measured and documented for future audit, management and performance review.Following the 2019-2020 academic year audit cycle, a new Assistant Vice President for Admissions and Financial Aid and a new Executive Director for Financial Aid and Scholarships were hired. Other leadership positions have also been added to the team to enhance compliance, performance, and student service needs. The new management team has implemented additional staff training programs and supervision and oversight procedures to ensure timeliness and accuracy. Routine weekly team meetings include status reports/check-ins to ensure procedures are followed and any issues that may arise are timely identified and resolved.? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted.The Assistant Vice President for Admissions & Financial Aid and the Executive Director for Financial Aid and Scholarships will be responsible for ensuring ongoing compliance.UNR?? 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 Financial Aid Policies and Procedures Manual has been revised to ensure that the return of Title IV funds are performed timely and the funds are returned to the Common Origination and Disbursement (?COD?) no later than 10 days before the 45 day deadline. This will provide the needed time to review any rejects and make the necessary corrections without impacting the deadline. In addition, a second person has been trained to provide assistance with the calculation of Title IV funds.? How compliance and performance will be measured and documented for future audit, management and performance review.A Performance Report will be reviewed bi-weekly to ensure the timely calculation and return of Title IV aid.? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted.The Director of Student Financial Aid & Scholarships provides oversight of the processes and is accountable for compliance in this area.
2020-002
FINDING 2021-005 - Special Tests and Provisions: Disbursements To or On Behalf of Students(Repeat Finding 2020-003, 2019-005, 2018-007, 2016-004, 2015-009)Federal ProgramsDepartment of EducationStudent Financial Assistance Cluster (Various Assistance Listing numbers)Award year ended June 30, 2021CriteriaPursuant to 34 CFR 668.165(a)(1) requires that before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed.ConditionDuring our testing at CSN, we identified an instance where the Institution disbursed a Pell Grant and Direct Loans to a student before notifying the student of the award.ContextFor one student out of sixty selected for testing at CSN, the Institution disbursed a Pell Grant and Direct Loans to a student before notifying the student of the award.Questioned CostsCSN - $0EffectCSN did not consistently comply with the specific requirements of Federal Regulations with respect to the disbursement of student funds.CauseFor CSN, the disbursement of student funds occurred before the award notification was sent to the student due to issue in PeopleSoft.RecommendationWe recommend that CSN enhances controls to ensure award notification letters are sent to students before the disbursement of funds.Views of Responsible Officials (unaudited)Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2021-005 - Special Tests and Provisions: Disbursements To or On Behalf of Students(Repeat Finding 2020-003, 2019-005, 2018-007, 2016-004, 2015-009)Federal ProgramsDepartment of EducationStudent Financial Assistance Cluster (Various Assistance Listing numbers)Award year ended June 30, 2021CriteriaPursuant to 34 CFR 668.165(a)(1) requires that before an institution disburses Title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each Title IV, HEA program, and how and when those funds will be disbursed.ConditionDuring our testing at CSN, we identified an instance where the Institution disbursed a Pell Grant and Direct Loans to a student before notifying the student of the award.ContextFor one student out of sixty selected for testing at CSN, the Institution disbursed a Pell Grant and Direct Loans to a student before notifying the student of the award.Questioned CostsCSN - $0EffectCSN did not consistently comply with the specific requirements of Federal Regulations with respect to the disbursement of student funds.CauseFor CSN, the disbursement of student funds occurred before the award notification was sent to the student due to issue in PeopleSoft.RecommendationWe recommend that CSN enhances controls to ensure award notification letters are sent to students before the disbursement of funds.Views of Responsible Officials (unaudited)Management concurs.
FINDING 2021-005 - Special Tests and Provisions: Disbursements To or On Behalf of Students(Repeat Finding 2020-003, 2019-005, 2018-007, 2016-004, 2015-009)? Name of contact person responsible for corrective action plan:Rhett R. Vertrees, CPAAssistant Chief Financial Officer2601 Enterprise RoadReno, NV 89512-1666Phone: 775-784-3409Fax: 775-784-1127Email: rvertrees@nshe.nevada.eduInstitution ResponsesCSN ?? 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;A query will be created to place a hold on the record prior to disbursement to ensure funding isn?t released until a notification has been sent to the student. Once a notification has been sent, the holds will be removed so disbursement can take place. Our plan is to have this new process implemented by December 1, 2021.? How compliance and performance will be measured and documented for future audit, management and performance review.The process to place and remove holds will run prior to any disbursement. CSN will also create additional queries to monitor and ensure the hold process (mentioned previously) is working properly. A Financial Aid Specialist will be reviewing and monitoring the hold processes weekly (special disbursements situations may increase from weekly to daily) to ensure compliance with federal regulations.? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted.The Associate Vice President and Financial Aid Assistant Director will be responsible to ensure that this finding doesn?t reoccur.
2020-003
FINDING 2021-006 - Special Tests and Provisions: Enrollment Reporting (Repeat finding 2020-004, 2019-006, 2018-008 2016-002, 2015-006, 2014-012)Federal ProgramsDepartment of EducationStudent Financial Assistance Cluster (Federal Direct Student Loans, Assistance Listing 84.268)Award year ended June 30, 2021CriteriaPursuant to 34 CFR 685.309(b), upon receipt of a student status confirmation report from the Secretary, an institution must complete and return that report to the Secretary within 30 days of receipt, and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who:(i) Enrolled at that school but has ceased to be enrolled on at least a half-time basis;(ii) Has been accepted for enrollment at that school but failed to enroll on at least a half-time basis for the period which the loan was intended; or has changed his or her permanent address.ConditionWe noted CSN and NSC did not report student status changes to the National Student Loan Data System (?NSLDS?) within 30 days, or within 60 days when they expected to submit their next student status confirmation report within that time period, of the change as required by the regulations.ContextFor eight of sixty students tested at CSN, and for eight of sixty students tested at NSC, the student?s changed enrollment status was not reported to NSLDS within the 30-day or 60-day timeframes as noted above.Questioned CostsCSN - $0NSC - $0EffectCSN and NSC did not comply with the specific requirements of Federal Regulations with respect to student status communications to the Secretary.CauseExceptions noted at CSN and NSC was due to oversight by personnel performing enrollment reporting procedures and improper review of population uploads to NSLDS.RecommendationWe recommend that CSN and NSC establish a procedure to ensure student status changes are uploaded timely and correctly to NSLDS after being submitted to National Student Clearinghouse. Additionally, we recommend that the Institutions review the remaining population of students and as well as student classifications to ensure that all are being properly reported.Views of Responsible Officials (unaudited)Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2021-006 - Special Tests and Provisions: Enrollment Reporting (Repeat finding 2020-004, 2019-006, 2018-008 2016-002, 2015-006, 2014-012)Federal ProgramsDepartment of EducationStudent Financial Assistance Cluster (Federal Direct Student Loans, Assistance Listing 84.268)Award year ended June 30, 2021CriteriaPursuant to 34 CFR 685.309(b), upon receipt of a student status confirmation report from the Secretary, an institution must complete and return that report to the Secretary within 30 days of receipt, and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who:(i) Enrolled at that school but has ceased to be enrolled on at least a half-time basis;(ii) Has been accepted for enrollment at that school but failed to enroll on at least a half-time basis for the period which the loan was intended; or has changed his or her permanent address.ConditionWe noted CSN and NSC did not report student status changes to the National Student Loan Data System (?NSLDS?) within 30 days, or within 60 days when they expected to submit their next student status confirmation report within that time period, of the change as required by the regulations.ContextFor eight of sixty students tested at CSN, and for eight of sixty students tested at NSC, the student?s changed enrollment status was not reported to NSLDS within the 30-day or 60-day timeframes as noted above.Questioned CostsCSN - $0NSC - $0EffectCSN and NSC did not comply with the specific requirements of Federal Regulations with respect to student status communications to the Secretary.CauseExceptions noted at CSN and NSC was due to oversight by personnel performing enrollment reporting procedures and improper review of population uploads to NSLDS.RecommendationWe recommend that CSN and NSC establish a procedure to ensure student status changes are uploaded timely and correctly to NSLDS after being submitted to National Student Clearinghouse. Additionally, we recommend that the Institutions review the remaining population of students and as well as student classifications to ensure that all are being properly reported.Views of Responsible Officials (unaudited)Management concurs.
FINDING 2021-006 - Special Tests and Provisions: Enrollment Reporting (Repeat finding 2020-004, 2019-006, 2018-008 2016-002, 2015-006, 2014-012)? Name of contact person responsible for corrective action plan:Rhett R. Vertrees, CPAAssistant Chief Financial Officer2601 Enterprise RoadReno, NV 89512-1666Phone: 775-784-3409Fax: 775-784-1127Email: rvertrees@nshe.nevada.eduInstitution ResponsesCSN -? 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;Due to the COVID-19 pandemic, CSN was working remotely which caused miscommunication and difficulties in oversight and access to enrollment reporting. This resulted in the reporting being out of compliance. The Registrar?s Office has already created a plan to ensure that in the event that remote working is to take place again, the challenges faced previously will no longer hinder enrollment reporting operations which will keep CSN in compliance.The Office of the Registrar has already implemented a quality assurance plan as well as a communication plan between four staff members (associate registrar, two analysts, and one administrative assistant) who will be responsible for reviewing and correcting error reports from the National Student Clearinghouse (NSC) and NSLDS in an accurate and timely manner. In conjunction with the Financial Aid Office, the Office of the Registrar will also produce reports from the NSLDS to compare against students receiving financial aid at CSN and update student enrollment statuses as necessary. This process will ensure accurate reporting on behalf of students to the NSC and NSLDS.Moving forward consistent training within the office, including training provided by the NSC, and clear communication between the team will occur to ensure reports are completed within 30 days as scheduled.? How compliance and performance will be measured and documented for future audit, management and performance review.The associate registrar will be responsible for ongoing cross training between two analysts and an administrative assistant to review, correct and update the NSC. Detailed records will be maintained in the shared Registrar network drive. Communication will play a key role to confirm reports are completed, student accounts are updated, enrollment status changes are accurate and reported timely within the reporting requirements.? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted.The Registrar and Associate Registrar ensure status changes are reported timely and within 30 days, or within the 60-day timeframe.NSC -? 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; Nevada State College (NSC) reports to theNational Student Clearinghouse every two weeks from the start of the semester. By reporting this often, we are ensuring that there is up-to-date information from the Clearinghouse to be sent to NSLDS within the 60-day period. Some of the errors found were a result of our file not calculating dates correctly to report status changes ? the files will be checked for accuracy before submission. Other errors were a result of Clearinghouse details not being sent correctly to NSLDS with status changes.? How compliance and performance will be measured and documented for future audit, management and performance review.Once an error report posts to Clearinghouse as the result of changes to the student?s status, it is downloaded and saved to a folder along with the corrections made in the error report. A monthly report is also sent to stakeholders within the institution with the monthly enrollment reporting submissions, corrections, and explanations of those corrections.? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted.The primary person responsible will be the Registrar.
2020-004
FINDING 2021-007 - Special Tests and Provisions: Verification and Updating of Student Aid Application Information (Repeat finding 2020-006)Federal ProgramsDepartment of EducationStudent Financial Assistance Cluster (Various Assistance Listing numbers)Award year ended June 30, 2021Criteria34 CFR 668.59(a) requires that for the subsidized student financial assistance programs, if an applicant's Free Application for Federal Student Aid (FAFSA) information changes as a result of verification, the applicant or the institution must report to the Secretary any changes to - (1) A non-dollar value item; or (2) A single dollar item of $25 or more.ConditionCSN did not properly and consistently update FAFSA information as a result of the verification process.ContextFor one of the sixty students tested at CSN, the Institution did not correct the student?s parent?s education credit based on the documentation provided on the tax return.Questioned CostsCSN - $0EffectCSN is not in compliance with federal regulations related to items required for verification.CauseInstances noted at CSN were due to oversight failures by personnel performing verification procedures.RecommendationWe recommend that CSN enhance internal controls to ensure updating of student aid application information is accurate, implement training to ensure verification is being performed accurately.Views of Responsible Officials (unaudited)Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2021-007 - Special Tests and Provisions: Verification and Updating of Student Aid Application Information (Repeat finding 2020-006)Federal ProgramsDepartment of EducationStudent Financial Assistance Cluster (Various Assistance Listing numbers)Award year ended June 30, 2021Criteria34 CFR 668.59(a) requires that for the subsidized student financial assistance programs, if an applicant's Free Application for Federal Student Aid (FAFSA) information changes as a result of verification, the applicant or the institution must report to the Secretary any changes to - (1) A non-dollar value item; or (2) A single dollar item of $25 or more.ConditionCSN did not properly and consistently update FAFSA information as a result of the verification process.ContextFor one of the sixty students tested at CSN, the Institution did not correct the student?s parent?s education credit based on the documentation provided on the tax return.Questioned CostsCSN - $0EffectCSN is not in compliance with federal regulations related to items required for verification.CauseInstances noted at CSN were due to oversight failures by personnel performing verification procedures.RecommendationWe recommend that CSN enhance internal controls to ensure updating of student aid application information is accurate, implement training to ensure verification is being performed accurately.Views of Responsible Officials (unaudited)Management concurs.
FINDING 2021-007 - Special Tests and Provisions: Verification and Updating of Student Aid Application Information (Repeat finding 2020-006)? Name of contact person responsible for corrective action plan:Rhett R. Vertrees, CPAAssistant Chief Financial Officer2601 Enterprise RoadReno, NV 89512-1666Phone: 775-784-3409Fax: 775-784-1127Email: rvertrees@nshe.nevada.eduInstitution ResponsesCSN -? 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;Problematic files or potential errors received by the third-party vendor will be routed back to CSN for processing. This will allow the institution to work directly with the student to complete verification process to ensure accuracy and avoid unnecessary burden to the student. CSN will also continue performing quality assurance on verification files to identify any errors or conflicting information. These measures will be in place starting November 1, 2021.? How compliance and performance will be measured and documented for future audit, management and performance review.CSN will track errors found in the quality assurance process and keep record of the number of students routed back to the institution for processing. CSN will discuss the data gathered with the third-party vendor during quarterly meetings and set any corrective action plans as needed.? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted.The Associate Vice President and Financial Aid Assistant Director will be responsible to ensure that this finding doesn?t reoccur.
2020-006
FINDING 2021-008 - Reporting Pell Common Origination RecordsFederal ProgramsDepartment of EducationStudent Financial Assistance Cluster (Federal Pell Grant Program, 84.063)Award year ended June 30, 2021CriteriaInstitutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data.ConditionCSN did not report disbursement of Pell grant within the required timeframe.ContextFor one of the sixty students tested at CSN, the Institution did not report to COD the disbursement of Pell grant to a student within 15 days of disbursement date.Questioned CostsCSN - $0EffectCSN is not in compliance with federal regulations related to reporting of Pell disbursement.CauseThe instance noted at CSN was due to oversight failures by personnel in ensuring that upload to COD was performed timely.RecommendationWe recommend that CSN enhance internal controls to ensure that Pell disbursement is reported within the required timeframe to COD.Views of Responsible Officials (unaudited)Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2021-008 - Reporting Pell Common Origination RecordsFederal ProgramsDepartment of EducationStudent Financial Assistance Cluster (Federal Pell Grant Program, 84.063)Award year ended June 30, 2021CriteriaInstitutions must report student disbursement data within 15 calendar days after the institution makes a disbursement or becomes aware of the need to make an adjustment to previously reported student disbursement data or expected student disbursement data.ConditionCSN did not report disbursement of Pell grant within the required timeframe.ContextFor one of the sixty students tested at CSN, the Institution did not report to COD the disbursement of Pell grant to a student within 15 days of disbursement date.Questioned CostsCSN - $0EffectCSN is not in compliance with federal regulations related to reporting of Pell disbursement.CauseThe instance noted at CSN was due to oversight failures by personnel in ensuring that upload to COD was performed timely.RecommendationWe recommend that CSN enhance internal controls to ensure that Pell disbursement is reported within the required timeframe to COD.Views of Responsible Officials (unaudited)Management concurs.
FINDING 2021-008 - Reporting Pell Common Origination Records? Name of contact person responsible for corrective action plan:Rhett R. Vertrees, CPAAssistant Chief Financial Officer2601 Enterprise RoadReno, NV 89512-1666Phone: 775-784-3409Fax: 775-784-1127Email: rvertrees@nshe.nevada.eduInstitution ResponsesCSN -? 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;CSN will continue to request Pell Reconciliation files from COD on a weekly basis. During peak processing times two Senior Specialists will be responsible for reviewing all Pell disbursements to meet disbursement deadlines. Disbursements and originations rejected by COD will be notated on Pell Reconciliation file so that Specialists are prompted to update the record correctly as ?ready to send? in Peoplesoft to be sent back to COD in the next day?s transmissions. This method will be implemented starting October 1, 2021.? How compliance and performance will be measured and documented for future audit, management and performance review.The Senior Specialist of Pell Reconciliation will review any updated Pell records within two business days to ensure the records were sent and accepted in COD. Additionally, the Senior Specialists will notify the Assistant Director of any problematic Pell records within five days of disbursement to allow enough time to resolve any issues within the 15-day timeframe. The Assistant Director will review the weekly Pell Reconciliation files to ensure compliance.? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted.The Associate Vice President and Financial Aid Assistant Director will be responsible to ensure that this finding doesn?t reoccur.
FAC accepted this audit on June 17, 2021 — management decision was due December 17, 2021.
FINDING 2020-001 - Internal Control over Compliance (Repeat Finding 2019-002, 2018-003, 2017-002, 2015-002, 2014-008) Federal Programs Departments of Education and Department of Health and Human Services Student Financial Assistance Cluster (Various CFDAs) Award year ended June 30, 2020 Department of Education Education Stabilization Fund (COVID-19) (CFDAs 84.425E and 84.425F) Award year ended June 30, 2020 Criteria 2 CFR 200.303(a) requires that non-Federal entities receiving Federal awards establish and maintain effective internal control over the Federal award to provide reasonable assurance that they are managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition At the University of Nevada, Reno (?UNR?), University of Nevada, Las Vegas (?UNLV?) and System Computing Services (?SCS?), we noted deficiencies in security administration related to the information technology general controls (?ITGCs?) in the PeopleSoft application. Specifically, controls were lacking around restriction of elevated access, user access reviews, termination of access and segregation of duties as it relates to the PeopleSoft application over the student financial assistance program. Context During our testing of the ITGCs in the PeopleSoft application, we noted the following segregation of duties issues: (1) At UNLV and SCS, several users have both PeopleSoft Administrator rights within the Production and Development environment; (2) At UNLV, five users have both PeopleSoft PeopleTool administrator rights within the Production and Development environment which allows them to modify PS objects and perform change management duties; (3) At UNR, four users have both PeopleSoft Administrator rights within the Production and Development environment; (4) At SCS, no user access reviews were performed during the audit period for the PeopleSoft application or Oracle Database (5) At SCS, two users have both PeopleSoft PeopleTool administrator rights within the Production and Development environment which allows them to modify PS objects and perform change management duties. (6) At SCS, UNR and UNLV, activity performed by users with SOD conflicts (see 1-3, 5 above), are not formally reviewed on a periodic basis for appropriateness. The deficiencies in security administration controls could impact compliance requirements related to determining eligibility, disbursements, return of Title IV funds and verification. Questioned Costs $0 Effect 1. Security Administration (#4) and Change Management (#1-3, #5 & #6)-Student data within the PeopleSoft application may be affected by users having conflicting roles or access levels, and accountability may not be established. Student data may be affected by unauthorized, inappropriate, or untested changes to the system. This could impact eligibility, disbursements, return of Title IV funds and verification. Cause The issues identified are part of the lack of effective ITGCs in the PeopleSoft application. Recommendation 1. Security Administration (#4)-Management should perform a formally documented periodic review of user access. 2.Change Management(#1-3, #5-6 & #7)-Management should segregate duties and remove users with access to both the Development and Production environments (limiting them to be able to access just one environment) or implement a formal review process over the activities performed by those responsible for program maintenance on a periodic basis. Views of Responsible Officials (unaudited) Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2020-001 - Internal Control over Compliance (Repeat Finding 2019-002, 2018-003, 2017-002, 2015-002, 2014-008) Federal Programs Departments of Education and Department of Health and Human Services Student Financial Assistance Cluster (Various CFDAs) Award year ended June 30, 2020 Department of Education Education Stabilization Fund (COVID-19) (CFDAs 84.425E and 84.425F) Award year ended June 30, 2020 Criteria 2 CFR 200.303(a) requires that non-Federal entities receiving Federal awards establish and maintain effective internal control over the Federal award to provide reasonable assurance that they are managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition At the University of Nevada, Reno (?UNR?), University of Nevada, Las Vegas (?UNLV?) and System Computing Services (?SCS?), we noted deficiencies in security administration related to the information technology general controls (?ITGCs?) in the PeopleSoft application. Specifically, controls were lacking around restriction of elevated access, user access reviews, termination of access and segregation of duties as it relates to the PeopleSoft application over the student financial assistance program. Context During our testing of the ITGCs in the PeopleSoft application, we noted the following segregation of duties issues: (1) At UNLV and SCS, several users have both PeopleSoft Administrator rights within the Production and Development environment; (2) At UNLV, five users have both PeopleSoft PeopleTool administrator rights within the Production and Development environment which allows them to modify PS objects and perform change management duties; (3) At UNR, four users have both PeopleSoft Administrator rights within the Production and Development environment; (4) At SCS, no user access reviews were performed during the audit period for the PeopleSoft application or Oracle Database (5) At SCS, two users have both PeopleSoft PeopleTool administrator rights within the Production and Development environment which allows them to modify PS objects and perform change management duties. (6) At SCS, UNR and UNLV, activity performed by users with SOD conflicts (see 1-3, 5 above), are not formally reviewed on a periodic basis for appropriateness. The deficiencies in security administration controls could impact compliance requirements related to determining eligibility, disbursements, return of Title IV funds and verification. Questioned Costs $0 Effect 1. Security Administration (#4) and Change Management (#1-3, #5 & #6)-Student data within the PeopleSoft application may be affected by users having conflicting roles or access levels, and accountability may not be established. Student data may be affected by unauthorized, inappropriate, or untested changes to the system. This could impact eligibility, disbursements, return of Title IV funds and verification. Cause The issues identified are part of the lack of effective ITGCs in the PeopleSoft application. Recommendation 1. Security Administration (#4)-Management should perform a formally documented periodic review of user access. 2.Change Management(#1-3, #5-6 & #7)-Management should segregate duties and remove users with access to both the Development and Production environments (limiting them to be able to access just one environment) or implement a formal review process over the activities performed by those responsible for program maintenance on a periodic basis. Views of Responsible Officials (unaudited) Management concurs.
FINDING 2020-001 - Internal Control over Compliance (Repeat Finding 2019-002, 2018-003, 2017-002, 2015-002, 2014-008) Responses UNR ? ? 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; (3) Due to the limited size of the Office of Information Technology staff, the PeopleSoft Administrator role will continue to be necessary for certain positions in order for them to accomplish their duties in the various environments. One consultant and three staff are currently assigned the PSA role. We recognize the risks associated with the role, and the following mitigation strategies are in place to reduce and manage the risk. ? The Office of Information Technology PeopleSoft Manager oversees the staff and consultants that are assigned the PSA role. Changes are documented in security applications and approved by the Manager. ? An audit trigger notifies the Registrar, PeopleSoft Manager, CSO and the CIO when the PSA role is granted to users in the production, test, quality assurance or development environments. ? The consultant is covered under the Master Services Agreement between NSHE and Sierra Cedar, Inc., signed on January 15, 2008, that includes Article 9 ? Data Rights and Confidentiality. The contractor is expected to be complete with the current SSO project by December 31, 2020. (6) Management has considered the auditor recommendation and determined that the amount of data to be reviewed during formally documented periodic reviews of user activity would be so voluminous that the process would result in inefficient operations and could adversely impact the system affecting University?s constituents and communities. The PeopleSoft Manager will explore options to address this condition, which will include assessing the change management system to determine if it has specific capabilities that would provide an additional control over changes made by the PSA?s, or determining whether data tables could be developed to allow for an efficient review process. ? How compliance and performance will be measured and documented for future audit, management and performance review. (4) Changes to user access are documented in security applications. Audit trigger notifications for the addition of PS Admin role will provide support that management is made aware when the PS Admin role is added. (6) Exploration of options to either develop a review process or to implement mitigating controls will be documented by the PeopleSoft Manager, and implemented as practicable. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The PeopleSoft Manager will be responsible for compliance with these requirements. UNLV ? ? 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; UNLV agrees with the finding. For context 1 and 2: UNLV understands the importance of adequate segregation of duties within the PeopleSoft environments and applications. The positions that are the subject of the finding are the PeopleSoft Administrators who are responsible for installation, configuration, upgrades and troubleshooting all the application environments and Database Administrators are responsible for installation, configuration, upgrade and troubleshooting for the services associated with the all the database environments. The PeopleSoft and Database Administrators are not programmers/developers and their access to the environments is required to provide timely support of the application within the scope of their job duties. UNLV will continue to review access requirements for the PeopleSoft and Database Administrators prior to the start of Fall and Spring terms. Additionally, UNLV will continue to research other control methods that will address segregation of duties while providing appropriate service and support. For context 6: UNLV understands the importance of activity review of all users especially those with segregation of duties conflicts. UNLV will increase our current review processes to ensure project review activities are appropriate and in line with approved activities. ? How compliance and performance will be measured and documented for future audit, management and performance review. For context 1 and 2, UNLV will review the access needs each Fall and Spring term to determine if the current levels of access for the PeopleSoft and Database Administrators are still required. Additionally, UNLV will continue to research other control methods that will address segregation of duties while providing appropriate service and support. For context 6, UNLV will review and compare project activities to the approved activities as documented within our change management process. The process will be initiated each Fall and Spring term and executed by the OIT Security office who have no direct involvement in change management activities. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. For context 1 and 2, the Associate Director of Enterprise Applications will be responsible for reviewing the access needs for the PeopleSoft and Database Administrators. The Associate Director will complete periodic reviews and is also accountable if repeat or similar observations are noted. For context 6, the Associate Director of Enterprise Applications and the Interim Chief Information Security Officer will ensure the execution of this review. SCS ? ? 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; (1,5) Due to the limited size of SCS?s Information Technology staff, the PeopleSoft and PeopleTool Administrator roles will continue to be necessary for certain positions in order for them to accomplish their duties in the various environments. Currently, 3 users are assigned the PeopleSoft Administrator role and 2 are assigned the PeopleSoft PeopleTools Administrator role. In order to perform system admin duties for all shared-instance institutions in an efficient and effective manner, at least one backup administrator is required for each of PeopleSoft and PeopleTools. We recognize the risks associated with the role, and the following mitigation strategies are in place to reduce and manage the risk. The Director of Information and Application Services oversees the IT staff that are assigned the Administrator roles. Key changes are communicated and approved by the Director. Audit alerts are established that notify the PeopleSoft Administrators, Director of Information and Application Services and CISO when Administrator roles and permissions are granted in the various PeopleSoft environments. (4) A periodic user access review process will be developed and overseen by Internal Audit and the NSHE Information Security Team. It is anticipated that this will be implemented during the next 6 months. (6) Change control processes are in place that support the oversight and approval of system changes, these are documented in KACE and JIRA. Unfortunately, PeopleSoft does not have activity reporting capabilities commensurate with all object changes as it relates to system admin activity. Per (1,5) above, audit alerts will notify the Director of Information and Application Services and CISO when administrator roles and permissions are granted outside of what has been pre-approved. ? How compliance and performance will be measured and documented for future audit, management and performance review. (1,5) Changes to user access is monitored and alerts have been established for Administrator roles and permissions. The users with administrator access to both production and development are established and trusted employees, and are required to engage in both PeopleSoft environments on a daily basis in order to perform their job function. Changes to the system are captured within the IT ticketing system (KACE/JIRA) and require approval from the Director of Information and Application Services. (4) A periodic user access review process will be developed and overseen by Internal Audit and the NSHE Information Security Team. The review will include an independent analysis of improper assignment of access as well as management sign-off. (6) During October 2020, the SCS PeopleSoft Administration team adopted JIRA as the system of record for change management. This will allow for improved transparency and documentation of system changes/updates associated with system admins. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. (1,5,6) SCS Director of Information and Application Services (4) SCS Director of Information and Application Services, NSHE Internal Audit, SCS Security Group
2019-002
FINDING 2020-002 - Special Tests and Provisions: Return of Title IV funds for withdrawn students (Repeat finding 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011) Federal Programs Department of Education Student Financial Assistance Cluster (Various CFDAs) Award year ended June 30, 2020 Criteria Pursuant to the 34 CFR 668.22(j)(2), an institution is required to determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew to allow for the timely calculation and return of Title IV funds as required. Pursuant to the 34CFR 668.22(e), an institution is required to calculate the amount of title IV assistance earned by the student once the institution has determined the withdrawal date in accordance with the 34 CFR 668.22(j), and pursuant to the 34 CFR 668.22(g), an institution is required to calculate and return unearned aid in the order as required: the lesser of the total amount of unearned Title IV assistance to be returned as calculated under 34 CFR 668.22(e)(4); or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student, as described in 34 CFR 668.22(e)(3). Pursuant to the 34 CFR 690.83(b)(2) an institution shall submit, in accordance with deadline dates established by the U.S. Department of Education (Secretary), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Pursuant to 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon, but no later than 45 days, after the date of the institution's determination that the student withdrew. 34 CFR 668.22(d) requires that an institution does not have to treat a leave of absence as a withdrawal if it is an approved leave of absence. A leave of absence is an approved leave of absence if - (i) The institution has a formal policy regarding leaves of absence; (ii) The student followed the institution's policy in requesting the leave of absence; (iii) The institution determines that there is a reasonable expectation that the student will return to the school; (iv) The institution approved the student's request in accordance with the institution's policy; (v) The leave of absence does not involve additional charges by the institution; (vi) The number of days in the approved leave of absence, when added to the number of days in all other 202approved leaves of absence, does not exceed 180 days in any 12-month period; (vii) Except for a clock hour or nonterm credit hour program, upon the student's return from the leave of absence, the student is permitted to complete the coursework he or she began prior to the leave of absence; and (viii) If the student is a title IV, HEA program loan recipient, the institution explains to the student, prior to granting the leave of absence, the effects that the student's failure to return from a leave of absence may have on the student's loan repayment terms, including the exhaustion of some or all of the student's grace period. Condition During our testing at UNLV, we identified the following instances: the Institution did not complete the return of Title IV funds as calculated within the 45 day requirement as noted in the Federal Regulations; the Institution did not properly calculate the institutional charges used to determine the portion of unearned Title IV aid that the school is responsible for returning; the Institution did not complete a return of title IV calculation for students who were on academic leave of absence or who withdrew before the institutional census date; COD upload errors were not corrected within the 45 day requirement; and the Institution did not complete the return of Title IV funds as calculated funds within 30 days for a student who did not begin attendance. During our testing at TMCC, we identified an instance where the Institution used the incorrect withdrawal date for a student who withdrew while enrolled in modular courses. Context For five out of the sixty students tested at UNLV, the Institution did not properly calculate institutional charges as defined in 34 CFR 668.22(g)(2) within the return of title IV calculation. Due to the incorrect institutional charges, two of the five students had an incorrect amount of title IV aid returned. For three out of sixty students tested at UNLV, the Institution did not perform a return of title IV funds calculation as the student was on an academic leave of absence. The leave of absence was not an approved leave of absence as defined in 34 CFR 668.22(d), so the calculation should have been performed for each and amounts returned, as appropriate. For two out of sixty students tested at UNLV, the Institution did not perform a return of title IV funds calculation for students who began attendance but withdrew before the institution?s census date. For four out of sixty students tested at UNLV, there were errors in reporting return of title IV funds to COD. The Institution corrected the errors after we had identified them, however the date the institution correct the reporting errors exceeded the required 45 day timeframe. For one out of sixty students tested at UNLV, the Institution did not determine a Return to Title IV calculation needed to be performed within the 30-day timeframe for a student who did not began attending. For forty-one of sixty students tested at UNLV, the funds to be returned were not returned and reported within the 45-day timeframe. Eleven of these errors included calculation and reporting errors mentioned above. For one out of sixty students tested at TMCC, a return of funds was made but was actually unnecessary as the student had not withdrawn. Questioned Costs UNLV - $14,123 TMCC - $772 Effect At UNLV and TMCC, the return of Title IV funds as calculated and applied to the individual student's account 203at each Institution was not reported to Common Origination and Disbursement (?COD?) timely or accurately. Cause At UNLV, the funds not being timely returned and reported to COD as calculated, was due to oversight by personnel performing the return calculation. At TMCC, the configuration of PeopleSoft resulted in importing an assumed withdrawal date associated with one course, however the student completed a later modular course and therefore had not withdrawn as contemplated by Department of Education guidance. Recommendation We recommend that TMCC enhance internal controls and the Return of Title IV funds process to ensure that it is accurately determining the withdrawal date. We recommend that UNLV enhances internal controls to improve the timing of determining if a student requires a Return to Title IV calculation and enhance the process to ensure the accurate calculation and reporting to COD. Views of Responsible Officials (unaudited) Management concurs
Show full finding ▾Hide full finding ▴FINDING 2020-002 - Special Tests and Provisions: Return of Title IV funds for withdrawn students (Repeat finding 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011) Federal Programs Department of Education Student Financial Assistance Cluster (Various CFDAs) Award year ended June 30, 2020 Criteria Pursuant to the 34 CFR 668.22(j)(2), an institution is required to determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew to allow for the timely calculation and return of Title IV funds as required. Pursuant to the 34CFR 668.22(e), an institution is required to calculate the amount of title IV assistance earned by the student once the institution has determined the withdrawal date in accordance with the 34 CFR 668.22(j), and pursuant to the 34 CFR 668.22(g), an institution is required to calculate and return unearned aid in the order as required: the lesser of the total amount of unearned Title IV assistance to be returned as calculated under 34 CFR 668.22(e)(4); or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student, as described in 34 CFR 668.22(e)(3). Pursuant to the 34 CFR 690.83(b)(2) an institution shall submit, in accordance with deadline dates established by the U.S. Department of Education (Secretary), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Pursuant to 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon, but no later than 45 days, after the date of the institution's determination that the student withdrew. 34 CFR 668.22(d) requires that an institution does not have to treat a leave of absence as a withdrawal if it is an approved leave of absence. A leave of absence is an approved leave of absence if - (i) The institution has a formal policy regarding leaves of absence; (ii) The student followed the institution's policy in requesting the leave of absence; (iii) The institution determines that there is a reasonable expectation that the student will return to the school; (iv) The institution approved the student's request in accordance with the institution's policy; (v) The leave of absence does not involve additional charges by the institution; (vi) The number of days in the approved leave of absence, when added to the number of days in all other 202approved leaves of absence, does not exceed 180 days in any 12-month period; (vii) Except for a clock hour or nonterm credit hour program, upon the student's return from the leave of absence, the student is permitted to complete the coursework he or she began prior to the leave of absence; and (viii) If the student is a title IV, HEA program loan recipient, the institution explains to the student, prior to granting the leave of absence, the effects that the student's failure to return from a leave of absence may have on the student's loan repayment terms, including the exhaustion of some or all of the student's grace period. Condition During our testing at UNLV, we identified the following instances: the Institution did not complete the return of Title IV funds as calculated within the 45 day requirement as noted in the Federal Regulations; the Institution did not properly calculate the institutional charges used to determine the portion of unearned Title IV aid that the school is responsible for returning; the Institution did not complete a return of title IV calculation for students who were on academic leave of absence or who withdrew before the institutional census date; COD upload errors were not corrected within the 45 day requirement; and the Institution did not complete the return of Title IV funds as calculated funds within 30 days for a student who did not begin attendance. During our testing at TMCC, we identified an instance where the Institution used the incorrect withdrawal date for a student who withdrew while enrolled in modular courses. Context For five out of the sixty students tested at UNLV, the Institution did not properly calculate institutional charges as defined in 34 CFR 668.22(g)(2) within the return of title IV calculation. Due to the incorrect institutional charges, two of the five students had an incorrect amount of title IV aid returned. For three out of sixty students tested at UNLV, the Institution did not perform a return of title IV funds calculation as the student was on an academic leave of absence. The leave of absence was not an approved leave of absence as defined in 34 CFR 668.22(d), so the calculation should have been performed for each and amounts returned, as appropriate. For two out of sixty students tested at UNLV, the Institution did not perform a return of title IV funds calculation for students who began attendance but withdrew before the institution?s census date. For four out of sixty students tested at UNLV, there were errors in reporting return of title IV funds to COD. The Institution corrected the errors after we had identified them, however the date the institution correct the reporting errors exceeded the required 45 day timeframe. For one out of sixty students tested at UNLV, the Institution did not determine a Return to Title IV calculation needed to be performed within the 30-day timeframe for a student who did not began attending. For forty-one of sixty students tested at UNLV, the funds to be returned were not returned and reported within the 45-day timeframe. Eleven of these errors included calculation and reporting errors mentioned above. For one out of sixty students tested at TMCC, a return of funds was made but was actually unnecessary as the student had not withdrawn. Questioned Costs UNLV - $14,123 TMCC - $772 Effect At UNLV and TMCC, the return of Title IV funds as calculated and applied to the individual student's account 203at each Institution was not reported to Common Origination and Disbursement (?COD?) timely or accurately. Cause At UNLV, the funds not being timely returned and reported to COD as calculated, was due to oversight by personnel performing the return calculation. At TMCC, the configuration of PeopleSoft resulted in importing an assumed withdrawal date associated with one course, however the student completed a later modular course and therefore had not withdrawn as contemplated by Department of Education guidance. Recommendation We recommend that TMCC enhance internal controls and the Return of Title IV funds process to ensure that it is accurately determining the withdrawal date. We recommend that UNLV enhances internal controls to improve the timing of determining if a student requires a Return to Title IV calculation and enhance the process to ensure the accurate calculation and reporting to COD. Views of Responsible Officials (unaudited) Management concurs
FINDING 2020-002 - Special Tests and Provisions: Return of Title IV funds for withdrawn students (Repeat finding 2019-003, 2018-005, 2017-004, 2016-003, 2015-004, 2014-011) Responses UNLV? UNLV agrees with this finding. Unexpected and sudden staffing changes among staff responsible for the processing and management resulted in new staff performing the return to Title IV procedures with inadequate initial training and oversight. ? 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; These aggregated findings demonstrate that our existing training methods and supervision proved inadequate. As a result, a more comprehensive and thorough training procedure is being developed and implemented to improve these results moving forward. We have collaborated with other NSHE campuses to affirm procedural consistency throughout the return to Title IV process as a result of the aggregate problems in this process. The results from this collaboration will be added to the improved training procedures moving forward as well. As it relates to the miscalculation errors, we recognize the finding stemmed from manual, but consistent, errors in data entry. As such, we have begun to research all return to Title IV calculations that were previously completed during this period to confirm the identified errors were not made on other records. If other errors are identified in the research, we will correct those records, including returning additional funds, if required, as well. As it relates to the timeliness errors, the UNLV financial aid office is currently reviewing all return to Title IV cases to confirm that all COD submissions occurred properly, including those who were not included in the sample populations. Where problems are identified, new calculations and COD submissions will result to render the file complete and compliant, even if late. The additional knowledge and coordination with our NSHE colleagues has resulted in a new comprehension of the required timeline to fully comply with all cases in the future. ? How compliance and performance will be measured and documented for future audit, management and performance review. The UNLV financial aid office has worked closely over the past year to close communication gaps between financial aid staff and campus partners for the purpose of policy clarifications and the timely sharing of information. We realized our need to further develop our return to Title IV policies and procedures, and we have collaborated with our NSHE partners to ensure consistent understanding of the return to Title IV requirements moving forward. We remain in regular contact to ensure a high degree of consistency in these procedural expectations. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. UNLV has an active recruitment for Assistant Vice President of Financial Aid & Scholarships. The AVP together with the Associate Director for Financial Aid & Scholarships will be responsible for ensuring ongoing compliance. TMCC? ? 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; TMCC has enhanced R2T4 queries to capture modular enrollment to catch students who add and drop modular classes. These queries will be implemented this month for Spring 2021. ? How compliance and performance will be measured and documented for future audit, management and performance review. The modular queries will be worked each week throughout the term, and stored as Excel files on the department shared drive for the standard three year period as required by ED. A column will be added to each query to indicate that the student has been reviewed by the Program Director. The Financial Aid Coordinator for Compliance will double check that each student was reviewed, which will be indicated by a second review column. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Currently the permanent position that oversees R2T4 is vacant. The Program Director for Student Services Systems temporarily oversees R2T4 processing, and may be held accountable for future repeat or similar observations.
2019-003
FINDING 2020-003 ? Special Tests and Provisions: Disbursements To or On Behalf of Students (Repeat Finding 2019-005, 2018-007, 2016-004, 2015-009) Federal Programs Department of Education Student Financial Assistance Cluster (Various CFDAs) Award year ended June 30, 2020 Criteria Pursuant to 34 CFR 668.164(b)(3), at the time a disbursement is made to a student for a payment period, an institution must confirm that the student is eligible for the type and amount of title IV, HEA program funds identified by that disbursement. Eligibility rules contemplate that first-time FSA borrowers have completed entrance counseling. Pursuant 34 CFR 685.301(b)(2), a school that originates a loan must ensure that the loan is supported by a completed promissory note as proof of the borrower's indebtedness. 34 CFR 668.165(a)(1) requires that before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. Condition During our testing at TMCC, we identified an instance where the Institution disbursed a Pell Grant to a student before notifying the student of the award. Context For one student out of sixty selected for testing at TMCC, the Institution disbursed a Pell Grant to a student before notifying the student of the award. Questioned Costs TMCC - $0 Effect TMCC did not consistently comply with the specific requirements of Federal Regulations with respect to the disbursement of student funds. Cause For TMCC, the disbursement of student funds occurred before the award notification was sent to the student due to issue in the PeopleSoft query. Recommendation We recommend that TMCC enhance controls to ensure award notification letters are sent to students before the disbursement of funds. Views of Responsible Officials (unaudited) Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2020-003 ? Special Tests and Provisions: Disbursements To or On Behalf of Students (Repeat Finding 2019-005, 2018-007, 2016-004, 2015-009) Federal Programs Department of Education Student Financial Assistance Cluster (Various CFDAs) Award year ended June 30, 2020 Criteria Pursuant to 34 CFR 668.164(b)(3), at the time a disbursement is made to a student for a payment period, an institution must confirm that the student is eligible for the type and amount of title IV, HEA program funds identified by that disbursement. Eligibility rules contemplate that first-time FSA borrowers have completed entrance counseling. Pursuant 34 CFR 685.301(b)(2), a school that originates a loan must ensure that the loan is supported by a completed promissory note as proof of the borrower's indebtedness. 34 CFR 668.165(a)(1) requires that before an institution disburses title IV, HEA program funds for any award year, the institution must notify a student of the amount of funds that the student or his or her parent can expect to receive under each title IV, HEA program, and how and when those funds will be disbursed. Condition During our testing at TMCC, we identified an instance where the Institution disbursed a Pell Grant to a student before notifying the student of the award. Context For one student out of sixty selected for testing at TMCC, the Institution disbursed a Pell Grant to a student before notifying the student of the award. Questioned Costs TMCC - $0 Effect TMCC did not consistently comply with the specific requirements of Federal Regulations with respect to the disbursement of student funds. Cause For TMCC, the disbursement of student funds occurred before the award notification was sent to the student due to issue in the PeopleSoft query. Recommendation We recommend that TMCC enhance controls to ensure award notification letters are sent to students before the disbursement of funds. Views of Responsible Officials (unaudited) Management concurs.
FINDING 2020-003 ? Special Tests and Provisions: Disbursements To or On Behalf of Students (Repeat Finding 2019-005, 2018-007, 2016-004, 2015-009) Responses TMCC? ? 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 query used to generate award letters and subsequent award letters has been modified again. We were using the query that the auditors suggested to us last year and we have since determined it was missing students as well. Students also have real-time, 24 hours a day, access to their awards via their MyTMCC Student Center. ? How compliance and performance will be measured and documented for future audit, management and performance review. Award letters are being generated on a daily basis and we have reviewed subsequent awards and determined new award letters are being generated for those students as required. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted The Program Director for Student Services Systems oversees award letter communications.
2019-005
FINDING 2020-004 ? Special Tests and Provisions: Enrollment Reporting (Repeat finding 2019-006, 2018-008 2016-002, 2015-006, 2014-012) Federal Programs Department of Education Student Financial Assistance Cluster (Federal Direct Student Loans, CFDA 84.268) Award year ended June 30, 2020 Criteria Pursuant to 34 CFR 685.309(b), upon receipt of a student status confirmation report from the Secretary, an institution must complete and return that report to the Secretary within 30 days of receipt, and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who: (i) Enrolled at that school but has ceased to be enrolled on at least a half-time basis; (ii) Has been accepted for enrollment at that school but failed to enroll on at least a half-time basis for the period which the loan was intended; or has changed his or her permanent address. Condition We noted CSN and TMCC did not report student status changes to the National Student Loan Data System (?NSLDS?) within 30 days, or within 60 days when it expected to submit its next student status confirmation report within that time period, of the change as required by the regulations. Context For three of sixty students tested at CSN, and three of sixty students tested at TMCC, the student?s changed enrollment status was not reported to NSLDS within the 30 day or 60 day timeframes as noted above. For the errors identified at CSN, the students? status was not properly uploaded to NSLDS. For one of the errors identified at TMCC, the student?s graduated status was not properly uploaded to NSLDS. Questioned Costs CSN - $0 TMCC - $0 Effect CSN and TMCC did not comply with the specific requirements of Federal Regulations with respect to student status communications to the Secretary. Cause Exceptions noted at CSN and TMCC were due to oversight by personnel performing enrollment reporting procedures and improper review of population uploads to NSLDS. Recommendation We recommend that CSN and TMCC establish a procedure to ensure student status changes are uploaded timely and correctly to NSLDS after being submitted to National Student Clearinghouse. Additionally, we recommend that the Institutions review the remaining population of students and as well as student classifications to ensure that all are being properly reported. Views of Responsible Officials (unaudited) Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2020-004 ? Special Tests and Provisions: Enrollment Reporting (Repeat finding 2019-006, 2018-008 2016-002, 2015-006, 2014-012) Federal Programs Department of Education Student Financial Assistance Cluster (Federal Direct Student Loans, CFDA 84.268) Award year ended June 30, 2020 Criteria Pursuant to 34 CFR 685.309(b), upon receipt of a student status confirmation report from the Secretary, an institution must complete and return that report to the Secretary within 30 days of receipt, and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who: (i) Enrolled at that school but has ceased to be enrolled on at least a half-time basis; (ii) Has been accepted for enrollment at that school but failed to enroll on at least a half-time basis for the period which the loan was intended; or has changed his or her permanent address. Condition We noted CSN and TMCC did not report student status changes to the National Student Loan Data System (?NSLDS?) within 30 days, or within 60 days when it expected to submit its next student status confirmation report within that time period, of the change as required by the regulations. Context For three of sixty students tested at CSN, and three of sixty students tested at TMCC, the student?s changed enrollment status was not reported to NSLDS within the 30 day or 60 day timeframes as noted above. For the errors identified at CSN, the students? status was not properly uploaded to NSLDS. For one of the errors identified at TMCC, the student?s graduated status was not properly uploaded to NSLDS. Questioned Costs CSN - $0 TMCC - $0 Effect CSN and TMCC did not comply with the specific requirements of Federal Regulations with respect to student status communications to the Secretary. Cause Exceptions noted at CSN and TMCC were due to oversight by personnel performing enrollment reporting procedures and improper review of population uploads to NSLDS. Recommendation We recommend that CSN and TMCC establish a procedure to ensure student status changes are uploaded timely and correctly to NSLDS after being submitted to National Student Clearinghouse. Additionally, we recommend that the Institutions review the remaining population of students and as well as student classifications to ensure that all are being properly reported. Views of Responsible Officials (unaudited) Management concurs.
FINDING 2020-004 ? Special Tests and Provisions: Enrollment Reporting (Repeat finding 2019-006, 2018-008 2016-002, 2015-006, 2014-012) Responses CSN - CSN concurs with the finding and recommendation. CSN?s current process for monitoring and reconciling errors from the National Student Clearinghouse Enrollment Transmission upload caused incomplete data to be reported to the NSLDS. This finding is different from the prior year finding in that the 2019 finding is specific to graduates only reporting whereas the 2020 finding is related to the overall reporting to NSLDS. ? 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; CSN will create and implement a quality assurance process to ensure accurate and timely enrollment reporting to NSLDS. This will add additional steps to our current process for reviewing the Enrollment Transmission uploads to the National Student Clearinghouse as well as what is being reported to NSLDS by the National Student Clearinghouse. In this procedure, once an Enrollment Transmission file has been sent to the National Student Clearinghouse on a monthly basis, CSN will wait for an NSLDS error report. If one is generated, CSN will work on reviewing and correcting the NSLDS error report and sending it back to be uploaded. The next step is to wait to ensure that the National Student Clearinghouse has loaded the corrections. Once the corrections have been loaded into NSLDS, CSN will log into NSLDS and export a report that we will compare against what has been provided to the National Student Clearinghouse. An analyst and administrative assistant will manually review students excluded from the NSLDS report. CSN is currently working with NSLDS to create a resolution report that will be directly loaded into NSLDS site with corrections and omissions. This will be done within 30 days from the initial reporting to the National Student Clearinghouse. Unresolved discrepancies will be reported to the Associate Registrar and follow-up phone calls/emails will be made to the National Student Clearinghouse and NSLDS as needed. ? How compliance and performance will be measured and documented for future audit, management and performance review. The CSN staff assigned to this task will review and report, in real time, discrepancies found in the Enrollment Transmission file and the NSLDS file, to the Associate Registrar who will make adjustments accordingly. Completed reconciliation reports will be retained on the Office of the Registrar network drive. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Registrar and Associate Registrar share responsibility for Enrollment Reporting. TMCC - ? 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; National Student Clearinghouse (NSC) generates a report and delivers it to the "Degree Verify Coordinator". The person who had this role was not fixing the errors. We have now switched it to the individual who submits the reports and she will receive training from NSC on how to work the error report. The person responsible for NSC reporting is now monitoring these reports. ? How compliance and performance will be measured and documented for future audit, management and performance review. National Student Clearinghouse (NSC) generates a report and delivers it to the "Degree Verify Coordinator". The person who had this role was not fixing the errors. We have now switched it to the individual who submits the reports and she will receive training from NSC on how to work the error report. The person responsible for NSC reporting is now monitoring these reports. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Assistant Director of Admissions and Records oversees the enrollment reporting process in Admissions & Records.
2019-006
FINDING 2020-005 ? Special Tests and Provisions: Gramm-Leach Bliley Act ? Student Information Security (Repeat finding 2019-007) Federal Programs Department of Education Student Financial Assistance Cluster (Various CFDAs) Award year ended June 30, 2020 Criteria 16 CFR 314.1, which implements sections 501 and 505(b)(2) of the Gramm-Leach-Bliley Act, sets forth standards for developing, implementing, and maintaining reasonable administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information. Condition We noted CSN, TMCC, and UNLV did not provide evidence of performance of a risk assessment that addresses the three required areas noted in 16 CFR 314.4(b): (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures or that safeguards for such risks had been put in place. Context CSN, TMCC, and UNLV did not provide evidence of a risk assessment or safeguards for associated risks as outlined above. Questioned Costs $0 Effect CSN, TMCC, and UNLV did not demonstrate to us compliance with the risk assessment or safeguard requirements. Cause Exceptions noted were due to lack of formal process in place at CSN, TMCC, and UNLV for a risk assessment to be performed and safeguards to be implemented. Recommendation We recommend CSN, TMCC, and UNLV to perform a risk assessment on the required areas and document the safeguards for the risks identified. Views of Responsible Officials (unaudited) Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2020-005 ? Special Tests and Provisions: Gramm-Leach Bliley Act ? Student Information Security (Repeat finding 2019-007) Federal Programs Department of Education Student Financial Assistance Cluster (Various CFDAs) Award year ended June 30, 2020 Criteria 16 CFR 314.1, which implements sections 501 and 505(b)(2) of the Gramm-Leach-Bliley Act, sets forth standards for developing, implementing, and maintaining reasonable administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information. Condition We noted CSN, TMCC, and UNLV did not provide evidence of performance of a risk assessment that addresses the three required areas noted in 16 CFR 314.4(b): (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures or that safeguards for such risks had been put in place. Context CSN, TMCC, and UNLV did not provide evidence of a risk assessment or safeguards for associated risks as outlined above. Questioned Costs $0 Effect CSN, TMCC, and UNLV did not demonstrate to us compliance with the risk assessment or safeguard requirements. Cause Exceptions noted were due to lack of formal process in place at CSN, TMCC, and UNLV for a risk assessment to be performed and safeguards to be implemented. Recommendation We recommend CSN, TMCC, and UNLV to perform a risk assessment on the required areas and document the safeguards for the risks identified. Views of Responsible Officials (unaudited) Management concurs.
FINDING 2020-005 ? Special Tests and Provisions: Gramm-Leach Bliley Act ? Student Information Security (Repeat finding 2019-007) Responses CSN - ? 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; CSN has a thorough GLBA Risk Assessment completed at this time. Remediation efforts will be through the planning phase by December 31, 2020. CSN has formed a task force of stakeholders who will implement the required changes to comply with 16 CFR 314, specifically including: o Action plans developed by December 31, 2020; o The annual risk assessment process to be established by January 31, 2021, for completion annually by January 31; o Implementation of recommended controls and mitigation by March 31, 2021. ? How compliance and performance will be measured and documented for future audit, management and performance review. After CSN?s Action Plan is developed by December 2020, CSN will establish its risk assessment process and will update its Risk Assessment Matrix, by no later than January 2021. CSN will implement all recommended controls and mitigation based on the current Risk Assessment Matrix by January 31, 2021. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. CSN?s Chief Information Officer will be responsible for ensuring compliance with the GLBA and student information security. TMCC - ? 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; TMCC has purchased one year of Cyber Security Training through KnowBe4. We conducted a phishing campaign and set a phishing response baseline. Employee training via videos or short presentations were offered through KnowBe4 and distributed by the IT department via their weekly IT News emails. Due to the budget crises caused by the covid-19 pandemic, funds for a continuation of the Knowbe4 subscriptions could not be approved. However, IT continues to inform employees of new events and cyber security risks through weekly IT News messages. IT also works closely with the NSHE CISO and distributes applicable information to TMCC employees. Information sharing and distribution of knowledge about cyber security threats have greatly improved since NSHE?s CISO was hired. Management of employees continues to be mainly dictated by a down-stream flow from Workday (WD). WD dictates which employees are active and which accounts are to be deactivated (termed) through an automated process. This procedure has been in place since WD?s go-live. These processes fall under a yearly IT audit with Grand Thornton and did not produce any reportable findings this year. Information Technology has deployed monitoring software such as SolarWinds to continuously monitor the network and data centers in terms of power, temperature or other failures. In early 2020, the cooling system in the main data center was renewed and a redundant system put in place. In addition, the Dandini campus and the Health Science Center (aka. Redfield campus) have generators in case of power failure. All computers and applicable mobile devices run a computer image created by the IT department. Symantec Endpoint protection and the local firewall are installed and configured by default. IT lately also deployed Malwarebytes to further find malicious software. Due to the remote work of a majority of employees, the firewalls are being kept up meticulously and the Virtual Private Network (VPN) was upgraded to the latest versions. Software applications that used to be widely accessible were moved behind the firewall and employees have to ?VPN in? to access those applications. TMCC uses a desktop management system that allows to push critical updates automatically to all off-site and on-site workstations. In addition, remote access through the IT Customer Service staff allows employees to receive help while working from home. ? How compliance and performance will be measured and documented for future audit, management and performance review. General procedures can be found on the TMCC IT website: https://www.tmcc.edu/information-technology/policies-and-procedures/network-operations-and-security. Additional information and procedures on Information Security can be found here: https://www.tmcc.edu/information-technology/policies-and-procedures/network-operations-and-security ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Chief Technology Officer is the responsible party overseeing the security of student information. UNLV - UNLV agrees with this 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; Although UNLV did engage a consultant to conduct a comprehensive evaluation of GLBA compliance, this assessment itself was not considered by the audit team to serve as the campus?s GLBA risk assessment, but rather a gap analysis. The campus continues to address gaps identified during this process and the campus will bolster our information technology and data security risk assessment using the tools developed by NSHE System Computing Services to support campus?s GLBA compliance efforts to include and address the GLBA-specific requirements. ? How compliance and performance will be measured and documented for future audit, management and performance review. UNLV?s stewards of the student information system, which includes the Vice Provost for Information Technology, the Associate Vice President, Financial Services, and the Associate Vice President for Enrollment & Student Services, meet regularly and have incorporated into a quarterly agenda the review and monitoring of the UNLV GLBA compliance program. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Associate Vice President, Financial Services and the Vice Provost for Information Technology and Associate Vice President for Enrollment & Student Services are responsible for GLBA compliance.
2019-007
FINDING 2020-006 - Verification and Updating of Student Aid Application Information Federal Programs Department of Education Student Financial Assistance Cluster (Various CFDAs) Award year ended June 30, 2020 Criteria 34 CFR 668.59(a) requires that for the subsidized student financial assistance programs, if an applicant's Free Application for Federal Student Aid (FAFSA) information changes as a result of verification, the applicant or the institution must report to the Secretary any changes to - (1) A non-dollar value item; or (2) A single dollar item of $25 or more. Further, 34 CFR 668.57(d) requires that if an applicant is selected to verify other information specified in the annual Federal Register notice, the applicant must provide the documentation specified for that information in the Federal Register notice. Additionally, for Pell recipients, institutions are required to report students? verification status code through Common Origination and Disbursement (COD). Condition UNLV, UNR, and TMCC did not properly and consistently update FAFSA information as a result of the verification process. UNLV did not properly maintain documentation to support updates made to FAFSA information as a result of the verification process. UNLV did not update COD once verification status was complete. Context For six of the sixty students tested at UNLV, the Institution did not properly calculate or update FAFSA information required to be verified. For the first and second instance, a correction was made incorrectly to the US tax paid. For the third and fourth instance, support was not obtained for the corrections made. For the fifth and sixth instance, the household size was incorrect. For two of the sixty students tested at UNLV, the Institution did not update the student?s verification status in COD. For two of sixty students tested at UNR, the Institution improperly recorded the student's income and the parent?s adjusted gross income. For two of the students tested at UNR, the tax return amount was incorrectly recorded. For one out of sixty students tested at TMCC, the Institution did not verify the requirements under V5 verification category but verified under the V4 category, instead. Questioned Costs UNLV - $4,813 UNR - $800 TMCC - $0 Effect UNLV, UNR, and TMCC are not in compliance with federal regulations related to items required for verification. Cause Instances noted at UNLV, UNR, and TMCC were due to oversight failures by personnel performing verification procedures. Recommendation We recommend that UNLV, UNR, and TMCC enhance internal controls to ensure updating of student aid application information is accurate, implement training to ensure verification is being performed accurately and evaluate the existence of these issues of non-compliance in the remaining population and remediate as necessary. Views of Responsible Officials (unaudited) Management concurs
Show full finding ▾Hide full finding ▴FINDING 2020-006 - Verification and Updating of Student Aid Application Information Federal Programs Department of Education Student Financial Assistance Cluster (Various CFDAs) Award year ended June 30, 2020 Criteria 34 CFR 668.59(a) requires that for the subsidized student financial assistance programs, if an applicant's Free Application for Federal Student Aid (FAFSA) information changes as a result of verification, the applicant or the institution must report to the Secretary any changes to - (1) A non-dollar value item; or (2) A single dollar item of $25 or more. Further, 34 CFR 668.57(d) requires that if an applicant is selected to verify other information specified in the annual Federal Register notice, the applicant must provide the documentation specified for that information in the Federal Register notice. Additionally, for Pell recipients, institutions are required to report students? verification status code through Common Origination and Disbursement (COD). Condition UNLV, UNR, and TMCC did not properly and consistently update FAFSA information as a result of the verification process. UNLV did not properly maintain documentation to support updates made to FAFSA information as a result of the verification process. UNLV did not update COD once verification status was complete. Context For six of the sixty students tested at UNLV, the Institution did not properly calculate or update FAFSA information required to be verified. For the first and second instance, a correction was made incorrectly to the US tax paid. For the third and fourth instance, support was not obtained for the corrections made. For the fifth and sixth instance, the household size was incorrect. For two of the sixty students tested at UNLV, the Institution did not update the student?s verification status in COD. For two of sixty students tested at UNR, the Institution improperly recorded the student's income and the parent?s adjusted gross income. For two of the students tested at UNR, the tax return amount was incorrectly recorded. For one out of sixty students tested at TMCC, the Institution did not verify the requirements under V5 verification category but verified under the V4 category, instead. Questioned Costs UNLV - $4,813 UNR - $800 TMCC - $0 Effect UNLV, UNR, and TMCC are not in compliance with federal regulations related to items required for verification. Cause Instances noted at UNLV, UNR, and TMCC were due to oversight failures by personnel performing verification procedures. Recommendation We recommend that UNLV, UNR, and TMCC enhance internal controls to ensure updating of student aid application information is accurate, implement training to ensure verification is being performed accurately and evaluate the existence of these issues of non-compliance in the remaining population and remediate as necessary. Views of Responsible Officials (unaudited) Management concurs
FINDING 2020-006 - Verification and Updating of Student Aid Application Information Response UNLV - Context 1: UNLV agrees with this finding. For the four items involving inaccurate data entry, the attributable cause of these errors resulted from mistyping data manually. The financial aid office recognizes the importance of accuracy and data integrity, but these cases are connected to speed and carelessness. Collaboration with other NSHE campus partners has helped reaffirm the need for accuracy, and we believe this collaboration, along with additional training and management oversight controls will combine to provide improved compliance in the future. For the two items that lacked supporting documentation, the financial aid office made corrections to student records based upon conflicting information and thorough review of available student documents that were available at the time. The root of these errors stemmed from an intentional evaluation where the outcome of the discovered inconsistency would not have been significant enough to change the student?s resulting aid award. We did not seek further documentation to clarify the conflicting information because the discrepancies were small and did not impact the award package. We understand in retrospect, however, these well-intended determinations were erroneous, and we have committed to the inclusion of such documentation moving forward. Context 2: The financial aid office did not properly follow this compliance measure for these two students. The financial aid office recognizes the importance of properly submitting this information to COD, and the office will review the population of students who completed verification and were not part of this sample to be sure the proper COD updates have occurred. ? 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 financial aid office recognizes the importance of accuracy and data integrity. These cases are connected to speed and carelessness. Additional training and management oversight will reinforce the need for accuracy when records are updated as a result of the verification process and to ensure completion includes updating the status to COD. ? How compliance and performance will be measured and documented for future audit, management and performance review. The substance from this finding will be added to the improved training procedures moving forward. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. UNLV has an active recruitment for Assistant Vice President of Financial Aid & Scholarships. The AVP together with the Associate Director for Financial Aid & Scholarships will be responsible for ensuring ongoing compliance. UNR - ? 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. Two exceptions were the result of numbers being transposed; the verification team has received additional training to review numbers more closely, and to specifically look for transposed numbers. The two exceptions that resulted in questioned costs related to complex files with special circumstances, and new training has been created and conducted to ensure that all staff verifying those files are current on the processes and respective calculations. Additionally, in the future a secondary review of files that have special circumstances will be performed. ? How compliance and performance will be measured and documented for future audit, management and performance review. Secondary reviews are documented, and changes to files and related approvals will be tracked. Compliance and performance standards are included in our Policies and Procedures manual, and the verification processes are updated annually based on new federal regulations for the awarding year. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Director of Financial Aid & Scholarships provides oversight of verification processes and is accountable for compliance in this area. TMCC - ? 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; Moving forward, a query will be generated and reviewed to track any changes in the verification flags of students who have been verified. This process went into effect 10/1/2020. ? How compliance and performance will be measured and documented for future audit, management and performance review. The verification team will review a query bi-weekly reviewing the effective date of the institutional student information record (ISIRs) update with respect to what verification to-do list items are posted on the student's account. The Financial Aid Coordinator for Compliance will work with the verification team to ensure that the query is reviewed bi-weekly. Should student's verification flag changes, students will be contacted immediately to submit the additional required documentation for verification, and aid will be cancelled until their verification file is completed. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. Oversight for tracking the changes in students' verification flag will be done by the Financial Aid Coordinator for Compliance, who will ensure that procedures are followed to avoid any future repeats of this error.
FINDING 2020-007 ? Borrower Data Transmission and Reconciliation Federal Programs Department of Education Student Financial Assistance Cluster (Various CFDAs) Award year ended June 30, 2020 Criteria 34 CFR 685.102(b), 685.301 and 303 requires a monthly reconciliation between the Student Account Statement (SAS) provided by ED from COD records and institution?s financial records for all loan disbursements to students. Condition UNLV?s monthly reconciliation process did not include a supervisory review by someone other than the preparer of the reconciliation. Context For the 4 months selected for testing at UNLV, reconciliations were reviewed to ensure that a reconciliation had occurred between institutional records and the SAS provided from the COD. We noticed reconciliations are not reviewed for completeness or accuracy by someone other than the preparer. Questioned Costs UNLV - $0 Effect UNLV has a segregation of duties issue, manifesting from improper review and oversight of the reconciliation function. Cause Instances noted at UNLV were due to a lack of review for completeness and accuracy in the reconciliation process. Recommendation We recommend that UNLV enhance internal controls to ensure a policy is established and that there is evidence documenting that the monthly reconciliation has been reviewed. Views of Responsible Officials (unaudited) Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2020-007 ? Borrower Data Transmission and Reconciliation Federal Programs Department of Education Student Financial Assistance Cluster (Various CFDAs) Award year ended June 30, 2020 Criteria 34 CFR 685.102(b), 685.301 and 303 requires a monthly reconciliation between the Student Account Statement (SAS) provided by ED from COD records and institution?s financial records for all loan disbursements to students. Condition UNLV?s monthly reconciliation process did not include a supervisory review by someone other than the preparer of the reconciliation. Context For the 4 months selected for testing at UNLV, reconciliations were reviewed to ensure that a reconciliation had occurred between institutional records and the SAS provided from the COD. We noticed reconciliations are not reviewed for completeness or accuracy by someone other than the preparer. Questioned Costs UNLV - $0 Effect UNLV has a segregation of duties issue, manifesting from improper review and oversight of the reconciliation function. Cause Instances noted at UNLV were due to a lack of review for completeness and accuracy in the reconciliation process. Recommendation We recommend that UNLV enhance internal controls to ensure a policy is established and that there is evidence documenting that the monthly reconciliation has been reviewed. Views of Responsible Officials (unaudited) Management concurs.
FINDING 2020-007 ? Borrower Data Transmission and Reconciliation Response UNLV - UNLV agrees with this finding. This finding represents a training and communication gap within the department. ? 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; We learned through this finding that a new employee had not been properly trained to serve as a review control in this context. That omission has been corrected, and the individual is aware of that expectation. Further, the financial aid office recognizes the need to share the importance of these systemic controls and oversights so more members of the team are made aware and can identify when these controls break down in the future. ? How compliance and performance will be measured and documented for future audit, management and performance review. The substance from this finding will be added to the improved training procedures moving forward. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. UNLV has an active recruitment for Assistant Vice President of Financial Aid & Scholarships. The AVP together with the Associate Director for Financial Aid & Scholarships will be responsible for ensuring ongoing compliance.
FINDING 2020-008 ? Period of Performance: Costs Charged to Award before Commencement of the Period of Performance Federal Programs Department of Education Education Stabilization Fund ? Higher Education Emergency Relief Fund Institutional Portion (COVID-19) (CFDA 84.425F) Award year ended June 30, 2020 Criteria Pursuant to the Certification and Agreement for the Institutional Portion of the Higher Education Emergency Relief Fund (HEERF), allowable institutional costs must have been first incurred on or after March 13, 2020, the date of the proclamation of national pandemic emergency in order to be attributed to the federal award. Condition In 3 instances in the sample of 40 expenditures tested, UNLV charged costs to the award which were incurred prior to March 13, 2020. Context Of the 40 samples selected for testing at UNLV, 3 samples with costs totaling $537 were incurred prior to March 13, 2020. Questioned Costs UNLV - $537 Effect UNLV has attributed expenses outside of the Period of Performance to the award. Cause The supervisory review of expenses coded to this award failed to detect the error in 3 out of 40 instances tested. Recommendation We recommend that UNLV enhance the effectiveness of supervisory review controls to ensure compliance with federal Period of Performance rules. Views of Responsible Officials (unaudited) Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2020-008 ? Period of Performance: Costs Charged to Award before Commencement of the Period of Performance Federal Programs Department of Education Education Stabilization Fund ? Higher Education Emergency Relief Fund Institutional Portion (COVID-19) (CFDA 84.425F) Award year ended June 30, 2020 Criteria Pursuant to the Certification and Agreement for the Institutional Portion of the Higher Education Emergency Relief Fund (HEERF), allowable institutional costs must have been first incurred on or after March 13, 2020, the date of the proclamation of national pandemic emergency in order to be attributed to the federal award. Condition In 3 instances in the sample of 40 expenditures tested, UNLV charged costs to the award which were incurred prior to March 13, 2020. Context Of the 40 samples selected for testing at UNLV, 3 samples with costs totaling $537 were incurred prior to March 13, 2020. Questioned Costs UNLV - $537 Effect UNLV has attributed expenses outside of the Period of Performance to the award. Cause The supervisory review of expenses coded to this award failed to detect the error in 3 out of 40 instances tested. Recommendation We recommend that UNLV enhance the effectiveness of supervisory review controls to ensure compliance with federal Period of Performance rules. Views of Responsible Officials (unaudited) Management concurs.
FINDING 2020-008 ? Period of Performance: Costs Charged to Award before Commencement of the Period of Performance Response UNLV - ? 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; UNLV agrees with the finding. Due to the timing of this award and the delays and evolution of federal guidance, a number of eligible expenditures were incurred before the award account was available in the financial system. A number of expenditures were reassigned from operating accounts to the award account, and in the process several transactions that had been incurred prior to the award start date of March 13, 2020 were inadvertently reassigned. When this was identified during this audit process, UNLV re-evaluated all transactions that were reassigned through June 30, 2020 to determine if similar errors occurred in addition to the three transactions included in the auditors sample. This review identified nine additional expenditures representing 0.4% of expenditures from this award. All transactions were reversed from the award account. ? How compliance and performance will be measured and documented for future audit, management and performance review. This was an unusual circumstance specific to this award in Spring 2020. Reviewers have been reminded to verify award start dates when reassigning expenditures from operating to award accounts. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. For this award, the Deputy Controller is responsible for ensuring expenditures fall within the period of performance.
FINDING 2020-009 ? Accuracy and Timeliness of Reporting, - of Education Stabilization Fund? Higher Education Emergency Relief Fund Federal Programs Department of Education Education Stabilization Fund ? Higher Education Emergency Relief Fund (HEERF) Student Aid Portion (COVID-19) (CFDA 84.425E) Award year ended June 30, 2020 Criteria ED requires institutions that received the Student Aid Portion of HEERF to publicly post the following information, among others, on their website no later than 30 days after award, and update that information every 45 days thereafter. ? The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the 30-day Report and every 45 days thereafter). ? The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to students under Section 18004(a)(1) of the CARES Act. ? The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act. ? The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act. Condition The total amount of grants distributed to students and the total number of students who had received such grants in UNLV?s 30-day report as posted on its website was not accurate. Moreover, UNLV?s website was not subsequently updated for the next required reporting interval even though new student grants were made during those 45 days after the 30-day report. Context Based on the review of UNLV?s 30-day report as posted on its website, grants distributed to students and the number of students who had received such grants did not match the underlying supporting records of grants distributed to students. Specifically, the reported amount for student grants was $6,691,500 when UNLV?s supporting records showed the amount to be $6,495,000. The number of students who received awards was reported to be 10,185 when UNLV?s supporting records showed 9,884. In addition, no updates were made to these figures for the subsequent 45-day report even though new grants had been made to students during those 45 days. Questioned Costs UNLV - $0 Effect UNLV did not comply with all of ED?s public reporting requirements for student awards originating out of the CARES Act HEERF funds awarded to the institution. As a result, information shared with the public and ED was not entirely accurate and remained static for the subsequent reporting period even though student grant activity resulted in new awards during the subsequent period. Cause Management attributes the reporting error to a miscommunication about reporting requirements for the Student Aid Portion of the HEERF. Recommendation We recommend that UNLV implement controls over ensuring timely updates are made to its website. These controls should involve having an accountable official review pertinent documents supporting the information that will be posted on the website to ensure accurate information is posted. Views of Responsible Officials (unaudited) Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2020-009 ? Accuracy and Timeliness of Reporting, - of Education Stabilization Fund? Higher Education Emergency Relief Fund Federal Programs Department of Education Education Stabilization Fund ? Higher Education Emergency Relief Fund (HEERF) Student Aid Portion (COVID-19) (CFDA 84.425E) Award year ended June 30, 2020 Criteria ED requires institutions that received the Student Aid Portion of HEERF to publicly post the following information, among others, on their website no later than 30 days after award, and update that information every 45 days thereafter. ? The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the 30-day Report and every 45 days thereafter). ? The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to students under Section 18004(a)(1) of the CARES Act. ? The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act. ? The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act. Condition The total amount of grants distributed to students and the total number of students who had received such grants in UNLV?s 30-day report as posted on its website was not accurate. Moreover, UNLV?s website was not subsequently updated for the next required reporting interval even though new student grants were made during those 45 days after the 30-day report. Context Based on the review of UNLV?s 30-day report as posted on its website, grants distributed to students and the number of students who had received such grants did not match the underlying supporting records of grants distributed to students. Specifically, the reported amount for student grants was $6,691,500 when UNLV?s supporting records showed the amount to be $6,495,000. The number of students who received awards was reported to be 10,185 when UNLV?s supporting records showed 9,884. In addition, no updates were made to these figures for the subsequent 45-day report even though new grants had been made to students during those 45 days. Questioned Costs UNLV - $0 Effect UNLV did not comply with all of ED?s public reporting requirements for student awards originating out of the CARES Act HEERF funds awarded to the institution. As a result, information shared with the public and ED was not entirely accurate and remained static for the subsequent reporting period even though student grant activity resulted in new awards during the subsequent period. Cause Management attributes the reporting error to a miscommunication about reporting requirements for the Student Aid Portion of the HEERF. Recommendation We recommend that UNLV implement controls over ensuring timely updates are made to its website. These controls should involve having an accountable official review pertinent documents supporting the information that will be posted on the website to ensure accurate information is posted. Views of Responsible Officials (unaudited) Management concurs.
FINDING 2020-009 ? Accuracy and Timeliness of Reporting, - of Education Stabilization Fund? Higher Education Emergency Relief Fund Response UNLV - ? 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; UNLV agrees with this finding. Efforts were focused on the disbursements to students and the reporting deadline was missed. Due to several changes in guidance in the short time period between the legislative authorization and June 30, 2020, UNLV had to make several adjustments to disbursement methodology. As a result of this changing guidance, UNLV had to make estimates for its initial report as adjustments to actual disbursements were anticipated. Reports have since been updated and posted to the website at the end of each month in order to maintain reporting updates within the 45 day reporting period requirement. ? How compliance and performance will be measured and documented for future audit, management and performance review. The reporting requirements are now well understood and a standard reporting template has been developed that is being used for ongoing updates. Staff will continue to monitor the guidance for reporting requirements and will modify the reporting template if needed. ? Who will be responsible and may be held accountable in the future if repeat or similar observations are noted. The Executive Director for Financial Aid and Scholarships is responsible for ensuring compliance with the HEERF student financial assistance reporting requirements.
FAC accepted this audit on December 17, 2019 — management decision was due June 17, 2020.
FINDING 2019-002 - Internal Control over Compliance (Repeat Finding 2018-003, 2017-002, 2015-002, 2014-008) The estimated completion date for 2019-002 ? January 31, 2020 NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education and Department of Health and Human Services Student Financial Assistance Cluster Award year ended June 30, 2019 Criteria 2 CFR 200.303(a) requires that non-Federal entities receiving Federal awards establish and maintain effective internal control over the Federal award to provide reasonable assurance that they are managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition At the University of Nevada, Reno (?UNR?), University of Nevada, Las Vegas (?UNLV?) and System Computing Services (?SCS?), we noted deficiencies in security administration related to the information technology general controls (?ITGCs?) in the PeopleSoft application. Specifically, controls were lacking around restriction of elevated access, user access reviews, termination of access and segregation of duties as it relates to the PeopleSoft application over the student financial assistance program. Context During our testing of the ITGCs in the PeopleSoft application, we noted the following segregation of duties issues: (1) At UNLV and SCS, several users have both PeopleSoft Administrator rights within the Production and Development environment; (2) At UNLV, three users have both PeopleSoft PeopleTool administrator rights within the Production and Development environment which allows them to modify PS objects and perform change management duties; (3) At UNLV, management identified a segregation of duties conflict in PeopleSoft such that employees could access and change student data that they should not have been able to (4) At UNR, four users have both PeopleSoft Administrator rights within the Production and Development environment; (5) At UNR, two terminated employees had their PeopleSoft application access removed in an untimely manner (more than 48 hours from date of termination per records from human resources). (6) At SCS, no user access reviews were performed during the audit period for the PeopleSoft application, Oracle Database or Microsoft AIX Sever. (7) At SCS, two users have both PeopleSoft PeopleTool administrator rights within the Production and Development environment which allows them to modify PS objects and perform change management duties. The deficiencies in security administration controls could impact compliance requirements related to determining eligibility, disbursements, return of Title IV funds and verification. Questioned Costs UNLV - $42,532 Effect 1. Security Administration (#4 & #5)-Student data within the PeopleSoft application may be accessed by unauthorized or inappropriate individuals. This could impact eligibility, disbursements, return of Title IV funds and verification. 2. Change Management (#1-3, #6 & #7)-Student data within the PeopleSoft application may be affected by users having conflicting roles or access levels, and accountability may not be established. Student data may be affected by unauthorized, inappropriate, or untested changes to the system. This could impact eligibility, disbursements, return of Title IV funds and verification. Cause The issues identified are part of the lack of effective ITGCs in the PeopleSoft application. Recommendation 1. Security Administration (#4 & #5) - #4-Management should ensure that terminated users have their application(s) access removed in a timely manner (industry standard is typically 48 hours). #5-Management should conduct user access reviews on a periodic basis to ensure appropriateness of access rights of users within key financial applications. 2. Change Management(#1-3, #6 & #7)-Management should segregate duties and remove users with access to both the Development and Production environments (limiting them to be able to access just one environment) or implement a formal review process over the activities performed by those responsible for program maintenance on a periodic basis. Views of Responsible Officials Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2019-002 - Internal Control over Compliance (Repeat Finding 2018-003, 2017-002, 2015-002, 2014-008) The estimated completion date for 2019-002 ? January 31, 2020 NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education and Department of Health and Human Services Student Financial Assistance Cluster Award year ended June 30, 2019 Criteria 2 CFR 200.303(a) requires that non-Federal entities receiving Federal awards establish and maintain effective internal control over the Federal award to provide reasonable assurance that they are managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition At the University of Nevada, Reno (?UNR?), University of Nevada, Las Vegas (?UNLV?) and System Computing Services (?SCS?), we noted deficiencies in security administration related to the information technology general controls (?ITGCs?) in the PeopleSoft application. Specifically, controls were lacking around restriction of elevated access, user access reviews, termination of access and segregation of duties as it relates to the PeopleSoft application over the student financial assistance program. Context During our testing of the ITGCs in the PeopleSoft application, we noted the following segregation of duties issues: (1) At UNLV and SCS, several users have both PeopleSoft Administrator rights within the Production and Development environment; (2) At UNLV, three users have both PeopleSoft PeopleTool administrator rights within the Production and Development environment which allows them to modify PS objects and perform change management duties; (3) At UNLV, management identified a segregation of duties conflict in PeopleSoft such that employees could access and change student data that they should not have been able to (4) At UNR, four users have both PeopleSoft Administrator rights within the Production and Development environment; (5) At UNR, two terminated employees had their PeopleSoft application access removed in an untimely manner (more than 48 hours from date of termination per records from human resources). (6) At SCS, no user access reviews were performed during the audit period for the PeopleSoft application, Oracle Database or Microsoft AIX Sever. (7) At SCS, two users have both PeopleSoft PeopleTool administrator rights within the Production and Development environment which allows them to modify PS objects and perform change management duties. The deficiencies in security administration controls could impact compliance requirements related to determining eligibility, disbursements, return of Title IV funds and verification. Questioned Costs UNLV - $42,532 Effect 1. Security Administration (#4 & #5)-Student data within the PeopleSoft application may be accessed by unauthorized or inappropriate individuals. This could impact eligibility, disbursements, return of Title IV funds and verification. 2. Change Management (#1-3, #6 & #7)-Student data within the PeopleSoft application may be affected by users having conflicting roles or access levels, and accountability may not be established. Student data may be affected by unauthorized, inappropriate, or untested changes to the system. This could impact eligibility, disbursements, return of Title IV funds and verification. Cause The issues identified are part of the lack of effective ITGCs in the PeopleSoft application. Recommendation 1. Security Administration (#4 & #5) - #4-Management should ensure that terminated users have their application(s) access removed in a timely manner (industry standard is typically 48 hours). #5-Management should conduct user access reviews on a periodic basis to ensure appropriateness of access rights of users within key financial applications. 2. Change Management(#1-3, #6 & #7)-Management should segregate duties and remove users with access to both the Development and Production environments (limiting them to be able to access just one environment) or implement a formal review process over the activities performed by those responsible for program maintenance on a periodic basis. Views of Responsible Officials Management concurs.
NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu 2019-002 ? January 31, 2020
2018-003
FINDING 2019-003 - Special Tests and Provisions: Return of Title IV funds for withdrawn students (Repeat finding 2018-005, 2017-004, 2016-003, 2015-004, 2014-011) The estimated completion date for 2019-003 - Immediately implemented NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education Student Financial Assistance Cluster Award year ended June 30, 2019 Criteria Pursuant to the 34 CFR 668.22(j)(2), an institution is required to determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew to allow for the timely calculation and return of Title IV funds as required. Pursuant to the 34CFR 668.22(e) an institution is required to calculate the amount of title IV assistance earned by the student once the institution has determined the withdrawal date in accordance with the 34 CFR 668.22(j), and pursuant to the 34 CFR 668.22(g), an institution is required to calculate and return unearned aid in the order as required: the lesser of the total amount of unearned Title IV assistance to be returned as calculated under 34 CFR 668.22(e)(4); or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student, as described in 34 CFR 668.22(e)(3). Pursuant to the 34 CFR 690.83(b)(2) an institution shall submit, in accordance with deadline dates established by the U.S. Department of Education (Secretary), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Pursuant to 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon, but no later than 45 days, after the date of the institution's determination that the student withdrew. Condition During our testing at Nevada State College (?NSC?), TMCC, UNLV, UNR, and Western Nevada College (?WNC?), and we identified instances where the Institutions did not complete the return of Title IV funds as calculated within the 45 day requirement as noted in the Federal Regulations and where the amount to return was not calculated correctly in accordance with Federal Regulations. During our testing at UNLV, we identified instances where the Intuition did not determine the withdrawal date for students who unofficially withdrew from the Institution within 30 days of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. Context For one out of sixty students tested at NSC, the original return calculation was incorrect and subsequently remediated by the quality control review, however, the date the institution returned and reported the amount as calculated exceeded the required 45 day timeframe. For one out of sixty students tested at TMCC, the institution did not identify an authorized change in the withdrawal date resulting in the incorrect withdrawal date used in the return of Title IV funds calculation. For two out of sixty students tested at TMCC and for two out of sixty students tested at WNC, the calculation of days used within the return of Title IV funds calculation was incorrect, and therefore the calculation for the return of Title IV funds on the student ?Return of Title IV? form was incorrect. For thirteen of sixty students tested at UNLV and for one out of sixty students tested at UNR, the funds to be returned were not returned and reported within the 45 day timeframe. For eleven of sixty students tested at UNLV, the institution did not determine a Return to Title IV calculation needed to be performed within the 30 day timeframe. For one of sixty students tested at UNLV, the incorrect Total TIV Aid amount was used on the student ?Return of Title IV? form. Questioned Costs NSC - $0 TMCC - $416 UNLV - $7,586 UNR - $0 WNC - $6 Effect At NSC, TMCC, UNR, UNLV, and WNC, the return of Title IV funds as calculated and applied to the individual student's account at each Institution was not reported to Common Origination and Disbursement (?COD?) timely and accurately. Cause At TMCC, UNR, UNLV, and WNC, the funds not being timely returned and reported to COD as calculated was due to oversight by personnel performing the return calculation. For UNLV, our sample was limited to sixty students, however it is our understanding that the delay in determination date for students who require a Return to Title IV calculation is a broader issue. Of the students identified with a delayed determination date, a majority were students who withdrew or dropped out during the Fall 2018 term. At NSC, the incorrect calculation, reporting, and return of funds was corrected during quality control review, however, the funds were not timely returned and reported to COD within the required timeframe. Recommendation We recommend that TMCC, UNR, UNLV, and WNC enhance internal controls to improve the accuracy of reporting to COD. We recommend that NSC enhance internal controls and the return of title four funds process to ensure that it is sufficient to timely determine the accuracy of reporting to COD. We recommend that UNLV enhances internal controls to improve the timing of determining if a student requires a Return to Title IV calculation. We also recommend that UNLV review all Fall 2018 students to identify any students that may need a Return of Title IV calculation performed. Views of Responsible Officials Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2019-003 - Special Tests and Provisions: Return of Title IV funds for withdrawn students (Repeat finding 2018-005, 2017-004, 2016-003, 2015-004, 2014-011) The estimated completion date for 2019-003 - Immediately implemented NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education Student Financial Assistance Cluster Award year ended June 30, 2019 Criteria Pursuant to the 34 CFR 668.22(j)(2), an institution is required to determine the withdrawal date for a student who withdraws without providing notification to the institution no later than 30 days after the end of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew to allow for the timely calculation and return of Title IV funds as required. Pursuant to the 34CFR 668.22(e) an institution is required to calculate the amount of title IV assistance earned by the student once the institution has determined the withdrawal date in accordance with the 34 CFR 668.22(j), and pursuant to the 34 CFR 668.22(g), an institution is required to calculate and return unearned aid in the order as required: the lesser of the total amount of unearned Title IV assistance to be returned as calculated under 34 CFR 668.22(e)(4); or an amount equal to the total institutional charges incurred by the student for the payment period or period of enrollment multiplied by the percentage of Title IV grant or loan assistance that has not been earned by the student, as described in 34 CFR 668.22(e)(3). Pursuant to the 34 CFR 690.83(b)(2) an institution shall submit, in accordance with deadline dates established by the U.S. Department of Education (Secretary), through publication in the Federal Register, other reports and information the Secretary requires and shall comply with the procedures the Secretary finds necessary to ensure that the reports are correct. Pursuant to 34 CFR 668.22(j)(1), an institution must return the amount of Title IV funds for which it is responsible as soon, but no later than 45 days, after the date of the institution's determination that the student withdrew. Condition During our testing at Nevada State College (?NSC?), TMCC, UNLV, UNR, and Western Nevada College (?WNC?), and we identified instances where the Institutions did not complete the return of Title IV funds as calculated within the 45 day requirement as noted in the Federal Regulations and where the amount to return was not calculated correctly in accordance with Federal Regulations. During our testing at UNLV, we identified instances where the Intuition did not determine the withdrawal date for students who unofficially withdrew from the Institution within 30 days of the earlier of the (1) payment period or period of enrollment, (2) academic year in which the student withdrew, or (3) educational program from which the student withdrew. Context For one out of sixty students tested at NSC, the original return calculation was incorrect and subsequently remediated by the quality control review, however, the date the institution returned and reported the amount as calculated exceeded the required 45 day timeframe. For one out of sixty students tested at TMCC, the institution did not identify an authorized change in the withdrawal date resulting in the incorrect withdrawal date used in the return of Title IV funds calculation. For two out of sixty students tested at TMCC and for two out of sixty students tested at WNC, the calculation of days used within the return of Title IV funds calculation was incorrect, and therefore the calculation for the return of Title IV funds on the student ?Return of Title IV? form was incorrect. For thirteen of sixty students tested at UNLV and for one out of sixty students tested at UNR, the funds to be returned were not returned and reported within the 45 day timeframe. For eleven of sixty students tested at UNLV, the institution did not determine a Return to Title IV calculation needed to be performed within the 30 day timeframe. For one of sixty students tested at UNLV, the incorrect Total TIV Aid amount was used on the student ?Return of Title IV? form. Questioned Costs NSC - $0 TMCC - $416 UNLV - $7,586 UNR - $0 WNC - $6 Effect At NSC, TMCC, UNR, UNLV, and WNC, the return of Title IV funds as calculated and applied to the individual student's account at each Institution was not reported to Common Origination and Disbursement (?COD?) timely and accurately. Cause At TMCC, UNR, UNLV, and WNC, the funds not being timely returned and reported to COD as calculated was due to oversight by personnel performing the return calculation. For UNLV, our sample was limited to sixty students, however it is our understanding that the delay in determination date for students who require a Return to Title IV calculation is a broader issue. Of the students identified with a delayed determination date, a majority were students who withdrew or dropped out during the Fall 2018 term. At NSC, the incorrect calculation, reporting, and return of funds was corrected during quality control review, however, the funds were not timely returned and reported to COD within the required timeframe. Recommendation We recommend that TMCC, UNR, UNLV, and WNC enhance internal controls to improve the accuracy of reporting to COD. We recommend that NSC enhance internal controls and the return of title four funds process to ensure that it is sufficient to timely determine the accuracy of reporting to COD. We recommend that UNLV enhances internal controls to improve the timing of determining if a student requires a Return to Title IV calculation. We also recommend that UNLV review all Fall 2018 students to identify any students that may need a Return of Title IV calculation performed. Views of Responsible Officials Management concurs.
NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu 2019-003 - Immediately implemented
2018-005
FINDING 2019-004 ? Special Tests and Provisions and Reporting: Pell Disbursements are not Submitted Timely to the Department of Education via the Common Origination and Disbursement (?COD?) (Repeat finding 2018-006 and 2017-006) The estimated completion date for 2019-004 - Immediately implemented NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education Student Financial Assistance Cluster Award year ended June 30, 2019 Criteria 34 CFR 690.83 (b)(1) states that a school shall report to the Secretary any change in the amount of a Pell grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. OMB No. 1845-0039 requires that Institutions report all loan disbursements and submit Pell Payment Data to the Department of Education via Common Origination and Disbursement (?COD?) within 15 days of disbursement Condition During our testing at CSN, NSC, UNLV and WNC, we identified instances where the Institutions did not report Pell payment data to the Department of Education via COD within 15 days. Context For one out of sixty students selected for testing at each school mentioned above, the Institutions did not report disbursement of Pell payment data to COD within the required timeframe. Questioned Costs CSN - $0 NSC - $0 UNLV - $0 WNC - $0 Effect CSN, NSC, UNLV, and WNC are not in compliance with federal regulations related to submitting required records to Department of Education via COD within 15 days. Cause For each of the Institutions, all instances related to certain disbursements which were not reported within 15 days due to an error in the original upload that was intended to be completed within the required timeframe. Recommendation We recommend that CSN, NSC, UNLV and WNC enhance internal controls to improve the accuracy of reporting to the COD reporting system. Management should evaluate the existence of this issue of non- compliance in the remaining population and ensure queries within PeopleSoft are adequate to meet the federal requirements. Views of Responsible Officials Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2019-004 ? Special Tests and Provisions and Reporting: Pell Disbursements are not Submitted Timely to the Department of Education via the Common Origination and Disbursement (?COD?) (Repeat finding 2018-006 and 2017-006) The estimated completion date for 2019-004 - Immediately implemented NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education Student Financial Assistance Cluster Award year ended June 30, 2019 Criteria 34 CFR 690.83 (b)(1) states that a school shall report to the Secretary any change in the amount of a Pell grant for which a student qualifies including any related Payment Data changes by submitting to the Secretary the student's Payment Data that discloses the basis and result of the change in award for each student. The institution shall submit the student's Payment Data reporting any change to the Secretary by the reporting deadlines published by the Secretary in the Federal Register. OMB No. 1845-0039 requires that Institutions report all loan disbursements and submit Pell Payment Data to the Department of Education via Common Origination and Disbursement (?COD?) within 15 days of disbursement Condition During our testing at CSN, NSC, UNLV and WNC, we identified instances where the Institutions did not report Pell payment data to the Department of Education via COD within 15 days. Context For one out of sixty students selected for testing at each school mentioned above, the Institutions did not report disbursement of Pell payment data to COD within the required timeframe. Questioned Costs CSN - $0 NSC - $0 UNLV - $0 WNC - $0 Effect CSN, NSC, UNLV, and WNC are not in compliance with federal regulations related to submitting required records to Department of Education via COD within 15 days. Cause For each of the Institutions, all instances related to certain disbursements which were not reported within 15 days due to an error in the original upload that was intended to be completed within the required timeframe. Recommendation We recommend that CSN, NSC, UNLV and WNC enhance internal controls to improve the accuracy of reporting to the COD reporting system. Management should evaluate the existence of this issue of non- compliance in the remaining population and ensure queries within PeopleSoft are adequate to meet the federal requirements. Views of Responsible Officials Management concurs.
NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu 2019-004 - Immediately implemented
2018-006
FINDING 2019-005 ? Special Tests and Provisions: Disbursements To or On Behalf of Students (Repeat Finding 2018-007, 2016-004, 2015-009) The estimated completion date for 2019-005 - Immediately implemented NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education Student Financial Assistance Cluster Award year ended June 30, 2019 Criteria Pursuant to 34 CFR 668.164(h)(1)and(2), a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to the student?s ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period as provided under paragraph (c). A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible but no later than, (i) fourteen days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) fourteen day s after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Pursuant to 34 CFR 668.164(i)(2), an institution may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5). Condition During our testing at CSN and TMCC, we identified instances where the Institutions did not return a credit balance on the students? account within the 14 day requirement. During our testing at CSN, we identified an instance where the Institution disbursed a Direct Loan to a first- year, first-time borrower prior to the 30-day delayed disbursement requirement. Context For one student out of sixty selected for testing at TMCC and CSN each, the Institutions did not return a credit balance to the student within the 14 day requirement. For one student out of sixty selected for testing at CSN, the Institution disbursed a Direct Loan to a first-year, first-time borrower prior to 30 days after the first day of class. Questioned Costs TMCC - $19 CSN - $178 Effect TMCC and CSN did not consistently comply with the specific requirements of Federal Regulations with respect to the return of student funds. CSN did not consistently comply with the specific requirements of Federal Regulations with respect to the disbursement of student funds. Cause For TMCC and CSN, the return of student funds did not occur within the required period due to oversight of responsible personnel. For CSN, the disbursement of student funds did not occur within the required period due to oversight of responsible personnel. Recommendation We recommend that TMCC enhances controls to ensure the required monitoring and return of student funds occurs within the required period. We recommend that CSN enhances controls to ensure the required monitoring, disbursement, and return of student funds occurs within the required period. Views of Responsible Officials Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2019-005 ? Special Tests and Provisions: Disbursements To or On Behalf of Students (Repeat Finding 2018-007, 2016-004, 2015-009) The estimated completion date for 2019-005 - Immediately implemented NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education Student Financial Assistance Cluster Award year ended June 30, 2019 Criteria Pursuant to 34 CFR 668.164(h)(1)and(2), a title IV, HEA credit balance occurs whenever the amount of title IV, HEA program funds credited to the student?s ledger account for a payment period exceeds the amount assessed the student for allowable charges associated with that payment period as provided under paragraph (c). A title IV, HEA credit balance must be paid directly to the student or parent as soon as possible but no later than, (i) fourteen days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or (ii) fourteen day s after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period. Pursuant to 34 CFR 668.164(i)(2), an institution may not make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5). Condition During our testing at CSN and TMCC, we identified instances where the Institutions did not return a credit balance on the students? account within the 14 day requirement. During our testing at CSN, we identified an instance where the Institution disbursed a Direct Loan to a first- year, first-time borrower prior to the 30-day delayed disbursement requirement. Context For one student out of sixty selected for testing at TMCC and CSN each, the Institutions did not return a credit balance to the student within the 14 day requirement. For one student out of sixty selected for testing at CSN, the Institution disbursed a Direct Loan to a first-year, first-time borrower prior to 30 days after the first day of class. Questioned Costs TMCC - $19 CSN - $178 Effect TMCC and CSN did not consistently comply with the specific requirements of Federal Regulations with respect to the return of student funds. CSN did not consistently comply with the specific requirements of Federal Regulations with respect to the disbursement of student funds. Cause For TMCC and CSN, the return of student funds did not occur within the required period due to oversight of responsible personnel. For CSN, the disbursement of student funds did not occur within the required period due to oversight of responsible personnel. Recommendation We recommend that TMCC enhances controls to ensure the required monitoring and return of student funds occurs within the required period. We recommend that CSN enhances controls to ensure the required monitoring, disbursement, and return of student funds occurs within the required period. Views of Responsible Officials Management concurs.
NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu 2019-005 - Immediately implemented
2018-007
FINDING 2019-006 ? Special Tests and Provisions: Enrollment Reporting (Repeat finding 2018-008 2016-002, 2015-006, 2014-012) The estimated completion date for 2019-006 - Immediately implemented NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education Student Financial Assistance Cluster (Federal Direct Student Loans, CFDA 84.268) Award year ended June 30, 2019 Criteria Pursuant to 34 CFR 685.309(b), upon receipt of a student status confirmation report from the Secretary, an institution must complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who: (i) Enrolled at that school but has ceased to be enrolled on at least a half-time basis; (ii) Has been accepted for enrollment at that school but failed to enroll on at least a half-time basis for the period which the loan was intended; or has changed his or her permanent address. Condition We noted CSN did not report student status changes to the National Student Loan Data System (?NSLDS?) within 30 days, or within 60 days when it expected to submit its next student status confirmation report within that time period, of the change as required by the regulations. Context For one of sixty students tested at CSN, the student?s changed enrollment status was not reported to NSLDS within the 30 day or 60 day requirements noted above. Specifically, the student?s graduated status was not properly uploaded to NSLDS. Questioned Costs CSN - $0 Effect CSN did not comply with the specific requirements of Federal Regulations with respect to student status communications to the Secretary. Cause Exceptions noted at CSN were due to oversight by personnel performing enrollment reporting procedures and improper review of population uploads to NSLDS. Recommendation We recommend that CSN develop policies and procedures to ensure student status changes are uploaded timely and correctly to NSLDS. Additionally, we recommend that the Institution review the remaining population of students and as well as student classifications to ensure that all are being properly reported. Views of Responsible Officials Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2019-006 ? Special Tests and Provisions: Enrollment Reporting (Repeat finding 2018-008 2016-002, 2015-006, 2014-012) The estimated completion date for 2019-006 - Immediately implemented NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education Student Financial Assistance Cluster (Federal Direct Student Loans, CFDA 84.268) Award year ended June 30, 2019 Criteria Pursuant to 34 CFR 685.309(b), upon receipt of a student status confirmation report from the Secretary, an institution must complete and return that report to the Secretary within 30 days of receipt; and unless it expects to submit its next student status confirmation report to the Secretary within the next 60 days, notify the Secretary within 30 days if it discovers that a Direct Subsidized, Direct Unsubsidized, or Direct PLUS Loan has been made to or on behalf of a student who: (i) Enrolled at that school but has ceased to be enrolled on at least a half-time basis; (ii) Has been accepted for enrollment at that school but failed to enroll on at least a half-time basis for the period which the loan was intended; or has changed his or her permanent address. Condition We noted CSN did not report student status changes to the National Student Loan Data System (?NSLDS?) within 30 days, or within 60 days when it expected to submit its next student status confirmation report within that time period, of the change as required by the regulations. Context For one of sixty students tested at CSN, the student?s changed enrollment status was not reported to NSLDS within the 30 day or 60 day requirements noted above. Specifically, the student?s graduated status was not properly uploaded to NSLDS. Questioned Costs CSN - $0 Effect CSN did not comply with the specific requirements of Federal Regulations with respect to student status communications to the Secretary. Cause Exceptions noted at CSN were due to oversight by personnel performing enrollment reporting procedures and improper review of population uploads to NSLDS. Recommendation We recommend that CSN develop policies and procedures to ensure student status changes are uploaded timely and correctly to NSLDS. Additionally, we recommend that the Institution review the remaining population of students and as well as student classifications to ensure that all are being properly reported. Views of Responsible Officials Management concurs.
NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu 2019-006 - Immediately implemented
2018-008
FINDING 2019-007 ? Special Tests and Provisions: Gramm-Leach Bliley Act ? Student Information Security The estimated completion date for 2019-007 - December 31, 2020 NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education Student Financial Assistance Cluster Award year ended June 30, 2019 Criteria 16 CFR 314.1, which implements sections 501 and 505(b)(2) of the Gramm-Leach-Bliley Act, sets forth standards for developing, implementing, and maintaining reasonable administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information. Condition We noted CSN, TMCC, UNLV and WNC did not provide evidence of performance of a risk assessment that addresses the three required areas noted in 16 CFR 314.4(b): (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures or that safeguards for such risks had been put in place. Context CSN, TMCC, and UNLV did not provide evidence of a risk assessment or safeguards for associated risks as outlined above. We obtained from WNC a ?GLBA Assessment Report?, which outlined the current controls in place and documented the compliance status. The report noted WNC was not in compliance with GLBA as it did not perform a risk assessment as required by GLBA. A risk assessment was not created during the audit period. Questioned Costs $0 Effect CSN, TMCC, UNLV and WNC did not demonstrate to us compliance with the risk assessment or safeguard requirements. Cause Exceptions noted were due to lack of formal process in place at CSN, TMCC, UNLV and WNC for a risk assessment to be performed and safeguards to be implemented. Recommendation We recommend CSN, TMCC, and UNLV to perform a risk assessment on the required areas and document the safeguards for the risks identified. We recommend WNC use the third-party gap assessment report as a baseline and perform a risk assessment on the required areas and document safeguards on the risks identified. Views of Responsible Officials Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2019-007 ? Special Tests and Provisions: Gramm-Leach Bliley Act ? Student Information Security The estimated completion date for 2019-007 - December 31, 2020 NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education Student Financial Assistance Cluster Award year ended June 30, 2019 Criteria 16 CFR 314.1, which implements sections 501 and 505(b)(2) of the Gramm-Leach-Bliley Act, sets forth standards for developing, implementing, and maintaining reasonable administrative, technical, and physical safeguards to protect the security, confidentiality, and integrity of customer information. Condition We noted CSN, TMCC, UNLV and WNC did not provide evidence of performance of a risk assessment that addresses the three required areas noted in 16 CFR 314.4(b): (1) Employee training and management; (2) Information systems, including network and software design, as well as information processing, storage, transmission and disposal; and (3) Detecting, preventing and responding to attacks, intrusions, or other systems failures or that safeguards for such risks had been put in place. Context CSN, TMCC, and UNLV did not provide evidence of a risk assessment or safeguards for associated risks as outlined above. We obtained from WNC a ?GLBA Assessment Report?, which outlined the current controls in place and documented the compliance status. The report noted WNC was not in compliance with GLBA as it did not perform a risk assessment as required by GLBA. A risk assessment was not created during the audit period. Questioned Costs $0 Effect CSN, TMCC, UNLV and WNC did not demonstrate to us compliance with the risk assessment or safeguard requirements. Cause Exceptions noted were due to lack of formal process in place at CSN, TMCC, UNLV and WNC for a risk assessment to be performed and safeguards to be implemented. Recommendation We recommend CSN, TMCC, and UNLV to perform a risk assessment on the required areas and document the safeguards for the risks identified. We recommend WNC use the third-party gap assessment report as a baseline and perform a risk assessment on the required areas and document safeguards on the risks identified. Views of Responsible Officials Management concurs.
NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu 2019-007 - December 31, 2020
FINDING 2019-008 ? Eligibility The estimated completion date for 2019-008 - Immediately implemented NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education Student Financial Assistance Cluster Award year ended June 30, 2019 Criteria A school is required to determine whether a student is eligible for federal aid under the eligibility rules described in 34 CFR 668.32. A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of 34 CFR 668.32 or meets the requirement in paragraph (n) of 34 CFR 668.32. Pursuant 34 CFR 668.32(f), a student must maintain satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of 34 CFR 668.34. Pursuant 34 CFR 668.32 (g), a student is eligible if he/she has not obtained loan amounts that exceed annual or aggregate loan limits made under any title IV, HEA loan program. Additionally, each year, based on the maximum Pell Grant established by Congress, ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment or Disbursement Schedule provides the maximum annual amount a student would receive for a full academic year for a given enrollment status, EFC and COA. The Payment Schedule is used to determine the annual award for a full-time student. There are separate Disbursement Schedules for three-quarter time, half-time, and less-than-half-time students. Condition We noted at UNLV instances where student were awarded aid who were not eligible to receive the aid disbursed or were not awarded and disbursed they were entitled to. Context For one out of sixty students tested at UNLV, a student was awarded aid for Summer 2019 when satisfactory academic progress requirements were not met for the previous term. For three out of seventy-five students tested at UNLV, Pell was calculated using the incorrect Disbursement Schedule. For one out of sixty students tested at UNLV, a student was awarded and disbursed a Subsidized Direct Loan which exceeded the aggregate limit of $23,000. Questioned Costs UNLV - $6,516 Effect UNLV did not comply with the specific requirements of Federal Regulations with respect to student eligibility and awarded aid over and above in which students were entitled. Cause Exceptions noted at UNLV were due to oversight and an improper review function by personnel packaging aid for students. Recommendation We recommend that UNLV enhance controls to ensure aid is packaged and disbursed to eligible students, with a timely review process by a director. Views of Responsible Officials Management concurs.
Show full finding ▾Hide full finding ▴FINDING 2019-008 ? Eligibility The estimated completion date for 2019-008 - Immediately implemented NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu Federal Programs Department of Education Student Financial Assistance Cluster Award year ended June 30, 2019 Criteria A school is required to determine whether a student is eligible for federal aid under the eligibility rules described in 34 CFR 668.32. A student is eligible to receive Title IV, HEA program assistance if the student either meets all of the requirements in paragraphs (a) through (m) of 34 CFR 668.32 or meets the requirement in paragraph (n) of 34 CFR 668.32. Pursuant 34 CFR 668.32(f), a student must maintain satisfactory academic progress in his or her course of study according to the institution's published standards of satisfactory academic progress that meet the requirements of 34 CFR 668.34. Pursuant 34 CFR 668.32 (g), a student is eligible if he/she has not obtained loan amounts that exceed annual or aggregate loan limits made under any title IV, HEA loan program. Additionally, each year, based on the maximum Pell Grant established by Congress, ED provides to institutions Payment and Disbursement Schedules for determining Pell awards. The Payment or Disbursement Schedule provides the maximum annual amount a student would receive for a full academic year for a given enrollment status, EFC and COA. The Payment Schedule is used to determine the annual award for a full-time student. There are separate Disbursement Schedules for three-quarter time, half-time, and less-than-half-time students. Condition We noted at UNLV instances where student were awarded aid who were not eligible to receive the aid disbursed or were not awarded and disbursed they were entitled to. Context For one out of sixty students tested at UNLV, a student was awarded aid for Summer 2019 when satisfactory academic progress requirements were not met for the previous term. For three out of seventy-five students tested at UNLV, Pell was calculated using the incorrect Disbursement Schedule. For one out of sixty students tested at UNLV, a student was awarded and disbursed a Subsidized Direct Loan which exceeded the aggregate limit of $23,000. Questioned Costs UNLV - $6,516 Effect UNLV did not comply with the specific requirements of Federal Regulations with respect to student eligibility and awarded aid over and above in which students were entitled. Cause Exceptions noted at UNLV were due to oversight and an improper review function by personnel packaging aid for students. Recommendation We recommend that UNLV enhance controls to ensure aid is packaged and disbursed to eligible students, with a timely review process by a director. Views of Responsible Officials Management concurs.
NSHE is a multi-institutional organization and corrective actions are coordinated centrally through: Rhett R. Vertrees, CPA Assistant Chief Financial Officer (775)784-3409 rvertrees@nshe.nevada.edu 2019-008 - Immediately implemented
FAC accepted this audit on January 28, 2019 — management decision was due July 28, 2019.
GSA_MIGRATION
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2017-002, 2015-002, 2014-008
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2017-003, 2016-001, 2015-003, 2014-010
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2017-004, 2016-003, 2015-004, 2014-011
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GSA_MIGRATION
2017-005
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2016-004, 2015-009
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GSA_MIGRATION
2016-002, 2015-006, 2014-012
GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on November 28, 2017 — management decision was due May 28, 2018.
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2015-002, 2014-008
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2016-001, 2015-003, 2014-010
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GSA_MIGRATION
2016-003, 2015-004, 2014-011
GSA_MIGRATION
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GSA_MIGRATION
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GSA_MIGRATION
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GSA_MIGRATION
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on December 1, 2016 — management decision was due June 1, 2017.
GSA_MIGRATION
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GSA_MIGRATION
2015-003, 2014-010
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GSA_MIGRATION
2015-006, 2014-012
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GSA_MIGRATION
2015-005, 2014-011
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2015-009
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GSA_MIGRATION
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