EIN: 886000028
UEI: SVRMWSEVMSA7
Audited by: Crowe LLP
Cognizant agency: 20 [Department of Transportation]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on December 17, 2025. 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 June 17, 2026 (78 days ago).
What is a management decision? →FAC accepted this audit on March 31, 2026 — management decision was due October 1, 2026.
FAC accepted this audit on December 5, 2024 — management decision was due June 5, 2025.
During the audit, it was noted that the entity failed to properly identify a subrecipient under the Congressional Directives program. As a result: 1. The entity did not conduct required subrecipient monitoring procedures, including risk assessments, reviewing financial reports, and ensuring compliance with federal requirements. 2. The entity did not file FFATA reports for the subaward, as required by 2 CFR §170.210 until noted by the auditors. Cause: The entity did not have adequate internal controls in place to properly assess and classify subrecipients versus contractors. This resulted in the subrecipient being treated as a contractor, leading to noncompliance with subrecipient monitoring and reporting requirements. Effect: The failure to properly identify and monitor the subrecipient increased the risk of noncompliance with federal requirements, potential misuse of federal funds, and a lack of transparency in federal subaward reporting. Additionally, the entity was not in compliance with FFATA reporting requirements, which could impact future funding and oversight. Questioned Costs: None noted. Context: During the audit of the Congressional Directives Program, it was observed during completeness testing over subrecipient monitoring that the entity failed to properly identify a subrecipient in accordance with the requirements set forth by the federal grant guidelines. The entity received federal funds intended for specific projects and was responsible for ensuring that all subrecipients were accurately identified and reported. However, due to inadequate internal controls and oversight, the entity did not recognize that a portion of the funds was being passed through to another organization, which should have been classified as a subrecipient. This oversight resulted in non-compliance with federal regulations, as the entity did not perform the necessary subrecipient monitoring and reporting. The failure to identify the subrecipient also led to a lack of proper documentation and accountability for the use of federal funds, potentially exposing the entity to financial and reputational risks. Identification of a repeat finding: No. Recommendation: We recommend that the entity: 1. Implement stronger internal controls to properly distinguish between subrecipients and contractors, ensuring that subrecipient relationships are identified at the time of award. 2. Develop and follow formalized procedures for subrecipient monitoring, including risk assessments, financial and programmatic oversight, and follow-up on compliance issues. 3. Ensure that all subawards exceeding the reporting threshold are reported timely to FSRS in compliance with FFATA requirements. Management Response: See Corrective Action Plan
Show full finding ▾Hide full finding ▴Finding 2024-001: Reporting – Significant Deficiency Subrecipient Monitoring – Significant Deficiency Program: Congressional Directives Assistance Listing No.: 93.493 Federal Agency: Department of Health and Human Services Award No.: 1270.METRODIV.2023 Award Year: Fiscal year 2024 - 2025 Category of Finding: Reporting and Subrecipient Monitoring Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. According to Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 332, a pass-through entity must identify subrecipients and ensure appropriate monitoring, including reviewing financial and performance reports, following up on deficiencies, and ensuring compliance with applicable requirements. A pass-through entity must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring required. Finally, the pass-through entity must monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes as well as complies with terms of the subaward. Additionally, under the Federal Funding Accountability and Transparency Act (FFATA) and 2 CFR §170.210, pass-through entities must report subawards of $30,000 or more to the FSRS (Federal Subaward Reporting System). Condition: During the audit, it was noted that the entity failed to properly identify a subrecipient under the Congressional Directives program. As a result: 1. The entity did not conduct required subrecipient monitoring procedures, including risk assessments, reviewing financial reports, and ensuring compliance with federal requirements. 2. The entity did not file FFATA reports for the subaward, as required by 2 CFR §170.210 until noted by the auditors. Cause: The entity did not have adequate internal controls in place to properly assess and classify subrecipients versus contractors. This resulted in the subrecipient being treated as a contractor, leading to noncompliance with subrecipient monitoring and reporting requirements. Effect: The failure to properly identify and monitor the subrecipient increased the risk of noncompliance with federal requirements, potential misuse of federal funds, and a lack of transparency in federal subaward reporting. Additionally, the entity was not in compliance with FFATA reporting requirements, which could impact future funding and oversight. Questioned Costs: None noted. Context: During the audit of the Congressional Directives Program, it was observed during completeness testing over subrecipient monitoring that the entity failed to properly identify a subrecipient in accordance with the requirements set forth by the federal grant guidelines. The entity received federal funds intended for specific projects and was responsible for ensuring that all subrecipients were accurately identified and reported. However, due to inadequate internal controls and oversight, the entity did not recognize that a portion of the funds was being passed through to another organization, which should have been classified as a subrecipient. This oversight resulted in non-compliance with federal regulations, as the entity did not perform the necessary subrecipient monitoring and reporting. The failure to identify the subrecipient also led to a lack of proper documentation and accountability for the use of federal funds, potentially exposing the entity to financial and reputational risks. Identification of a repeat finding: No. Recommendation: We recommend that the entity: 1. Implement stronger internal controls to properly distinguish between subrecipients and contractors, ensuring that subrecipient relationships are identified at the time of award. 2. Develop and follow formalized procedures for subrecipient monitoring, including risk assessments, financial and programmatic oversight, and follow-up on compliance issues. 3. Ensure that all subawards exceeding the reporting threshold are reported timely to FSRS in compliance with FFATA requirements. Management Response: See Corrective Action Plan
Federal Funding Accountability and Transparency Act - Significant Deficiency Congressional Directives 93.493 Department of Health and Human Services 1270.METRODIV.2023 Fiscal Year 2024-2025 To remedy the condition, cause, and effect resulting in the finding regarding timely FFATA (Federal Funding Accountability and Transparency Act) reporting into the FSRS (FFATA Subaward Reporting System), see our team's strategy to ensure that proper internal controls are strengthened moving forward. A formal procedure was established and implemented at Clark County Social Service (CCSS) in 2022 that included a recurring task of reporting information monthly into FSRS no later than the last day of the month following the month in which any obligation or modification was made to a subrecipient award. This procedure is inclusive of all grants and projects with federal funding and includes separation of duties defined by Grants Coordinators entering the FFATA information no later than the i5th of the month for the previous month's contract executions and a Senior Grants Coordinator reviewing the information within 5 business days to ensure accuracy. These entries and reviews are recorded on a tracking log that is reviewable by all levels of the Executive Management Team. Since the inception of this process, sub recipient monitoring inclusive of risk assessments, reviewing financial reports, and ensuring compliance with federal regulations including identification of sub-recipient vs. contractor has been added to the grant process procedure. Additionally, all grant and congressional directives funding will be assigned to the contract team to implement and monitor to ensure compliance with FFATA. To ensure that all CCSS team members engaged with grant funding are informed of these federal requirements, grant training will be provided to them within 30 days of their hire date. This training will be recorded and available on the CCSS intranet which is available at all times to all CCSS team members, regardless of their title. Additionally, annual training will be provided to the Management Team on FFATA, Subrecipient Monitoring, Reporting, Conducting Risk Assessments, and other federal requirements related to grant implementation. These trainings will be formalized in CCSS Standard Operation Procedures (SOP) on or before June 30, 2025. At that time all personnel responsible for federal grant management will be trained on the SOP.
FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
During the audit, it was noted that the entity failed to properly identify a subrecipient under the Congressional Directives program. As a result: 1. The entity did not conduct required subrecipient monitoring procedures, including risk assessments, reviewing financial reports, and ensuring compliance with federal requirements. 2. The entity did not file FFATA reports for the subaward, as required by 2 CFR §170.210 until noted by the auditors. Cause: The entity did not have adequate internal controls in place to properly assess and classify subrecipients versus contractors. This resulted in the subrecipient being treated as a contractor, leading to noncompliance with subrecipient monitoring and reporting requirements. Effect: The failure to properly identify and monitor the subrecipient increased the risk of noncompliance with federal requirements, potential misuse of federal funds, and a lack of transparency in federal subaward reporting. Additionally, the entity was not in compliance with FFATA reporting requirements, which could impact future funding and oversight. Questioned Costs: None noted. Context: During the audit of the Congressional Directives Program, it was observed during completeness testing over subrecipient monitoring that the entity failed to properly identify a subrecipient in accordance with the requirements set forth by the federal grant guidelines. The entity received federal funds intended for specific projects and was responsible for ensuring that all subrecipients were accurately identified and reported. However, due to inadequate internal controls and oversight, the entity did not recognize that a portion of the funds was being passed through to another organization, which should have been classified as a subrecipient. This oversight resulted in non-compliance with federal regulations, as the entity did not perform the necessary subrecipient monitoring and reporting. The failure to identify the subrecipient also led to a lack of proper documentation and accountability for the use of federal funds, potentially exposing the entity to financial and reputational risks. Identification of a repeat finding: No. Recommendation: We recommend that the entity: 1. Implement stronger internal controls to properly distinguish between subrecipients and contractors, ensuring that subrecipient relationships are identified at the time of award. 2. Develop and follow formalized procedures for subrecipient monitoring, including risk assessments, financial and programmatic oversight, and follow-up on compliance issues. 3. Ensure that all subawards exceeding the reporting threshold are reported timely to FSRS in compliance with FFATA requirements. Management Response: See Corrective Action Plan
Show full finding ▾Hide full finding ▴Finding 2024-001: Reporting – Significant Deficiency Subrecipient Monitoring – Significant Deficiency Program: Congressional Directives Assistance Listing No.: 93.493 Federal Agency: Department of Health and Human Services Award No.: 1270.METRODIV.2023 Award Year: Fiscal year 2024 - 2025 Category of Finding: Reporting and Subrecipient Monitoring Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. According to Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 332, a pass-through entity must identify subrecipients and ensure appropriate monitoring, including reviewing financial and performance reports, following up on deficiencies, and ensuring compliance with applicable requirements. A pass-through entity must also evaluate each subrecipient’s risk of noncompliance for purposes of determining the appropriate subrecipient monitoring required. Finally, the pass-through entity must monitor the activities of the subrecipient to ensure that the subaward is used for authorized purposes as well as complies with terms of the subaward. Additionally, under the Federal Funding Accountability and Transparency Act (FFATA) and 2 CFR §170.210, pass-through entities must report subawards of $30,000 or more to the FSRS (Federal Subaward Reporting System). Condition: During the audit, it was noted that the entity failed to properly identify a subrecipient under the Congressional Directives program. As a result: 1. The entity did not conduct required subrecipient monitoring procedures, including risk assessments, reviewing financial reports, and ensuring compliance with federal requirements. 2. The entity did not file FFATA reports for the subaward, as required by 2 CFR §170.210 until noted by the auditors. Cause: The entity did not have adequate internal controls in place to properly assess and classify subrecipients versus contractors. This resulted in the subrecipient being treated as a contractor, leading to noncompliance with subrecipient monitoring and reporting requirements. Effect: The failure to properly identify and monitor the subrecipient increased the risk of noncompliance with federal requirements, potential misuse of federal funds, and a lack of transparency in federal subaward reporting. Additionally, the entity was not in compliance with FFATA reporting requirements, which could impact future funding and oversight. Questioned Costs: None noted. Context: During the audit of the Congressional Directives Program, it was observed during completeness testing over subrecipient monitoring that the entity failed to properly identify a subrecipient in accordance with the requirements set forth by the federal grant guidelines. The entity received federal funds intended for specific projects and was responsible for ensuring that all subrecipients were accurately identified and reported. However, due to inadequate internal controls and oversight, the entity did not recognize that a portion of the funds was being passed through to another organization, which should have been classified as a subrecipient. This oversight resulted in non-compliance with federal regulations, as the entity did not perform the necessary subrecipient monitoring and reporting. The failure to identify the subrecipient also led to a lack of proper documentation and accountability for the use of federal funds, potentially exposing the entity to financial and reputational risks. Identification of a repeat finding: No. Recommendation: We recommend that the entity: 1. Implement stronger internal controls to properly distinguish between subrecipients and contractors, ensuring that subrecipient relationships are identified at the time of award. 2. Develop and follow formalized procedures for subrecipient monitoring, including risk assessments, financial and programmatic oversight, and follow-up on compliance issues. 3. Ensure that all subawards exceeding the reporting threshold are reported timely to FSRS in compliance with FFATA requirements. Management Response: See Corrective Action Plan
Federal Funding Accountability and Transparency Act - Significant Deficiency Congressional Directives 93.493 Department of Health and Human Services 1270.METRODIV.2023 Fiscal Year 2024-2025 To remedy the condition, cause, and effect resulting in the finding regarding timely FFATA (Federal Funding Accountability and Transparency Act) reporting into the FSRS (FFATA Subaward Reporting System), see our team's strategy to ensure that proper internal controls are strengthened moving forward. A formal procedure was established and implemented at Clark County Social Service (CCSS) in 2022 that included a recurring task of reporting information monthly into FSRS no later than the last day of the month following the month in which any obligation or modification was made to a subrecipient award. This procedure is inclusive of all grants and projects with federal funding and includes separation of duties defined by Grants Coordinators entering the FFATA information no later than the i5th of the month for the previous month's contract executions and a Senior Grants Coordinator reviewing the information within 5 business days to ensure accuracy. These entries and reviews are recorded on a tracking log that is reviewable by all levels of the Executive Management Team. Since the inception of this process, sub recipient monitoring inclusive of risk assessments, reviewing financial reports, and ensuring compliance with federal regulations including identification of sub-recipient vs. contractor has been added to the grant process procedure. Additionally, all grant and congressional directives funding will be assigned to the contract team to implement and monitor to ensure compliance with FFATA. To ensure that all CCSS team members engaged with grant funding are informed of these federal requirements, grant training will be provided to them within 30 days of their hire date. This training will be recorded and available on the CCSS intranet which is available at all times to all CCSS team members, regardless of their title. Additionally, annual training will be provided to the Management Team on FFATA, Subrecipient Monitoring, Reporting, Conducting Risk Assessments, and other federal requirements related to grant implementation. These trainings will be formalized in CCSS Standard Operation Procedures (SOP) on or before June 30, 2025. At that time all personnel responsible for federal grant management will be trained on the SOP.
FAC accepted this audit on January 29, 2024 — management decision was due July 29, 2024.
The County did not have an effective system of internal control in place to ensure segregation of duties for processing and review to ensure the applications submitted were adequately documented for eligibility and calculation of benefit over a subset of disbursements in the CARES Housing Assistance Program (CHAP). During our review of internal controls, we identified that Clark County Social Services Department employees would directly process applications that met certain criteria, a separate process from applications where the County utilized 3rd party contractors for preparation before review by Clark County. The applications were directly processed by department employees when they were identified as higher priority, such as applications that were related to Court Cases involving evictions. Upon discussion with management, it was determined that the Social Services Department employee processed the application but there was not a subsequent independent review of applications for eligibility requirements and for allowability before disbursement for all applications subject to this process. Effective October 17, 2022 management implemented a secondary review over applications processed directly by the Department of Social Services. Of the 60 participant files that were selected for testing, we noted two cases where management did not have adequate documentation to support that allowability/eligibility criteria were satisfied. Additionally, one case subject to the process utilizing 3rd party contractors did not have adequate documentation over segregation of duties. Cause: Prior to the implementation of the secondary review control, the Clark County Social Services Department were required to quickly develop a procedure to process applications for higher priority CARES Housing Assistance Program (CHAP) cases, such as those related to evictions moving through the Clark County Court system. As a result, the procedure was not properly designed to ensure adequate controls over the application review process prior to October 17, 2022. The matter identified related to the process utilizing 3rd party contractors was due to insufficient adherence to control procedures. Effect: Transactions that follow a process without adequate segregation of duties may lead to noncompliant disbursements. Without internal controls over participant eligibility, ineligible participants may benefit from federally funded programs. Lack of a separate independent review over these transactions involving allowability and eligibility determinations could result in additional noncompliance with federal requirements. Questioned Costs: $27,474 Context: Effective October 17, 2022 management implemented a secondary review over applications processed directly by the Department of Social Services. In fiscal year 2022-2023 the Countys CHAP disbursed roughly $99.4 million in assistance payments of which $6.7 million were processed directly by the Department of Social Services prior to the effective date of the secondary review control. We selected 60 participant files for testing of eligibility and allowability totaling $797,718. We noted one case processed by 3rd party contractors did not have adequate documentation of secondary review. We found that two of the 60 cases selected did not have adequate supporting documentation, such as income verification support for all household members and adequate support for benefit amounts, which resulted in $27,474 in known questioned costs out of the $797,718 tested. Identification of a repeat finding: Yes Recommendation: We recommend that the County strengthen processes to ensure consistent adherence to control procedures surrounding rental assistance application processing and approval. Management Response: See Corrective Action Plan
Show full finding ▾Hide full finding ▴Finding 2023-001: Allowable Costs and Eligibility Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of the Treasury Award No.: 1505-0270, 2021 CAA CCSS, 2022 CAA CCSS Award Year: Fiscal year 20/21, 21/22 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Allowable Costs - 2 CFR Part 200.403 Factors affecting allowability of costs except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also § 200.306(b). (g) Be adequately documented. See also §§ 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3). 501(c)(2)(A) of the Consolidated Appropriations Act and section 3201(d)(1)(A) of ARPA Financial assistance to households includes payment of rent, rental arrears, utilities and home energy costs, utility and home energy costs arrears, and other expenses related to housing. Eligibility - Consolidated Appropriations Act, 2021, for ERA 1 in sections 501(c)(2)(C)(ii) of the Act concerning documentation of payments to households, sections 501(f)(2)(A) and (B) of the Act concerning signature requirements for applications and documentation required for tenants, section 501(k)(1) concerning area median income determinations, and sections 501(k)(3)(A)(I) and (II) concerning eligible household determinations and attestation requirements. Grantees must require all applications for assistance to include an attestation from the applicant household that all information included is correct and complete. In all cases, grantees must document their policies and procedures for determining household eligibility to include policies and procedures for determining the prioritization of households in compliance with the statute and maintain records of their determinations. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The County did not have an effective system of internal control in place to ensure segregation of duties for processing and review to ensure the applications submitted were adequately documented for eligibility and calculation of benefit over a subset of disbursements in the CARES Housing Assistance Program (CHAP). During our review of internal controls, we identified that Clark County Social Services Department employees would directly process applications that met certain criteria, a separate process from applications where the County utilized 3rd party contractors for preparation before review by Clark County. The applications were directly processed by department employees when they were identified as higher priority, such as applications that were related to Court Cases involving evictions. Upon discussion with management, it was determined that the Social Services Department employee processed the application but there was not a subsequent independent review of applications for eligibility requirements and for allowability before disbursement for all applications subject to this process. Effective October 17, 2022 management implemented a secondary review over applications processed directly by the Department of Social Services. Of the 60 participant files that were selected for testing, we noted two cases where management did not have adequate documentation to support that allowability/eligibility criteria were satisfied. Additionally, one case subject to the process utilizing 3rd party contractors did not have adequate documentation over segregation of duties. Cause: Prior to the implementation of the secondary review control, the Clark County Social Services Department were required to quickly develop a procedure to process applications for higher priority CARES Housing Assistance Program (CHAP) cases, such as those related to evictions moving through the Clark County Court system. As a result, the procedure was not properly designed to ensure adequate controls over the application review process prior to October 17, 2022. The matter identified related to the process utilizing 3rd party contractors was due to insufficient adherence to control procedures. Effect: Transactions that follow a process without adequate segregation of duties may lead to noncompliant disbursements. Without internal controls over participant eligibility, ineligible participants may benefit from federally funded programs. Lack of a separate independent review over these transactions involving allowability and eligibility determinations could result in additional noncompliance with federal requirements. Questioned Costs: $27,474 Context: Effective October 17, 2022 management implemented a secondary review over applications processed directly by the Department of Social Services. In fiscal year 2022-2023 the Countys CHAP disbursed roughly $99.4 million in assistance payments of which $6.7 million were processed directly by the Department of Social Services prior to the effective date of the secondary review control. We selected 60 participant files for testing of eligibility and allowability totaling $797,718. We noted one case processed by 3rd party contractors did not have adequate documentation of secondary review. We found that two of the 60 cases selected did not have adequate supporting documentation, such as income verification support for all household members and adequate support for benefit amounts, which resulted in $27,474 in known questioned costs out of the $797,718 tested. Identification of a repeat finding: Yes Recommendation: We recommend that the County strengthen processes to ensure consistent adherence to control procedures surrounding rental assistance application processing and approval. Management Response: See Corrective Action Plan
CORRECTIVE ACTION PLAN Finding 2023-001: Allowable Costs and Eligibility - Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of the Treasury Award No.: 1505-0270, 2021 CAA CCSS, 2022 CAA CCSS Award Year: Fiscal year 20/21, 21/22 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility The Clark County Department of Social Service acknowledges and agrees with the finding. To ensure proper internal controls are in place for processing cases, the department has automated its secondary review process over allowability and eligibility determinations prior to the disbursement of funds. The secondary review procedure, which began as a manual process in October 2022, ensures decisions made by the department’s employees are accurate and in compliance with applicable regulations and guidelines. To guarantee transparency and accountability, evidence of the secondary review is recorded in each case. This documentation serves as proof that a thorough review has been conducted and that all necessary steps have been taken to ensure the accuracy and appropriateness of the disbursement of funds. To further strengthen our internal controls, the secondary review process was automated in our case management system ACES in March 2023. ACES will not allow authorization of a benefit until a secondary review process has been completed. Prior to a benefit being issued, each case is routed to a member of a secondary review team, who subsequently conducts a thorough review of each case to ensure the accuracy and appropriateness of the disbursement of funds. The implementation of these measures was a top priority for Clark County. We are commited to continuously improving our internal controls and ensuring the proper use of funds. By implementing the automated secondary review process, we aim to enhance the integrity and effectiveness of our operations, ultimately benefiting the individuals and families we serve. Deputy Director
2022-002
The County did not receive and record program income earned by a subrecipient for fiscal years 2017-2018 or 2021-2022 on a timely basis. For program income received in the fiscal year under audit, the County was unable to provide adequate documentation of controls in place for the review of calculated amounts to be retained by the subrecipient. Cause: The County did not have adequate policies and procedures surrounding review of the calculation of program income and to ensure timely accounting for program income. Effect: Inadequate segregation of duties for the timely accounting and calculation of program income could result in the program being noncompliant with federal statutes, regulations and the terms and conditions of the program. Questioned Costs: None noted. Context: In 2011, Clark County passed NSP3 funds through to the Southern Nevada Regional Housing Authority (SNRHA) as a subrecipient to purchase and rehabilitate vacant single-family homes. After the homes were rehabilitated, the housing authority became the owner of the property to rent to qualified families. The agreement between the County and SNRHA stipulates "Program income, as defined in 24 CFR 507.504(c), shall be returned to the County unless the County authorizes in writing that all or a specific portion thereof of such program income will be retained by the subrecipient. Under NSP3, any rents collected that exceed the cost of operations for each Program is considered Program Income and must be returned to the County." Program income earned by SNRHA during fiscal year 2017-2018 and 2021-2022 had not yet been received or recorded by the County. The County received and recorded program income earned by SNRHA related to fiscal year 2018-2019, 2019-2020, and 2020-2021. Total program income earned by SNRHA during fiscal year 2018-2019, 2019-2020, and 2020-2021 was $767 thousand, of which $495 thousand was retained by SNRHA. The County was unable to provide supporting documentation substantiating the review and approval of the calculation of program income to be retained by SNRHA for the three fiscal years above. Additionally, program income was not accounted for on a timely basis as fiscal year 2017-2018 and 2021- 2022 program income was not received and recorded as of fiscal year 2022-2023. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management strengthen internal controls related to the review over the calculation of program income and accounting for program income in a timely manner. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2023-002: Program Income Significant Deficiency Program: Community Development Block Grant Assistance Listing No.: 14.218 Federal Agency: Department of Housing and Urban Development Award No.: State NSP3 Award Year: Fiscal year 2011-2012 Category of Finding: Program Income Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 24 CFR 570.503(b)(3) Program income states The agreement shall include the program income requirements set forth in § 570.504(c). The agreement shall also specify that, at the end of the program year, the grantee may require remittance of all or part of any program income balances (including investments thereof) held by the subrecipient (except those needed for immediate cash needs, cash balances of a revolving loan fund, cash balances from a lump sum drawdown, or cash or investments held for section 108 security needs). 2 CFR 200.302(a)(2) Financial management states Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: The County did not receive and record program income earned by a subrecipient for fiscal years 2017-2018 or 2021-2022 on a timely basis. For program income received in the fiscal year under audit, the County was unable to provide adequate documentation of controls in place for the review of calculated amounts to be retained by the subrecipient. Cause: The County did not have adequate policies and procedures surrounding review of the calculation of program income and to ensure timely accounting for program income. Effect: Inadequate segregation of duties for the timely accounting and calculation of program income could result in the program being noncompliant with federal statutes, regulations and the terms and conditions of the program. Questioned Costs: None noted. Context: In 2011, Clark County passed NSP3 funds through to the Southern Nevada Regional Housing Authority (SNRHA) as a subrecipient to purchase and rehabilitate vacant single-family homes. After the homes were rehabilitated, the housing authority became the owner of the property to rent to qualified families. The agreement between the County and SNRHA stipulates "Program income, as defined in 24 CFR 507.504(c), shall be returned to the County unless the County authorizes in writing that all or a specific portion thereof of such program income will be retained by the subrecipient. Under NSP3, any rents collected that exceed the cost of operations for each Program is considered Program Income and must be returned to the County." Program income earned by SNRHA during fiscal year 2017-2018 and 2021-2022 had not yet been received or recorded by the County. The County received and recorded program income earned by SNRHA related to fiscal year 2018-2019, 2019-2020, and 2020-2021. Total program income earned by SNRHA during fiscal year 2018-2019, 2019-2020, and 2020-2021 was $767 thousand, of which $495 thousand was retained by SNRHA. The County was unable to provide supporting documentation substantiating the review and approval of the calculation of program income to be retained by SNRHA for the three fiscal years above. Additionally, program income was not accounted for on a timely basis as fiscal year 2017-2018 and 2021- 2022 program income was not received and recorded as of fiscal year 2022-2023. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management strengthen internal controls related to the review over the calculation of program income and accounting for program income in a timely manner. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2023-002: Program: CFDA No.: Federal Agency: Award No.: Award Year: Program Income - Significant Deficiency Community Development Block Grant (NSP) 14.218 Department of Housing and Urban Development State NSP3 Fiscal year 2011-2012 Context: In 2011 Clark County passed NSP3 funds through to the Southern Nevada Regional Housing Authority (SNRHA) as a subrecipient to purchase and rehabilitate vacant single-family homes. After the homes were rehabilitated, the housing authority became the owner of the property to rent to qualified families. The agreement between the County and SNRHA stipulates "Program income, as defined in 24 CFR 507.504(c), shall be returned to the County unless the County authorizes in writing that all or a specific portion thereof of such program income will be retained by the subrecipient. Under NSP3, any rents collected that exceed the cost of operations for each Program is considered Program Income and must be returned to the County." Program income earned by SNRHA during fiscal year 2018-2019 and 2021-2022 had not yet been received or recorded by the County. The County received and recorded program income earned by SNRHA related to fiscal year 2018-2019, 2019-2020, and 2020-2021. Total program income earned by SNRHA during fiscal year 2018-2019, 2019-2020, and 2020-2021 was $767k, of which $495k was retained by SNRHA. The County was unable to provide supporting documentation substantiating the review and approval of the calculation of program income to be retained by SNRHA for the 3 fiscal years above. Additionally, program income was not accounted for on a timely basis as fiscal year 2017-2018 and 2021-2022 program income was not received and recorded as of fiscal year 2022-2023. Remedy: To remedy the condition, cause, and effect resulting in the finding regarding program income, our team's strategy will be to strengthen internal controls related to the review over the calculation of program income and accounting for program income in a timely manner; see our team's strategy to ensure that proper internal controls are in place moving forward: NSP - Program Income Calculation and Accounting Strategy Issues that contributed to the deficiency of internal controls related to the calculation of program income: • In the November 9, 2018, monitoring letter from Clark County to SNRHA, Clark County indicated they will consider proposals from SNRHA to use their FY2017-2018 NSP3 SNRHA program income funds for other NSP3 eligible activities. Although a project for mobile homes was discussed tor this use - records of the approval and project were not located. • HUD is aware that Clark County is experiencing issues with SNRHA and their failure to provide program income timely, as there is an outstanding HUD finding from 2016 that Clark County is in the process of resolving. Initially the prior CRM Manager, Kristin Cooper's response to HUD indicated an MOU would be executed, however in further research we have found that an MOU was never executed, and it was determined in FY2023 that the MOU is not sufficient. Strategy to strengthen internal controls related to the calculation of NSP3 Program Income: • Clark County is in the process of creating an amendment to SNRHA's NSP3 agreement to include all detailed expectations moving forward. • Clark County will also include oversight of rental management practices as well as, internal controls to strengthen the calculation for SNRHA NSP3 program income. Issues that contributed to the untimely receipt and reporting of NSP 3 Program Income: • Ongoing multi-year monitoring of SNRHA records to identify and obtain NSP3 program income (monitoring began February 2017 and was ongoing through May 2019). • Clark County is experiencing issues with SNRHA and their failure to provide program income timely. • No clear written internal process on receiving and accounting for NSP3 program income. Strategies to strengthen controls related to the receipt and reporting of NSP3 Program Income: • Establish a detailed annual recurring NSP3 monitoring process specifically addressing the calculation and accounting of SNRHA NSP3 Program Income. • Create an amendment to the SNRHA's NSP3 agreement to clarify future program income expectations and oversight. • Create and implement an NSP3 written process for SNRHA to ensure timely receipt and accounting of NSP3 program income. We hope to have the matter resolved by no later than June 30, 2024. Jamie Sorenson, Director Clark County Social Service Jamie.Sorenson@ClarkCountyNV.gov 702.455.5596 CC: Kathleen San Andres, A.J. Johnson (Crowe) Pamela Kowalski, Anna Danchik, Colleen Boyle, Teresa Etcheberry, Dagny Stapleton, Karen Michelin, Deanna Judkins, Kerri Medill, Marylin Schoen (Clark County)
There are two Departments responsible for overseeing the program. One of these Departments, the Clark County Department of Comprehensive Planning, did not have adequate procedures in place to ensure segregation of duties for the preparation and approval of reimbursements through March 2023, when additional control procedures were implemented in response to an audit recommendation from the fiscal year 2021-2022 single audit. One reimbursement made prior to March 2023 for $82 thousand was requested by the Department for the wrong grant agreement. This error was subsequently corrected by the Department upon notification from the grantor. One reimbursement made after March 2023 for $1.08 million was selected and did not have adequate documentation to verify segregation of duties. Cause: The Clark County Department of Comprehensive Planning did not have adequate procedures in place to ensure segregation of duties surrounding reimbursement requests prior to March, 2023 and did not sufficiently adhere to additional control procedures implemented in March 2023. Effect: Insufficient internal controls over reimbursement requests could result in the program being noncompliant with federal statutes, regulations and the terms and conditions of the program. Questioned Costs: None. Context: The Southern Nevada Public Land Management Program is managed by two Clark County departments, the Department of Comprehensive Planning and the Department of Environment and Sustainability. During the fiscal year 2021-2022, inadequate documentation surrounding segregation of duties for reimbursement requests was identified. Management implemented control procedures in March 2023 to ensure adequate segregation of duties surrounding the review and approval of reimbursement requests. For fiscal year 2022-2023 the Department of Comprehensive planning oversaw $4.1 million in SNPLM funds while the Department of Environment and Sustainability oversaw $371 thousand in SNPLM funds. We selected four reimbursements from the Department of Comprehensive Planning totaling $1.9 million and three reimbursements from the Department of Environment and Sustainability totaling $144 thousand out of a population of 35 totaling $4.5 million. For fiscal year 2022-2023, $3 million out of the $4.5 million in drawdowns were processed prior to implementation of the control noted above. Of the seven reimbursement requests selected, one reimbursement from the Department of Comprehensive Planning for $82 thousand was requested under the incorrect grant due to an error in initial set up of the grant in the financial system. This error was prior to the implementation of control procedures implemented to ensure adequate segregation of duties in March 2023 and was corrected prior to testing after receiving communications from the grantor. Of the seven reimbursement requests selected, one reimbursement from the Department of Comprehensive Planning made after March 2023 for $1.08 million was selected and did not have adequate documentation to verify segregation of duties. Identification of a repeat finding: Yes. Recommendation: We recommend that management ensure their revised control procedures for drawdowns be applied to all drawdowns processed by the Department of Comprehensive Planning. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2023-003: Internal Controls Over Reimbursement Requests Material Weakness Program: Southern Nevada Public Land Management Program Assistance Listing No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No.: L16AC00098, L17AC00040, L20AC00064, L20AC00069, and L20AC00075 Award Year: Fiscal year 2016-2017, 2019-2020, and 2020-2021 Category of Finding: Cash Management Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: There are two Departments responsible for overseeing the program. One of these Departments, the Clark County Department of Comprehensive Planning, did not have adequate procedures in place to ensure segregation of duties for the preparation and approval of reimbursements through March 2023, when additional control procedures were implemented in response to an audit recommendation from the fiscal year 2021-2022 single audit. One reimbursement made prior to March 2023 for $82 thousand was requested by the Department for the wrong grant agreement. This error was subsequently corrected by the Department upon notification from the grantor. One reimbursement made after March 2023 for $1.08 million was selected and did not have adequate documentation to verify segregation of duties. Cause: The Clark County Department of Comprehensive Planning did not have adequate procedures in place to ensure segregation of duties surrounding reimbursement requests prior to March, 2023 and did not sufficiently adhere to additional control procedures implemented in March 2023. Effect: Insufficient internal controls over reimbursement requests could result in the program being noncompliant with federal statutes, regulations and the terms and conditions of the program. Questioned Costs: None. Context: The Southern Nevada Public Land Management Program is managed by two Clark County departments, the Department of Comprehensive Planning and the Department of Environment and Sustainability. During the fiscal year 2021-2022, inadequate documentation surrounding segregation of duties for reimbursement requests was identified. Management implemented control procedures in March 2023 to ensure adequate segregation of duties surrounding the review and approval of reimbursement requests. For fiscal year 2022-2023 the Department of Comprehensive planning oversaw $4.1 million in SNPLM funds while the Department of Environment and Sustainability oversaw $371 thousand in SNPLM funds. We selected four reimbursements from the Department of Comprehensive Planning totaling $1.9 million and three reimbursements from the Department of Environment and Sustainability totaling $144 thousand out of a population of 35 totaling $4.5 million. For fiscal year 2022-2023, $3 million out of the $4.5 million in drawdowns were processed prior to implementation of the control noted above. Of the seven reimbursement requests selected, one reimbursement from the Department of Comprehensive Planning for $82 thousand was requested under the incorrect grant due to an error in initial set up of the grant in the financial system. This error was prior to the implementation of control procedures implemented to ensure adequate segregation of duties in March 2023 and was corrected prior to testing after receiving communications from the grantor. Of the seven reimbursement requests selected, one reimbursement from the Department of Comprehensive Planning made after March 2023 for $1.08 million was selected and did not have adequate documentation to verify segregation of duties. Identification of a repeat finding: Yes. Recommendation: We recommend that management ensure their revised control procedures for drawdowns be applied to all drawdowns processed by the Department of Comprehensive Planning. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2023-003: AL No.: Federal Agency: Award No: Award Year: Category of Finding: Internal Controls Over Reimbursement Requests - Material Weakness Program Southern Nevada Public Land Management Program 15.235 Federal Bureau of Land Management L 16AC00098, L 17 AC00040, L20AC00064, L20AC00069, and L20AC00075 Fiscal year 20I6-2017, 20 I 9-2020, and 2020-2021 Cash Management Context: The Southern Nevada Public Land Management Program is managed by two Clark County depmiments, the Depmiment of Comprehensive Planning and the Department of Environment and Sustainability. During the fiscal year 2021-2022, inadequate documentation sunounding segregation of duties for reimbursement requests was identified. Management implemented control procedures in March 2023 to ensure adequate segregation of duties sunounding the review and approval of reimbursement requests. During the fiscal year 2022-2023, reimbursement control procedures updated in March 2023 were not strictly adhered to by the Depmiment of Comprehensive Planning for documenting segregation of duties. Remedy: The Standards of Procedures (SOP) for the Department of Comprehensive Planning has been updated to include the segregation of duties for SNPLMA reimbursement requests. Effective immediately, the Senior Management Analyst will be required to review and submit reimbursement requests to the department director electronically with the following language included in the e-mail: "I, Senior Management Analyst Tamara Williams, have reviewed the reimbursement requests for accuracy on XX/XX/XXXX. I am submitting it for review and signature approval to the Director of Comprehensive Planning, Sami Real." The SOP has been updated to include that upon receipt of the approval, the Senior Management Analyst will archive a copy of the reimbursement request. Sami Real Director of Comprehensive Planning
2022-005
The County did not have adequate procedures in place to ensure segregation of duties for the preparation and approval of reports through February 2023 when additional control procedures were implemented. Cause: The County did not have adequate procedures for internal controls surrounding reporting to ensure requirements were met. Effect: Failure to adhere to internal control procedures to ensure the accuracy of reports in accordance with federal regulations could result in the program being noncompliant with federal statues, regulations and the terms and conditions of the federal awards. Questioned Costs: None. Context: The County has 12 active Southern Nevada Public Land Management grants. During the fiscal year 2021-2022 audit, inadequate documentation surrounding segregation of duties for grant reporting was identified. Management indicated control procedures were updated in February 2023 to ensure adequate documentation of segregation of duties surrounding the preparation and approval of grant reports. We tested four annual financial reports and nine quarterly performance reports and did not identify any compliance matters. Identification of a repeat finding: Yes. Recommendation: We recommend that management ensure their revised procedures include a separate independent review over report preparation that is applied to all reports. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2023-004: Internal Controls Over Reporting Significant Deficiency Program: Southern Nevada Public Land Management Program Assistance Listing No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No.: L16AC00098, L17AC00040, L17AC00076, L20AC00064, 20AC00065, 20AC00066, 20AC00067, L20AC00069, L20AC00075, L23AC00009, L23AC00018, and L23AC00019 Award Year: Fiscal year 2016-2017, 2018-2019, 2019-2020, 2020-2021, and 2022-2023 Category of Finding: Reporting Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County did not have adequate procedures in place to ensure segregation of duties for the preparation and approval of reports through February 2023 when additional control procedures were implemented. Cause: The County did not have adequate procedures for internal controls surrounding reporting to ensure requirements were met. Effect: Failure to adhere to internal control procedures to ensure the accuracy of reports in accordance with federal regulations could result in the program being noncompliant with federal statues, regulations and the terms and conditions of the federal awards. Questioned Costs: None. Context: The County has 12 active Southern Nevada Public Land Management grants. During the fiscal year 2021-2022 audit, inadequate documentation surrounding segregation of duties for grant reporting was identified. Management indicated control procedures were updated in February 2023 to ensure adequate documentation of segregation of duties surrounding the preparation and approval of grant reports. We tested four annual financial reports and nine quarterly performance reports and did not identify any compliance matters. Identification of a repeat finding: Yes. Recommendation: We recommend that management ensure their revised procedures include a separate independent review over report preparation that is applied to all reports. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding #: 2023-004 Internal Controls over Reporting – TBD Category of Finding: Reporting Program: Southern Nevada Public Land Management Program AL No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No.: L17AC00076, L17AC00077, L20AC00065, L20AC00066, L20AC000067 Award Year: Fiscal Y e2ar 20 2-2023 To remedy the cause resulting in the finding the County did not have adequate procedures for internal controls to ensure reports. met requirements and were submitted timely. The Department of Environment and Sustainability’s has implemented the following strategy to ensure that proper internal controls are in place moving forward: Context: Annual Financial Report did not have adequate support indicating segregation of duties regarding preparation and approval over the report. Remedy: The Department of Environment and Sustainability has updated the standard operating procedures (SOP) to require the Administrative Specialist submit the prepared SF425 to our Director electronically with the following language included in the email: “I, Administrative Specialist Sharon McLeish, have prepared the SF-425 on XX/XX/XXXX. I am submitting it for review and signature approval to the Director of Environment and Sustainability Marci Henson.” The SOP has been updated to include that upon return of the signed form from the Director, the Administrative Assistant will. perform a verification of the Director’s signature and date. The SOP was also updated to require the email chain that includes. the attestation of preparation and signature approval be archived with the SF425. Context: Quarterly Progress Reports did not have the adequate support indicating segregation of duties regarding preparation and approval over the report. Remedy: The Department of Environment and Sustainability has updated the standard operating procedures (SOP) to require the Project Managers to submit the prepared Quarterly Progress Reports to the Program Lead electronically with the following. language included in the email: “I, (Title/Employee), have prepared the FYXX QX Quarterly Progress Report on XX/XX/XXXX. I am submitting it for review. and electronic approval to the Principal Environmental Specialist, Kimberley Jenkins.” The SOP has been updated to include that upon receipt of the approval of the Quarterly Progress Report, the Project Manager will archive a copy of the report and approval. Sincerely, Jodi Bechtel, Deputy Director Department of Environment and Sustainability
2022-004
FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.
The County did not have an effective system of internal control in place to ensure segregation of duties for processing and review to ensure the applications submitted were adequately documented for eligibility and calculation of benefit over a subset of disbursements in the CARES Housing Assistance Program (CHAP). During our review of internal controls, we identified that Clark County Social Services Department employees would directly process applications that met certain criteria, a separate process from applications where the County utilized 3rd party contractors for preparation before review by Clark County. The applications were directly processed by department employees when they were identified as higher priority, such as applications that were related to Court Cases involving evictions. Upon discussion with management, it was determined that the Social Services Department employee processed the application but there was not a subsequent independent review of applications for eligibility requirements and for allowability before disbursement for all applications subject to this process. Effective October 17, 2022 management implemented a secondary review over applications processed directly by the Department of Social Services. Of the 60 participant files that were selected for testing, we noted two cases where management did not have adequate documentation to support that allowability/eligibility criteria were satisfied. Additionally, one case subject to the process utilizing 3rd party contractors did not have adequate documentation over segregation of duties. Cause: Prior to the implementation of the secondary review control, the Clark County Social Services Department were required to quickly develop a procedure to process applications for higher priority CARES Housing Assistance Program (CHAP) cases, such as those related to evictions moving through the Clark County Court system. As a result, the procedure was not properly designed to ensure adequate controls over the application review process prior to October 17, 2022. The matter identified related to the process utilizing 3rd party contractors was due to insufficient adherence to control procedures. Effect: Transactions that follow a process without adequate segregation of duties may lead to noncompliant disbursements. Without internal controls over participant eligibility, ineligible participants may benefit from federally funded programs. Lack of a separate independent review over these transactions involving allowability and eligibility determinations could result in additional noncompliance with federal requirements. Questioned Costs: $27,474 Context: Effective October 17, 2022 management implemented a secondary review over applications processed directly by the Department of Social Services. In fiscal year 2022-2023 the Countys CHAP disbursed roughly $99.4 million in assistance payments of which $6.7 million were processed directly by the Department of Social Services prior to the effective date of the secondary review control. We selected 60 participant files for testing of eligibility and allowability totaling $797,718. We noted one case processed by 3rd party contractors did not have adequate documentation of secondary review. We found that two of the 60 cases selected did not have adequate supporting documentation, such as income verification support for all household members and adequate support for benefit amounts, which resulted in $27,474 in known questioned costs out of the $797,718 tested. Identification of a repeat finding: Yes Recommendation: We recommend that the County strengthen processes to ensure consistent adherence to control procedures surrounding rental assistance application processing and approval. Management Response: See Corrective Action Plan
Show full finding ▾Hide full finding ▴Finding 2023-001: Allowable Costs and Eligibility Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of the Treasury Award No.: 1505-0270, 2021 CAA CCSS, 2022 CAA CCSS Award Year: Fiscal year 20/21, 21/22 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Allowable Costs - 2 CFR Part 200.403 Factors affecting allowability of costs except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also § 200.306(b). (g) Be adequately documented. See also §§ 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to § 200.308(e)(3). 501(c)(2)(A) of the Consolidated Appropriations Act and section 3201(d)(1)(A) of ARPA Financial assistance to households includes payment of rent, rental arrears, utilities and home energy costs, utility and home energy costs arrears, and other expenses related to housing. Eligibility - Consolidated Appropriations Act, 2021, for ERA 1 in sections 501(c)(2)(C)(ii) of the Act concerning documentation of payments to households, sections 501(f)(2)(A) and (B) of the Act concerning signature requirements for applications and documentation required for tenants, section 501(k)(1) concerning area median income determinations, and sections 501(k)(3)(A)(I) and (II) concerning eligible household determinations and attestation requirements. Grantees must require all applications for assistance to include an attestation from the applicant household that all information included is correct and complete. In all cases, grantees must document their policies and procedures for determining household eligibility to include policies and procedures for determining the prioritization of households in compliance with the statute and maintain records of their determinations. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The County did not have an effective system of internal control in place to ensure segregation of duties for processing and review to ensure the applications submitted were adequately documented for eligibility and calculation of benefit over a subset of disbursements in the CARES Housing Assistance Program (CHAP). During our review of internal controls, we identified that Clark County Social Services Department employees would directly process applications that met certain criteria, a separate process from applications where the County utilized 3rd party contractors for preparation before review by Clark County. The applications were directly processed by department employees when they were identified as higher priority, such as applications that were related to Court Cases involving evictions. Upon discussion with management, it was determined that the Social Services Department employee processed the application but there was not a subsequent independent review of applications for eligibility requirements and for allowability before disbursement for all applications subject to this process. Effective October 17, 2022 management implemented a secondary review over applications processed directly by the Department of Social Services. Of the 60 participant files that were selected for testing, we noted two cases where management did not have adequate documentation to support that allowability/eligibility criteria were satisfied. Additionally, one case subject to the process utilizing 3rd party contractors did not have adequate documentation over segregation of duties. Cause: Prior to the implementation of the secondary review control, the Clark County Social Services Department were required to quickly develop a procedure to process applications for higher priority CARES Housing Assistance Program (CHAP) cases, such as those related to evictions moving through the Clark County Court system. As a result, the procedure was not properly designed to ensure adequate controls over the application review process prior to October 17, 2022. The matter identified related to the process utilizing 3rd party contractors was due to insufficient adherence to control procedures. Effect: Transactions that follow a process without adequate segregation of duties may lead to noncompliant disbursements. Without internal controls over participant eligibility, ineligible participants may benefit from federally funded programs. Lack of a separate independent review over these transactions involving allowability and eligibility determinations could result in additional noncompliance with federal requirements. Questioned Costs: $27,474 Context: Effective October 17, 2022 management implemented a secondary review over applications processed directly by the Department of Social Services. In fiscal year 2022-2023 the Countys CHAP disbursed roughly $99.4 million in assistance payments of which $6.7 million were processed directly by the Department of Social Services prior to the effective date of the secondary review control. We selected 60 participant files for testing of eligibility and allowability totaling $797,718. We noted one case processed by 3rd party contractors did not have adequate documentation of secondary review. We found that two of the 60 cases selected did not have adequate supporting documentation, such as income verification support for all household members and adequate support for benefit amounts, which resulted in $27,474 in known questioned costs out of the $797,718 tested. Identification of a repeat finding: Yes Recommendation: We recommend that the County strengthen processes to ensure consistent adherence to control procedures surrounding rental assistance application processing and approval. Management Response: See Corrective Action Plan
CORRECTIVE ACTION PLAN Finding 2023-001: Allowable Costs and Eligibility - Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of the Treasury Award No.: 1505-0270, 2021 CAA CCSS, 2022 CAA CCSS Award Year: Fiscal year 20/21, 21/22 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility The Clark County Department of Social Service acknowledges and agrees with the finding. To ensure proper internal controls are in place for processing cases, the department has automated its secondary review process over allowability and eligibility determinations prior to the disbursement of funds. The secondary review procedure, which began as a manual process in October 2022, ensures decisions made by the department’s employees are accurate and in compliance with applicable regulations and guidelines. To guarantee transparency and accountability, evidence of the secondary review is recorded in each case. This documentation serves as proof that a thorough review has been conducted and that all necessary steps have been taken to ensure the accuracy and appropriateness of the disbursement of funds. To further strengthen our internal controls, the secondary review process was automated in our case management system ACES in March 2023. ACES will not allow authorization of a benefit until a secondary review process has been completed. Prior to a benefit being issued, each case is routed to a member of a secondary review team, who subsequently conducts a thorough review of each case to ensure the accuracy and appropriateness of the disbursement of funds. The implementation of these measures was a top priority for Clark County. We are commited to continuously improving our internal controls and ensuring the proper use of funds. By implementing the automated secondary review process, we aim to enhance the integrity and effectiveness of our operations, ultimately benefiting the individuals and families we serve. Deputy Director
2022-002
The County did not receive and record program income earned by a subrecipient for fiscal years 2017-2018 or 2021-2022 on a timely basis. For program income received in the fiscal year under audit, the County was unable to provide adequate documentation of controls in place for the review of calculated amounts to be retained by the subrecipient. Cause: The County did not have adequate policies and procedures surrounding review of the calculation of program income and to ensure timely accounting for program income. Effect: Inadequate segregation of duties for the timely accounting and calculation of program income could result in the program being noncompliant with federal statutes, regulations and the terms and conditions of the program. Questioned Costs: None noted. Context: In 2011, Clark County passed NSP3 funds through to the Southern Nevada Regional Housing Authority (SNRHA) as a subrecipient to purchase and rehabilitate vacant single-family homes. After the homes were rehabilitated, the housing authority became the owner of the property to rent to qualified families. The agreement between the County and SNRHA stipulates "Program income, as defined in 24 CFR 507.504(c), shall be returned to the County unless the County authorizes in writing that all or a specific portion thereof of such program income will be retained by the subrecipient. Under NSP3, any rents collected that exceed the cost of operations for each Program is considered Program Income and must be returned to the County." Program income earned by SNRHA during fiscal year 2017-2018 and 2021-2022 had not yet been received or recorded by the County. The County received and recorded program income earned by SNRHA related to fiscal year 2018-2019, 2019-2020, and 2020-2021. Total program income earned by SNRHA during fiscal year 2018-2019, 2019-2020, and 2020-2021 was $767 thousand, of which $495 thousand was retained by SNRHA. The County was unable to provide supporting documentation substantiating the review and approval of the calculation of program income to be retained by SNRHA for the three fiscal years above. Additionally, program income was not accounted for on a timely basis as fiscal year 2017-2018 and 2021- 2022 program income was not received and recorded as of fiscal year 2022-2023. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management strengthen internal controls related to the review over the calculation of program income and accounting for program income in a timely manner. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2023-002: Program Income Significant Deficiency Program: Community Development Block Grant Assistance Listing No.: 14.218 Federal Agency: Department of Housing and Urban Development Award No.: State NSP3 Award Year: Fiscal year 2011-2012 Category of Finding: Program Income Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 24 CFR 570.503(b)(3) Program income states The agreement shall include the program income requirements set forth in § 570.504(c). The agreement shall also specify that, at the end of the program year, the grantee may require remittance of all or part of any program income balances (including investments thereof) held by the subrecipient (except those needed for immediate cash needs, cash balances of a revolving loan fund, cash balances from a lump sum drawdown, or cash or investments held for section 108 security needs). 2 CFR 200.302(a)(2) Financial management states Accurate, current, and complete disclosure of the financial results of each Federal award or program in accordance with the reporting requirements set forth in 200.328 and 200.329. Condition: The County did not receive and record program income earned by a subrecipient for fiscal years 2017-2018 or 2021-2022 on a timely basis. For program income received in the fiscal year under audit, the County was unable to provide adequate documentation of controls in place for the review of calculated amounts to be retained by the subrecipient. Cause: The County did not have adequate policies and procedures surrounding review of the calculation of program income and to ensure timely accounting for program income. Effect: Inadequate segregation of duties for the timely accounting and calculation of program income could result in the program being noncompliant with federal statutes, regulations and the terms and conditions of the program. Questioned Costs: None noted. Context: In 2011, Clark County passed NSP3 funds through to the Southern Nevada Regional Housing Authority (SNRHA) as a subrecipient to purchase and rehabilitate vacant single-family homes. After the homes were rehabilitated, the housing authority became the owner of the property to rent to qualified families. The agreement between the County and SNRHA stipulates "Program income, as defined in 24 CFR 507.504(c), shall be returned to the County unless the County authorizes in writing that all or a specific portion thereof of such program income will be retained by the subrecipient. Under NSP3, any rents collected that exceed the cost of operations for each Program is considered Program Income and must be returned to the County." Program income earned by SNRHA during fiscal year 2017-2018 and 2021-2022 had not yet been received or recorded by the County. The County received and recorded program income earned by SNRHA related to fiscal year 2018-2019, 2019-2020, and 2020-2021. Total program income earned by SNRHA during fiscal year 2018-2019, 2019-2020, and 2020-2021 was $767 thousand, of which $495 thousand was retained by SNRHA. The County was unable to provide supporting documentation substantiating the review and approval of the calculation of program income to be retained by SNRHA for the three fiscal years above. Additionally, program income was not accounted for on a timely basis as fiscal year 2017-2018 and 2021- 2022 program income was not received and recorded as of fiscal year 2022-2023. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management strengthen internal controls related to the review over the calculation of program income and accounting for program income in a timely manner. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2023-002: Program: CFDA No.: Federal Agency: Award No.: Award Year: Program Income - Significant Deficiency Community Development Block Grant (NSP) 14.218 Department of Housing and Urban Development State NSP3 Fiscal year 2011-2012 Context: In 2011 Clark County passed NSP3 funds through to the Southern Nevada Regional Housing Authority (SNRHA) as a subrecipient to purchase and rehabilitate vacant single-family homes. After the homes were rehabilitated, the housing authority became the owner of the property to rent to qualified families. The agreement between the County and SNRHA stipulates "Program income, as defined in 24 CFR 507.504(c), shall be returned to the County unless the County authorizes in writing that all or a specific portion thereof of such program income will be retained by the subrecipient. Under NSP3, any rents collected that exceed the cost of operations for each Program is considered Program Income and must be returned to the County." Program income earned by SNRHA during fiscal year 2018-2019 and 2021-2022 had not yet been received or recorded by the County. The County received and recorded program income earned by SNRHA related to fiscal year 2018-2019, 2019-2020, and 2020-2021. Total program income earned by SNRHA during fiscal year 2018-2019, 2019-2020, and 2020-2021 was $767k, of which $495k was retained by SNRHA. The County was unable to provide supporting documentation substantiating the review and approval of the calculation of program income to be retained by SNRHA for the 3 fiscal years above. Additionally, program income was not accounted for on a timely basis as fiscal year 2017-2018 and 2021-2022 program income was not received and recorded as of fiscal year 2022-2023. Remedy: To remedy the condition, cause, and effect resulting in the finding regarding program income, our team's strategy will be to strengthen internal controls related to the review over the calculation of program income and accounting for program income in a timely manner; see our team's strategy to ensure that proper internal controls are in place moving forward: NSP - Program Income Calculation and Accounting Strategy Issues that contributed to the deficiency of internal controls related to the calculation of program income: • In the November 9, 2018, monitoring letter from Clark County to SNRHA, Clark County indicated they will consider proposals from SNRHA to use their FY2017-2018 NSP3 SNRHA program income funds for other NSP3 eligible activities. Although a project for mobile homes was discussed tor this use - records of the approval and project were not located. • HUD is aware that Clark County is experiencing issues with SNRHA and their failure to provide program income timely, as there is an outstanding HUD finding from 2016 that Clark County is in the process of resolving. Initially the prior CRM Manager, Kristin Cooper's response to HUD indicated an MOU would be executed, however in further research we have found that an MOU was never executed, and it was determined in FY2023 that the MOU is not sufficient. Strategy to strengthen internal controls related to the calculation of NSP3 Program Income: • Clark County is in the process of creating an amendment to SNRHA's NSP3 agreement to include all detailed expectations moving forward. • Clark County will also include oversight of rental management practices as well as, internal controls to strengthen the calculation for SNRHA NSP3 program income. Issues that contributed to the untimely receipt and reporting of NSP 3 Program Income: • Ongoing multi-year monitoring of SNRHA records to identify and obtain NSP3 program income (monitoring began February 2017 and was ongoing through May 2019). • Clark County is experiencing issues with SNRHA and their failure to provide program income timely. • No clear written internal process on receiving and accounting for NSP3 program income. Strategies to strengthen controls related to the receipt and reporting of NSP3 Program Income: • Establish a detailed annual recurring NSP3 monitoring process specifically addressing the calculation and accounting of SNRHA NSP3 Program Income. • Create an amendment to the SNRHA's NSP3 agreement to clarify future program income expectations and oversight. • Create and implement an NSP3 written process for SNRHA to ensure timely receipt and accounting of NSP3 program income. We hope to have the matter resolved by no later than June 30, 2024. Jamie Sorenson, Director Clark County Social Service Jamie.Sorenson@ClarkCountyNV.gov 702.455.5596 CC: Kathleen San Andres, A.J. Johnson (Crowe) Pamela Kowalski, Anna Danchik, Colleen Boyle, Teresa Etcheberry, Dagny Stapleton, Karen Michelin, Deanna Judkins, Kerri Medill, Marylin Schoen (Clark County)
There are two Departments responsible for overseeing the program. One of these Departments, the Clark County Department of Comprehensive Planning, did not have adequate procedures in place to ensure segregation of duties for the preparation and approval of reimbursements through March 2023, when additional control procedures were implemented in response to an audit recommendation from the fiscal year 2021-2022 single audit. One reimbursement made prior to March 2023 for $82 thousand was requested by the Department for the wrong grant agreement. This error was subsequently corrected by the Department upon notification from the grantor. One reimbursement made after March 2023 for $1.08 million was selected and did not have adequate documentation to verify segregation of duties. Cause: The Clark County Department of Comprehensive Planning did not have adequate procedures in place to ensure segregation of duties surrounding reimbursement requests prior to March, 2023 and did not sufficiently adhere to additional control procedures implemented in March 2023. Effect: Insufficient internal controls over reimbursement requests could result in the program being noncompliant with federal statutes, regulations and the terms and conditions of the program. Questioned Costs: None. Context: The Southern Nevada Public Land Management Program is managed by two Clark County departments, the Department of Comprehensive Planning and the Department of Environment and Sustainability. During the fiscal year 2021-2022, inadequate documentation surrounding segregation of duties for reimbursement requests was identified. Management implemented control procedures in March 2023 to ensure adequate segregation of duties surrounding the review and approval of reimbursement requests. For fiscal year 2022-2023 the Department of Comprehensive planning oversaw $4.1 million in SNPLM funds while the Department of Environment and Sustainability oversaw $371 thousand in SNPLM funds. We selected four reimbursements from the Department of Comprehensive Planning totaling $1.9 million and three reimbursements from the Department of Environment and Sustainability totaling $144 thousand out of a population of 35 totaling $4.5 million. For fiscal year 2022-2023, $3 million out of the $4.5 million in drawdowns were processed prior to implementation of the control noted above. Of the seven reimbursement requests selected, one reimbursement from the Department of Comprehensive Planning for $82 thousand was requested under the incorrect grant due to an error in initial set up of the grant in the financial system. This error was prior to the implementation of control procedures implemented to ensure adequate segregation of duties in March 2023 and was corrected prior to testing after receiving communications from the grantor. Of the seven reimbursement requests selected, one reimbursement from the Department of Comprehensive Planning made after March 2023 for $1.08 million was selected and did not have adequate documentation to verify segregation of duties. Identification of a repeat finding: Yes. Recommendation: We recommend that management ensure their revised control procedures for drawdowns be applied to all drawdowns processed by the Department of Comprehensive Planning. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2023-003: Internal Controls Over Reimbursement Requests Material Weakness Program: Southern Nevada Public Land Management Program Assistance Listing No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No.: L16AC00098, L17AC00040, L20AC00064, L20AC00069, and L20AC00075 Award Year: Fiscal year 2016-2017, 2019-2020, and 2020-2021 Category of Finding: Cash Management Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: There are two Departments responsible for overseeing the program. One of these Departments, the Clark County Department of Comprehensive Planning, did not have adequate procedures in place to ensure segregation of duties for the preparation and approval of reimbursements through March 2023, when additional control procedures were implemented in response to an audit recommendation from the fiscal year 2021-2022 single audit. One reimbursement made prior to March 2023 for $82 thousand was requested by the Department for the wrong grant agreement. This error was subsequently corrected by the Department upon notification from the grantor. One reimbursement made after March 2023 for $1.08 million was selected and did not have adequate documentation to verify segregation of duties. Cause: The Clark County Department of Comprehensive Planning did not have adequate procedures in place to ensure segregation of duties surrounding reimbursement requests prior to March, 2023 and did not sufficiently adhere to additional control procedures implemented in March 2023. Effect: Insufficient internal controls over reimbursement requests could result in the program being noncompliant with federal statutes, regulations and the terms and conditions of the program. Questioned Costs: None. Context: The Southern Nevada Public Land Management Program is managed by two Clark County departments, the Department of Comprehensive Planning and the Department of Environment and Sustainability. During the fiscal year 2021-2022, inadequate documentation surrounding segregation of duties for reimbursement requests was identified. Management implemented control procedures in March 2023 to ensure adequate segregation of duties surrounding the review and approval of reimbursement requests. For fiscal year 2022-2023 the Department of Comprehensive planning oversaw $4.1 million in SNPLM funds while the Department of Environment and Sustainability oversaw $371 thousand in SNPLM funds. We selected four reimbursements from the Department of Comprehensive Planning totaling $1.9 million and three reimbursements from the Department of Environment and Sustainability totaling $144 thousand out of a population of 35 totaling $4.5 million. For fiscal year 2022-2023, $3 million out of the $4.5 million in drawdowns were processed prior to implementation of the control noted above. Of the seven reimbursement requests selected, one reimbursement from the Department of Comprehensive Planning for $82 thousand was requested under the incorrect grant due to an error in initial set up of the grant in the financial system. This error was prior to the implementation of control procedures implemented to ensure adequate segregation of duties in March 2023 and was corrected prior to testing after receiving communications from the grantor. Of the seven reimbursement requests selected, one reimbursement from the Department of Comprehensive Planning made after March 2023 for $1.08 million was selected and did not have adequate documentation to verify segregation of duties. Identification of a repeat finding: Yes. Recommendation: We recommend that management ensure their revised control procedures for drawdowns be applied to all drawdowns processed by the Department of Comprehensive Planning. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2023-003: AL No.: Federal Agency: Award No: Award Year: Category of Finding: Internal Controls Over Reimbursement Requests - Material Weakness Program Southern Nevada Public Land Management Program 15.235 Federal Bureau of Land Management L 16AC00098, L 17 AC00040, L20AC00064, L20AC00069, and L20AC00075 Fiscal year 20I6-2017, 20 I 9-2020, and 2020-2021 Cash Management Context: The Southern Nevada Public Land Management Program is managed by two Clark County depmiments, the Depmiment of Comprehensive Planning and the Department of Environment and Sustainability. During the fiscal year 2021-2022, inadequate documentation sunounding segregation of duties for reimbursement requests was identified. Management implemented control procedures in March 2023 to ensure adequate segregation of duties sunounding the review and approval of reimbursement requests. During the fiscal year 2022-2023, reimbursement control procedures updated in March 2023 were not strictly adhered to by the Depmiment of Comprehensive Planning for documenting segregation of duties. Remedy: The Standards of Procedures (SOP) for the Department of Comprehensive Planning has been updated to include the segregation of duties for SNPLMA reimbursement requests. Effective immediately, the Senior Management Analyst will be required to review and submit reimbursement requests to the department director electronically with the following language included in the e-mail: "I, Senior Management Analyst Tamara Williams, have reviewed the reimbursement requests for accuracy on XX/XX/XXXX. I am submitting it for review and signature approval to the Director of Comprehensive Planning, Sami Real." The SOP has been updated to include that upon receipt of the approval, the Senior Management Analyst will archive a copy of the reimbursement request. Sami Real Director of Comprehensive Planning
2022-005
The County did not have adequate procedures in place to ensure segregation of duties for the preparation and approval of reports through February 2023 when additional control procedures were implemented. Cause: The County did not have adequate procedures for internal controls surrounding reporting to ensure requirements were met. Effect: Failure to adhere to internal control procedures to ensure the accuracy of reports in accordance with federal regulations could result in the program being noncompliant with federal statues, regulations and the terms and conditions of the federal awards. Questioned Costs: None. Context: The County has 12 active Southern Nevada Public Land Management grants. During the fiscal year 2021-2022 audit, inadequate documentation surrounding segregation of duties for grant reporting was identified. Management indicated control procedures were updated in February 2023 to ensure adequate documentation of segregation of duties surrounding the preparation and approval of grant reports. We tested four annual financial reports and nine quarterly performance reports and did not identify any compliance matters. Identification of a repeat finding: Yes. Recommendation: We recommend that management ensure their revised procedures include a separate independent review over report preparation that is applied to all reports. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2023-004: Internal Controls Over Reporting Significant Deficiency Program: Southern Nevada Public Land Management Program Assistance Listing No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No.: L16AC00098, L17AC00040, L17AC00076, L20AC00064, 20AC00065, 20AC00066, 20AC00067, L20AC00069, L20AC00075, L23AC00009, L23AC00018, and L23AC00019 Award Year: Fiscal year 2016-2017, 2018-2019, 2019-2020, 2020-2021, and 2022-2023 Category of Finding: Reporting Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in Standards for Internal Control in the Federal Government issued by the Comptroller General of the United States or the Internal Control Integrated Framework, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County did not have adequate procedures in place to ensure segregation of duties for the preparation and approval of reports through February 2023 when additional control procedures were implemented. Cause: The County did not have adequate procedures for internal controls surrounding reporting to ensure requirements were met. Effect: Failure to adhere to internal control procedures to ensure the accuracy of reports in accordance with federal regulations could result in the program being noncompliant with federal statues, regulations and the terms and conditions of the federal awards. Questioned Costs: None. Context: The County has 12 active Southern Nevada Public Land Management grants. During the fiscal year 2021-2022 audit, inadequate documentation surrounding segregation of duties for grant reporting was identified. Management indicated control procedures were updated in February 2023 to ensure adequate documentation of segregation of duties surrounding the preparation and approval of grant reports. We tested four annual financial reports and nine quarterly performance reports and did not identify any compliance matters. Identification of a repeat finding: Yes. Recommendation: We recommend that management ensure their revised procedures include a separate independent review over report preparation that is applied to all reports. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding #: 2023-004 Internal Controls over Reporting – TBD Category of Finding: Reporting Program: Southern Nevada Public Land Management Program AL No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No.: L17AC00076, L17AC00077, L20AC00065, L20AC00066, L20AC000067 Award Year: Fiscal Y e2ar 20 2-2023 To remedy the cause resulting in the finding the County did not have adequate procedures for internal controls to ensure reports. met requirements and were submitted timely. The Department of Environment and Sustainability’s has implemented the following strategy to ensure that proper internal controls are in place moving forward: Context: Annual Financial Report did not have adequate support indicating segregation of duties regarding preparation and approval over the report. Remedy: The Department of Environment and Sustainability has updated the standard operating procedures (SOP) to require the Administrative Specialist submit the prepared SF425 to our Director electronically with the following language included in the email: “I, Administrative Specialist Sharon McLeish, have prepared the SF-425 on XX/XX/XXXX. I am submitting it for review and signature approval to the Director of Environment and Sustainability Marci Henson.” The SOP has been updated to include that upon return of the signed form from the Director, the Administrative Assistant will. perform a verification of the Director’s signature and date. The SOP was also updated to require the email chain that includes. the attestation of preparation and signature approval be archived with the SF425. Context: Quarterly Progress Reports did not have the adequate support indicating segregation of duties regarding preparation and approval over the report. Remedy: The Department of Environment and Sustainability has updated the standard operating procedures (SOP) to require the Project Managers to submit the prepared Quarterly Progress Reports to the Program Lead electronically with the following. language included in the email: “I, (Title/Employee), have prepared the FYXX QX Quarterly Progress Report on XX/XX/XXXX. I am submitting it for review. and electronic approval to the Principal Environmental Specialist, Kimberley Jenkins.” The SOP has been updated to include that upon receipt of the approval of the Quarterly Progress Report, the Project Manager will archive a copy of the report and approval. Sincerely, Jodi Bechtel, Deputy Director Department of Environment and Sustainability
2022-004
FAC accepted this audit on December 20, 2022 — management decision was due June 20, 2023.
Finding 2022-002: Allowable Costs and Eligibility - Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of the Treasury ? Direct Award Program Award No.: 1505-0266, 24599, USDT-ERAP2021, ERA0117, 2021 CAA CCSS, 2022 CAA CCSS, CCERA2-2021 Award Year: Fiscal year 2021-2022 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility. Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Cause: The Clark County Social Services Department was required to quickly develop a procedure to process applications for higher priority Cares Housing Assistance Program (CHAP) applications, such as those related to evictions moving through the Clark County Court system. As a result, the procedure was not properly designed to ensure adequate controls over the application review process. Effect: Transactions that follow a process without adequate segregation of duties may lead to noncompliant disbursements. Without strong internal controls over participant eligibility, ineligible participants may benefit from federally funded programs. Lack of a separate independent review over these transactions involving allowability and eligibility determinations could result in additional noncompliance with federal requirements. Questioned Costs: None Context: This matter was identified in the prior fiscal years single audit, management implemented a control but was unable to complete a retroactive review of applications that had already been processed by the Social Services department in the fiscal year. During our testing Crowe did not identify any instances of noncompliance during our testing of 74 applications, 30 of which were processed through the Social Services department. Identification of a repeat finding: Yes Recommendation: We recommend that the County ensure their revised procedures that include a separate independent review surrounding determinations of eligibility and allowability for disbursements to applicants prior to disbursement be applied to all Emergency Rental Assistance applications processed by the Social Services Department. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2022-002: Allowable Costs and Eligibility - Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of the Treasury ? Direct Award Program Award No.: 1505-0266, 24599, USDT-ERAP2021, ERA0117, 2021 CAA CCSS, 2022 CAA CCSS, CCERA2-2021 Award Year: Fiscal year 2021-2022 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility. Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Cause: The Clark County Social Services Department was required to quickly develop a procedure to process applications for higher priority Cares Housing Assistance Program (CHAP) applications, such as those related to evictions moving through the Clark County Court system. As a result, the procedure was not properly designed to ensure adequate controls over the application review process. Effect: Transactions that follow a process without adequate segregation of duties may lead to noncompliant disbursements. Without strong internal controls over participant eligibility, ineligible participants may benefit from federally funded programs. Lack of a separate independent review over these transactions involving allowability and eligibility determinations could result in additional noncompliance with federal requirements. Questioned Costs: None Context: This matter was identified in the prior fiscal years single audit, management implemented a control but was unable to complete a retroactive review of applications that had already been processed by the Social Services department in the fiscal year. During our testing Crowe did not identify any instances of noncompliance during our testing of 74 applications, 30 of which were processed through the Social Services department. Identification of a repeat finding: Yes Recommendation: We recommend that the County ensure their revised procedures that include a separate independent review surrounding determinations of eligibility and allowability for disbursements to applicants prior to disbursement be applied to all Emergency Rental Assistance applications processed by the Social Services Department. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2022-002: Allowable Costs and Eligibility - Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of Treasury Award No.: 1505-0266, 24599, USDT-ERAP2021, ERA0117, 2021 CM CCSS, 2022 CM CCSS, CCERA2-2021 Award Year: Fiscal year 2021-2022 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility The Department acknowledges and agrees with the finding. To ensure proper internal controls are in place for cases processed directly by Clark County Department of Social Service employees, during FY23 the Department implemented an independent secondary review procedure over allowability and eligibility determinations prior to the disbursement of funds. Evidence of secondary review has since been sufficiently documented in each case. A review checklist, standard operating procedures, and staff training has been implemented since the discovery of the finding. Randy Reinoso Deputy Director
2021-002
The County did not have an effective system of internal control in place to ensure subrecipient payments were made within 30 days of receiving the subrecipients complete payment request. Cause: Staffing challenges within the Clark County Social Services Department lead to delays in payments beyond the 30 day requirement. Effect: The County was not in compliance with the requirement to pay subrecipients within 30 days of receiving a complete payment request. Questioned Costs: None Context: During fiscal year 21/22 the Emergency Solutions Grants Program had roughly 335 subrecipient payments totaling $11,013,872. Crowe tested a sample of 28 subrecipient payments totaling $2,545,919, of which 11 selections totaling $60,701 were not paid within 30 days of receiving the reimbursement request from the subrecipient. Late payments over the 30 day deadline ranged from 4 to 93 days. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that the County strengthen controls surrounding the timely payment of subrecipients within the 30 day requirement. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2022-003: Special Tests and Provision ? Significant Deficiency Program: Emergency Solutions Grant Program Assistance Listing No.: 14.231 Federal Agency: Department of Housing and Urban Development Award No.: E-21-UC-32-0001, E-20-UW-32-001, E-20-DW-32-0001, E-20-UC-32-0001 Award Year: Fiscal year 2021-2022 Category of Finding: Special Tests and Provisions Criteria or Specific Requirement: The U.S. Department of Housing and Urban Development (HUD) requires that payments to subrecipients for allowable costs be made within 30 days after receiving the subrecipients complete payment request. Condition: The County did not have an effective system of internal control in place to ensure subrecipient payments were made within 30 days of receiving the subrecipients complete payment request. Cause: Staffing challenges within the Clark County Social Services Department lead to delays in payments beyond the 30 day requirement. Effect: The County was not in compliance with the requirement to pay subrecipients within 30 days of receiving a complete payment request. Questioned Costs: None Context: During fiscal year 21/22 the Emergency Solutions Grants Program had roughly 335 subrecipient payments totaling $11,013,872. Crowe tested a sample of 28 subrecipient payments totaling $2,545,919, of which 11 selections totaling $60,701 were not paid within 30 days of receiving the reimbursement request from the subrecipient. Late payments over the 30 day deadline ranged from 4 to 93 days. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that the County strengthen controls surrounding the timely payment of subrecipients within the 30 day requirement. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2022-003: Special Tests and Provision ? Significant Deficiency Program: Emergency Solutions Grant program Passed through Nevada Department of Public Safety CFDA No.: 14.231 Federal Agency: Department of Housing and Urban Development Award No.: E-21-UC-32-0001, E-20-UW-32-001, E-20-DW-32-0001, E-20-UC-32-0001 Award Year: Fiscal year 2021-2022 To remedy the condition, cause, and effect resulting in the finding regarding payments to subrecipients for allowable costs to be made within 30 days after receiving the subrecipients complete payment request: Clark County Social Service- Community Resources Management ? Community Resources Management leadership has taken an active role to increase our compliance with HUD regulations by creating an internal Accounts Payable process for reimbursement for all of our grants, including ESG. This process outlines the entire reimbursement process from beginning to end, including the required actions for each staff member involved. ? As an additional step, CRM has also implemented the use of the ?Invoice Status Sheet?. This sheet will be created and maintained for each ESG reimbursement to track different actions taken for each invoice. This sheet will be useful in providing detail of reasoning behind delayed reimbursement processing as well as assist staff in maintaining more accurate records. ? Lastly, invoice trackers have been created for all grants, including ESG. The invoice tracker tracks each invoice received, and includes dates for when invoices are received, when invoices are routed through each step of the process, and when they are submitted to the Comptroller?s Office for payment. The tracker is located in a shared accessible folder and will be monitored by the CRM Accountant and Manager to ensure payments are submitted for payment within 30 days. These changes were introduced to the CRM team on March 7, 2023. Sincerely, Kristin Cooper, Deputy Director Clark County Social Service
The County did not have adequate documentation of internal controls to ensure reports met requirements and were submitted timely. Cause: The County did not have adequate procedures for internal controls surrounding reporting to ensure requirements were met. Effect: Failure to implement sufficient internal controls to ensure the accuracy and timely filing of reports in accordance with federal regulations could result in the program being noncompliant with federal statues, regulations and the terms and conditions of the federal awards and resulted in a material reporting error. Questioned Costs: None Context: The County has 10 active grants for the program, based on timing of execution the County issued 10 Annual Financial Reports and 31 Quarterly Performance Reports during the year under audit. Crowe?s testing of 2 Annual Financial Reports and 7 Quarterly Performance Reports Crowe identified the following: - 2 of the Annual Financial Reports did not have adequate support indicating segregation of duties regarding preparation and approval over the report. - 1 of the Annual Financial Report's Federal Share of Expenditure was not properly reported. The amount reported for federal share of expenditures was $1,065,222.04 while the expenditures incurred by that point were $3,008,504.18, a $1,943,282.14 difference. - 7 of the Quarterly Progress Reports did not have adequate support indicating segregation of duties regarding preparation and approval over the report. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend the County to formalize the preparation and review process for Southern Nevada Public Land Management grant reports, including retention of preparation and approval documentation. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2022-004: Reporting ? Material Weakness Program: Southern Nevada Public Land Management Program Assistance Listing No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No.: L16AC0098, L16AC00099, L17AC00041, L17AC00040, L17AC00077, L17AC00076, L20AC00065, L20AC00067, L20AC00070, L20AC00075, L20AC00069 Award Year: Fiscal year 2021-2022 Category of Finding: Reporting Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County did not have adequate documentation of internal controls to ensure reports met requirements and were submitted timely. Cause: The County did not have adequate procedures for internal controls surrounding reporting to ensure requirements were met. Effect: Failure to implement sufficient internal controls to ensure the accuracy and timely filing of reports in accordance with federal regulations could result in the program being noncompliant with federal statues, regulations and the terms and conditions of the federal awards and resulted in a material reporting error. Questioned Costs: None Context: The County has 10 active grants for the program, based on timing of execution the County issued 10 Annual Financial Reports and 31 Quarterly Performance Reports during the year under audit. Crowe?s testing of 2 Annual Financial Reports and 7 Quarterly Performance Reports Crowe identified the following: - 2 of the Annual Financial Reports did not have adequate support indicating segregation of duties regarding preparation and approval over the report. - 1 of the Annual Financial Report's Federal Share of Expenditure was not properly reported. The amount reported for federal share of expenditures was $1,065,222.04 while the expenditures incurred by that point were $3,008,504.18, a $1,943,282.14 difference. - 7 of the Quarterly Progress Reports did not have adequate support indicating segregation of duties regarding preparation and approval over the report. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend the County to formalize the preparation and review process for Southern Nevada Public Land Management grant reports, including retention of preparation and approval documentation. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2022-004: Reporting Material Weakness Program: Southern Nevada Public Land Management Program AL No.: 15.235 Federal Agency:Federal Bureau of Land Management Award No: L16AC00098, L17AC00041, Ll7AC00040, L20AC00075, L20AC00069, L20AC00070 Award Year: FY 2021-2022 Category of Finding: Reporting Context: Annual Financial Reports did not have adequate support documentation indicating segregation of duties regarding preparation and approval over the report. Remedy: The Department of Comprehensive Planning Standard Operating Procedures (SOP) have been updated to require the Senior Management Analyst submit the prepared SF425 to our Director electronically with the following language included in the e-mail: "I, Senior Management Analyst Tamara Williams, have prepared the SF425 on XX/XX/XXXX. I am submitting it for review and signature approval to the Director of Comprehensive Planning, Nancy A. Amundsen ." The SOP has been updated to include that upon return of the signed form from the Director, the Executive Assistant will perform a verification of the Director's signature and date. The SOP will also be updated to require the e-mail chain that includes the attestation of preparation and signature approval be archived with the SF425. Context: Quarterly Progress Reports did not have the adequate support indicating segregation of duties regarding preparation and approval over the report. Remedy: The Department of Comprehensive Planning has updated the standard operating procedures (SOP) to require the Senior Management Analyst to submit the prepared Quarterly Progress Reports to the Assistant Planning Manager electronically with the following language included in the email: "I, Senior Management Analyst Tamara Williams, have prepared the FYXX QX Quarterly Progress Report on XX/XX/XXXXX. I am submitting it for review and electronic approval to the Director of Comprehensive Planning, Nancy A. Amundsen." The SOP has been updated to include that upon receipt of the approval of the Quarterly Progress Rep01t, the Senior Management Analyst will archive a copy of the report and approval. Sincerely, Nancy A. Amudsen Department of Comprehensive Planning Finding #: 2022-004 Reporting - Material Weakness Program: Southern Nevada Public Land Management Program AL No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No.: L17AC00076, L17AC00077, L20AC00065, L20AC000067 Award Year: Fiscal Year 2021-2022 To remedy the cause resulting in the finding the County did not have adequate procedures for internal controls to ensure reports met requirements and were submitted timely. The Department of Environment and Sustainability?s has implemented the following strategy to ensure that proper internal controls are in place moving forward: Context: Annual Financial Report did not have adequate support indicating segregation of duties regarding preparation and approval over the report. Remedy: The Department of Environment and Sustainability has updated the standard operating procedures (SOP) to require the Administrative Specialist submit the prepared SF425 to our Director electronically with the following language included in the email: ?I, Administrative Specialist Sharon McLeish, have prepared the SF-425 on XX/XX/XXXX. I am submitting it for review and signature approval to the Director of Environment and Sustainability Marci Henson.? The SOP has been updated to include that upon return of the signed form from the Director, the Administrative Assistant will perform a verification of the Director?s signature and date. The SOP was also updated to require the email chain that includes the attestation of preparation and signature approval be archived with the SF425. Context: Quarterly Progress Reports did not have the adequate support indicating segregation of duties regarding preparation and approval over the report. Remedy: The Department of Environment and Sustainability has updated the standard operating procedures (SOP) to require the Project Managers to submit the prepared Quarterly Progress Reports to the Program Lead electronically with the following language included in the email: ?I, (Title/Employee), have prepared the FYXX QX Quarterly Progress Report on XX/XX/XXXX. I am submitting it for review and electronic approval to the Principal Environmental Specialist, Kimberley Jenkins.? The SOP has been updated to include that upon receipt of the approval of the Quarterly Progress Report, the Project Manager will archive a copy of the report and approval. Sincerely, Jodi Bechtel, Deputy Director Department of Environment and Sustainability
Upon testing 4 reimbursement requests related to the Southern Nevada Public Land Management within the Clark County Department of Comprehensive Planning we were unable to obtain documentation verifying segregation of duties. Cause: The Clark County Department of Comprehensive Planning did not have adequate procedures in place to ensure adequate segregation of duties surrounding reimbursement requests. Effect: Insufficient internal controls over reimbursement requests could result in the program being noncompliant with federal statutes, regulations and the terms and conditions of the program. Questioned Costs: None. Context: The Southern Nevada Public Land Management Program is managed by two Clark County departments, the Department of Comprehensive Planning and the Department of Environment and Sustainability. For fiscal year 21/22 the Department of Comprehensive planning oversaw $5.1m in SNPLM funds while the Department of Environment and Sustainability oversaw $1.3m in SNPLM funds. We selected 4 reimbursements from the Department of Comprehensive Planning totaling $3.6m and 4 reimbursements from the Department of Environment and Sustainability totaling $84k out of a population of 111 totaling $6.6m. During the testing of the 4 reimbursement requests from the Department of Comprehensive Planning We noted that there was not supporting documentation for adequate segregation of duties for the reimbursements requests that include documentation of a separate preparer and approver. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management strengthen their internal controls policies and procedures related to reimbursement requests for the Southern Nevada Public Land Management program. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2022-005: Internal Controls Over Reimbursement Requests ? Material Weakness Program: Southern Nevada Public Land Management Program Assistance Listing No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No.: L16AC0098, L16AC00099, L17AC00041, L17AC00040, L17AC00077, L17AC00076, L20AC00065, L20AC00067, L20AC00070, L20AC00075, L20AC00069 Award Year: Fiscal year 2021-2022 Category of Finding: Cash Management Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Upon testing 4 reimbursement requests related to the Southern Nevada Public Land Management within the Clark County Department of Comprehensive Planning we were unable to obtain documentation verifying segregation of duties. Cause: The Clark County Department of Comprehensive Planning did not have adequate procedures in place to ensure adequate segregation of duties surrounding reimbursement requests. Effect: Insufficient internal controls over reimbursement requests could result in the program being noncompliant with federal statutes, regulations and the terms and conditions of the program. Questioned Costs: None. Context: The Southern Nevada Public Land Management Program is managed by two Clark County departments, the Department of Comprehensive Planning and the Department of Environment and Sustainability. For fiscal year 21/22 the Department of Comprehensive planning oversaw $5.1m in SNPLM funds while the Department of Environment and Sustainability oversaw $1.3m in SNPLM funds. We selected 4 reimbursements from the Department of Comprehensive Planning totaling $3.6m and 4 reimbursements from the Department of Environment and Sustainability totaling $84k out of a population of 111 totaling $6.6m. During the testing of the 4 reimbursement requests from the Department of Comprehensive Planning We noted that there was not supporting documentation for adequate segregation of duties for the reimbursements requests that include documentation of a separate preparer and approver. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management strengthen their internal controls policies and procedures related to reimbursement requests for the Southern Nevada Public Land Management program. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2022-005: Internal Controls Over Reimbursement Requests - Material Weakness Program: Southern Nevada Public Land Management Program AL No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No: L16AC00098, L17AC00041, L17AC00040, L20AC00075, L20AC00069, L20AC00070 Award Year: FY 2021-2022 Category of Finding: Cash Management Context: The Clark County Department of Comprehensive Planning did not have adequate procedures in place to ensure adequate segregation of duties surrounding reimbursement requests. Remedy: The Department of Real Property Management Design & Construction (D&C) initially approves reimbursement requests from contractors that are then approved by the Department of Finance. The Department of Comprehensive Planning Standard Operating Procedures (SOP) have been updated to require the Senior Management Analyst submit the reimbursement requests to our Director electronically with the following language included in the e-mail: "I, Senior Management Analyst Tamara Williams, have reviewed the reimbursement requests for FYXX QX on XX/XX/XXXX. I am submitting it for review and signature approval to the Director of Comprehensive Planning, Nancy A. Amundsen." The SOP has been updated to include that upon receipt of the approval of the reimbursement request, the Senior Management Analyst will archive a copy of the request and approval. Sincerely, Nancy A. Amudsen Department of Comprehensive Planning
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
Finding 2022-002: Allowable Costs and Eligibility - Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of the Treasury ? Direct Award Program Award No.: 1505-0266, 24599, USDT-ERAP2021, ERA0117, 2021 CAA CCSS, 2022 CAA CCSS, CCERA2-2021 Award Year: Fiscal year 2021-2022 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility. Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Cause: The Clark County Social Services Department was required to quickly develop a procedure to process applications for higher priority Cares Housing Assistance Program (CHAP) applications, such as those related to evictions moving through the Clark County Court system. As a result, the procedure was not properly designed to ensure adequate controls over the application review process. Effect: Transactions that follow a process without adequate segregation of duties may lead to noncompliant disbursements. Without strong internal controls over participant eligibility, ineligible participants may benefit from federally funded programs. Lack of a separate independent review over these transactions involving allowability and eligibility determinations could result in additional noncompliance with federal requirements. Questioned Costs: None Context: This matter was identified in the prior fiscal years single audit, management implemented a control but was unable to complete a retroactive review of applications that had already been processed by the Social Services department in the fiscal year. During our testing Crowe did not identify any instances of noncompliance during our testing of 74 applications, 30 of which were processed through the Social Services department. Identification of a repeat finding: Yes Recommendation: We recommend that the County ensure their revised procedures that include a separate independent review surrounding determinations of eligibility and allowability for disbursements to applicants prior to disbursement be applied to all Emergency Rental Assistance applications processed by the Social Services Department. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2022-002: Allowable Costs and Eligibility - Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of the Treasury ? Direct Award Program Award No.: 1505-0266, 24599, USDT-ERAP2021, ERA0117, 2021 CAA CCSS, 2022 CAA CCSS, CCERA2-2021 Award Year: Fiscal year 2021-2022 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility. Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Cause: The Clark County Social Services Department was required to quickly develop a procedure to process applications for higher priority Cares Housing Assistance Program (CHAP) applications, such as those related to evictions moving through the Clark County Court system. As a result, the procedure was not properly designed to ensure adequate controls over the application review process. Effect: Transactions that follow a process without adequate segregation of duties may lead to noncompliant disbursements. Without strong internal controls over participant eligibility, ineligible participants may benefit from federally funded programs. Lack of a separate independent review over these transactions involving allowability and eligibility determinations could result in additional noncompliance with federal requirements. Questioned Costs: None Context: This matter was identified in the prior fiscal years single audit, management implemented a control but was unable to complete a retroactive review of applications that had already been processed by the Social Services department in the fiscal year. During our testing Crowe did not identify any instances of noncompliance during our testing of 74 applications, 30 of which were processed through the Social Services department. Identification of a repeat finding: Yes Recommendation: We recommend that the County ensure their revised procedures that include a separate independent review surrounding determinations of eligibility and allowability for disbursements to applicants prior to disbursement be applied to all Emergency Rental Assistance applications processed by the Social Services Department. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2022-002: Allowable Costs and Eligibility - Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of Treasury Award No.: 1505-0266, 24599, USDT-ERAP2021, ERA0117, 2021 CM CCSS, 2022 CM CCSS, CCERA2-2021 Award Year: Fiscal year 2021-2022 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility The Department acknowledges and agrees with the finding. To ensure proper internal controls are in place for cases processed directly by Clark County Department of Social Service employees, during FY23 the Department implemented an independent secondary review procedure over allowability and eligibility determinations prior to the disbursement of funds. Evidence of secondary review has since been sufficiently documented in each case. A review checklist, standard operating procedures, and staff training has been implemented since the discovery of the finding. Randy Reinoso Deputy Director
2021-002
The County did not have an effective system of internal control in place to ensure subrecipient payments were made within 30 days of receiving the subrecipients complete payment request. Cause: Staffing challenges within the Clark County Social Services Department lead to delays in payments beyond the 30 day requirement. Effect: The County was not in compliance with the requirement to pay subrecipients within 30 days of receiving a complete payment request. Questioned Costs: None Context: During fiscal year 21/22 the Emergency Solutions Grants Program had roughly 335 subrecipient payments totaling $11,013,872. Crowe tested a sample of 28 subrecipient payments totaling $2,545,919, of which 11 selections totaling $60,701 were not paid within 30 days of receiving the reimbursement request from the subrecipient. Late payments over the 30 day deadline ranged from 4 to 93 days. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that the County strengthen controls surrounding the timely payment of subrecipients within the 30 day requirement. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2022-003: Special Tests and Provision ? Significant Deficiency Program: Emergency Solutions Grant Program Assistance Listing No.: 14.231 Federal Agency: Department of Housing and Urban Development Award No.: E-21-UC-32-0001, E-20-UW-32-001, E-20-DW-32-0001, E-20-UC-32-0001 Award Year: Fiscal year 2021-2022 Category of Finding: Special Tests and Provisions Criteria or Specific Requirement: The U.S. Department of Housing and Urban Development (HUD) requires that payments to subrecipients for allowable costs be made within 30 days after receiving the subrecipients complete payment request. Condition: The County did not have an effective system of internal control in place to ensure subrecipient payments were made within 30 days of receiving the subrecipients complete payment request. Cause: Staffing challenges within the Clark County Social Services Department lead to delays in payments beyond the 30 day requirement. Effect: The County was not in compliance with the requirement to pay subrecipients within 30 days of receiving a complete payment request. Questioned Costs: None Context: During fiscal year 21/22 the Emergency Solutions Grants Program had roughly 335 subrecipient payments totaling $11,013,872. Crowe tested a sample of 28 subrecipient payments totaling $2,545,919, of which 11 selections totaling $60,701 were not paid within 30 days of receiving the reimbursement request from the subrecipient. Late payments over the 30 day deadline ranged from 4 to 93 days. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that the County strengthen controls surrounding the timely payment of subrecipients within the 30 day requirement. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2022-003: Special Tests and Provision ? Significant Deficiency Program: Emergency Solutions Grant program Passed through Nevada Department of Public Safety CFDA No.: 14.231 Federal Agency: Department of Housing and Urban Development Award No.: E-21-UC-32-0001, E-20-UW-32-001, E-20-DW-32-0001, E-20-UC-32-0001 Award Year: Fiscal year 2021-2022 To remedy the condition, cause, and effect resulting in the finding regarding payments to subrecipients for allowable costs to be made within 30 days after receiving the subrecipients complete payment request: Clark County Social Service- Community Resources Management ? Community Resources Management leadership has taken an active role to increase our compliance with HUD regulations by creating an internal Accounts Payable process for reimbursement for all of our grants, including ESG. This process outlines the entire reimbursement process from beginning to end, including the required actions for each staff member involved. ? As an additional step, CRM has also implemented the use of the ?Invoice Status Sheet?. This sheet will be created and maintained for each ESG reimbursement to track different actions taken for each invoice. This sheet will be useful in providing detail of reasoning behind delayed reimbursement processing as well as assist staff in maintaining more accurate records. ? Lastly, invoice trackers have been created for all grants, including ESG. The invoice tracker tracks each invoice received, and includes dates for when invoices are received, when invoices are routed through each step of the process, and when they are submitted to the Comptroller?s Office for payment. The tracker is located in a shared accessible folder and will be monitored by the CRM Accountant and Manager to ensure payments are submitted for payment within 30 days. These changes were introduced to the CRM team on March 7, 2023. Sincerely, Kristin Cooper, Deputy Director Clark County Social Service
The County did not have adequate documentation of internal controls to ensure reports met requirements and were submitted timely. Cause: The County did not have adequate procedures for internal controls surrounding reporting to ensure requirements were met. Effect: Failure to implement sufficient internal controls to ensure the accuracy and timely filing of reports in accordance with federal regulations could result in the program being noncompliant with federal statues, regulations and the terms and conditions of the federal awards and resulted in a material reporting error. Questioned Costs: None Context: The County has 10 active grants for the program, based on timing of execution the County issued 10 Annual Financial Reports and 31 Quarterly Performance Reports during the year under audit. Crowe?s testing of 2 Annual Financial Reports and 7 Quarterly Performance Reports Crowe identified the following: - 2 of the Annual Financial Reports did not have adequate support indicating segregation of duties regarding preparation and approval over the report. - 1 of the Annual Financial Report's Federal Share of Expenditure was not properly reported. The amount reported for federal share of expenditures was $1,065,222.04 while the expenditures incurred by that point were $3,008,504.18, a $1,943,282.14 difference. - 7 of the Quarterly Progress Reports did not have adequate support indicating segregation of duties regarding preparation and approval over the report. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend the County to formalize the preparation and review process for Southern Nevada Public Land Management grant reports, including retention of preparation and approval documentation. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2022-004: Reporting ? Material Weakness Program: Southern Nevada Public Land Management Program Assistance Listing No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No.: L16AC0098, L16AC00099, L17AC00041, L17AC00040, L17AC00077, L17AC00076, L20AC00065, L20AC00067, L20AC00070, L20AC00075, L20AC00069 Award Year: Fiscal year 2021-2022 Category of Finding: Reporting Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: The County did not have adequate documentation of internal controls to ensure reports met requirements and were submitted timely. Cause: The County did not have adequate procedures for internal controls surrounding reporting to ensure requirements were met. Effect: Failure to implement sufficient internal controls to ensure the accuracy and timely filing of reports in accordance with federal regulations could result in the program being noncompliant with federal statues, regulations and the terms and conditions of the federal awards and resulted in a material reporting error. Questioned Costs: None Context: The County has 10 active grants for the program, based on timing of execution the County issued 10 Annual Financial Reports and 31 Quarterly Performance Reports during the year under audit. Crowe?s testing of 2 Annual Financial Reports and 7 Quarterly Performance Reports Crowe identified the following: - 2 of the Annual Financial Reports did not have adequate support indicating segregation of duties regarding preparation and approval over the report. - 1 of the Annual Financial Report's Federal Share of Expenditure was not properly reported. The amount reported for federal share of expenditures was $1,065,222.04 while the expenditures incurred by that point were $3,008,504.18, a $1,943,282.14 difference. - 7 of the Quarterly Progress Reports did not have adequate support indicating segregation of duties regarding preparation and approval over the report. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend the County to formalize the preparation and review process for Southern Nevada Public Land Management grant reports, including retention of preparation and approval documentation. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2022-004: Reporting Material Weakness Program: Southern Nevada Public Land Management Program AL No.: 15.235 Federal Agency:Federal Bureau of Land Management Award No: L16AC00098, L17AC00041, Ll7AC00040, L20AC00075, L20AC00069, L20AC00070 Award Year: FY 2021-2022 Category of Finding: Reporting Context: Annual Financial Reports did not have adequate support documentation indicating segregation of duties regarding preparation and approval over the report. Remedy: The Department of Comprehensive Planning Standard Operating Procedures (SOP) have been updated to require the Senior Management Analyst submit the prepared SF425 to our Director electronically with the following language included in the e-mail: "I, Senior Management Analyst Tamara Williams, have prepared the SF425 on XX/XX/XXXX. I am submitting it for review and signature approval to the Director of Comprehensive Planning, Nancy A. Amundsen ." The SOP has been updated to include that upon return of the signed form from the Director, the Executive Assistant will perform a verification of the Director's signature and date. The SOP will also be updated to require the e-mail chain that includes the attestation of preparation and signature approval be archived with the SF425. Context: Quarterly Progress Reports did not have the adequate support indicating segregation of duties regarding preparation and approval over the report. Remedy: The Department of Comprehensive Planning has updated the standard operating procedures (SOP) to require the Senior Management Analyst to submit the prepared Quarterly Progress Reports to the Assistant Planning Manager electronically with the following language included in the email: "I, Senior Management Analyst Tamara Williams, have prepared the FYXX QX Quarterly Progress Report on XX/XX/XXXXX. I am submitting it for review and electronic approval to the Director of Comprehensive Planning, Nancy A. Amundsen." The SOP has been updated to include that upon receipt of the approval of the Quarterly Progress Rep01t, the Senior Management Analyst will archive a copy of the report and approval. Sincerely, Nancy A. Amudsen Department of Comprehensive Planning Finding #: 2022-004 Reporting - Material Weakness Program: Southern Nevada Public Land Management Program AL No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No.: L17AC00076, L17AC00077, L20AC00065, L20AC000067 Award Year: Fiscal Year 2021-2022 To remedy the cause resulting in the finding the County did not have adequate procedures for internal controls to ensure reports met requirements and were submitted timely. The Department of Environment and Sustainability?s has implemented the following strategy to ensure that proper internal controls are in place moving forward: Context: Annual Financial Report did not have adequate support indicating segregation of duties regarding preparation and approval over the report. Remedy: The Department of Environment and Sustainability has updated the standard operating procedures (SOP) to require the Administrative Specialist submit the prepared SF425 to our Director electronically with the following language included in the email: ?I, Administrative Specialist Sharon McLeish, have prepared the SF-425 on XX/XX/XXXX. I am submitting it for review and signature approval to the Director of Environment and Sustainability Marci Henson.? The SOP has been updated to include that upon return of the signed form from the Director, the Administrative Assistant will perform a verification of the Director?s signature and date. The SOP was also updated to require the email chain that includes the attestation of preparation and signature approval be archived with the SF425. Context: Quarterly Progress Reports did not have the adequate support indicating segregation of duties regarding preparation and approval over the report. Remedy: The Department of Environment and Sustainability has updated the standard operating procedures (SOP) to require the Project Managers to submit the prepared Quarterly Progress Reports to the Program Lead electronically with the following language included in the email: ?I, (Title/Employee), have prepared the FYXX QX Quarterly Progress Report on XX/XX/XXXX. I am submitting it for review and electronic approval to the Principal Environmental Specialist, Kimberley Jenkins.? The SOP has been updated to include that upon receipt of the approval of the Quarterly Progress Report, the Project Manager will archive a copy of the report and approval. Sincerely, Jodi Bechtel, Deputy Director Department of Environment and Sustainability
Upon testing 4 reimbursement requests related to the Southern Nevada Public Land Management within the Clark County Department of Comprehensive Planning we were unable to obtain documentation verifying segregation of duties. Cause: The Clark County Department of Comprehensive Planning did not have adequate procedures in place to ensure adequate segregation of duties surrounding reimbursement requests. Effect: Insufficient internal controls over reimbursement requests could result in the program being noncompliant with federal statutes, regulations and the terms and conditions of the program. Questioned Costs: None. Context: The Southern Nevada Public Land Management Program is managed by two Clark County departments, the Department of Comprehensive Planning and the Department of Environment and Sustainability. For fiscal year 21/22 the Department of Comprehensive planning oversaw $5.1m in SNPLM funds while the Department of Environment and Sustainability oversaw $1.3m in SNPLM funds. We selected 4 reimbursements from the Department of Comprehensive Planning totaling $3.6m and 4 reimbursements from the Department of Environment and Sustainability totaling $84k out of a population of 111 totaling $6.6m. During the testing of the 4 reimbursement requests from the Department of Comprehensive Planning We noted that there was not supporting documentation for adequate segregation of duties for the reimbursements requests that include documentation of a separate preparer and approver. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management strengthen their internal controls policies and procedures related to reimbursement requests for the Southern Nevada Public Land Management program. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2022-005: Internal Controls Over Reimbursement Requests ? Material Weakness Program: Southern Nevada Public Land Management Program Assistance Listing No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No.: L16AC0098, L16AC00099, L17AC00041, L17AC00040, L17AC00077, L17AC00076, L20AC00065, L20AC00067, L20AC00070, L20AC00075, L20AC00069 Award Year: Fiscal year 2021-2022 Category of Finding: Cash Management Criteria or Specific Requirement: Title 2 U.S. Code of Federal Regulations Part 200 (2 CFR 200) Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, section 303(a) states, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statues, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: Upon testing 4 reimbursement requests related to the Southern Nevada Public Land Management within the Clark County Department of Comprehensive Planning we were unable to obtain documentation verifying segregation of duties. Cause: The Clark County Department of Comprehensive Planning did not have adequate procedures in place to ensure adequate segregation of duties surrounding reimbursement requests. Effect: Insufficient internal controls over reimbursement requests could result in the program being noncompliant with federal statutes, regulations and the terms and conditions of the program. Questioned Costs: None. Context: The Southern Nevada Public Land Management Program is managed by two Clark County departments, the Department of Comprehensive Planning and the Department of Environment and Sustainability. For fiscal year 21/22 the Department of Comprehensive planning oversaw $5.1m in SNPLM funds while the Department of Environment and Sustainability oversaw $1.3m in SNPLM funds. We selected 4 reimbursements from the Department of Comprehensive Planning totaling $3.6m and 4 reimbursements from the Department of Environment and Sustainability totaling $84k out of a population of 111 totaling $6.6m. During the testing of the 4 reimbursement requests from the Department of Comprehensive Planning We noted that there was not supporting documentation for adequate segregation of duties for the reimbursements requests that include documentation of a separate preparer and approver. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management strengthen their internal controls policies and procedures related to reimbursement requests for the Southern Nevada Public Land Management program. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2022-005: Internal Controls Over Reimbursement Requests - Material Weakness Program: Southern Nevada Public Land Management Program AL No.: 15.235 Federal Agency: Federal Bureau of Land Management Award No: L16AC00098, L17AC00041, L17AC00040, L20AC00075, L20AC00069, L20AC00070 Award Year: FY 2021-2022 Category of Finding: Cash Management Context: The Clark County Department of Comprehensive Planning did not have adequate procedures in place to ensure adequate segregation of duties surrounding reimbursement requests. Remedy: The Department of Real Property Management Design & Construction (D&C) initially approves reimbursement requests from contractors that are then approved by the Department of Finance. The Department of Comprehensive Planning Standard Operating Procedures (SOP) have been updated to require the Senior Management Analyst submit the reimbursement requests to our Director electronically with the following language included in the e-mail: "I, Senior Management Analyst Tamara Williams, have reviewed the reimbursement requests for FYXX QX on XX/XX/XXXX. I am submitting it for review and signature approval to the Director of Comprehensive Planning, Nancy A. Amundsen." The SOP has been updated to include that upon receipt of the approval of the reimbursement request, the Senior Management Analyst will archive a copy of the request and approval. Sincerely, Nancy A. Amudsen Department of Comprehensive Planning
FAC accepted this audit on January 25, 2022 — management decision was due July 25, 2022.
For the Edward Byrne Memorial Justice Assistance Grant Program (JAG), the County did not submit the required key data elements in FSRS in timely manner. The County did not comply with the requirement to report the information no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award modification was made. We selected seven of the thirty-six subawards for compliance testing and noted five subawards did not meet the reporting deadline by their required due dates resulting in late reporting ranging from a month to 25 months. The total amount of the five subawards not reported timely was $494,636. In addition, there was one subaward where the County reported the wrong obligation date in the FSRS. The date recorded in FSRS was March 19, 2019, while based on the source document, the date that was supposed to be recorded was September 1, 2019. Transactions Tested Subaward not reported Report not timely Subaward amounts incorrect Subaward missing key elements 7 0 5 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amounts incorrect Subaward missing key elements $581,769 0 $494,636 0 0 Cause: Controls over reporting of Federal Funding Accountability and Transparency Act were not designed and implemented to ensure timely submission of the report. In addition, there seemed to be a lack of knowledge of the compliance requirements regarding the reporting of the subawards. Effect: The County did not have effective controls in place to timely submit report information no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Questioned Costs: None. Context: During our walkthrough of the internal control assessment of the Federal Funding Accountability and Transparency Act (FFATA) reporting for the grant, we had noted there were no evidence of internal control in place to ensure the FFATA reporting was reported timely in the FSRS portal. We selected a sample of four out of thirty-six subawards pertaining to the Edward Byrne Memorial Justice Assistance Grant Program (JAG). Out of the four subawards selected, three of them were not reported timely as required by the reporting requirement under the criteria. Based on this initial observation, Crowe selected three additional subawards and noted that two out of these additional three were also untimely. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management establish and maintain effective internal control ensuring timely submission required under the Federal Funding Accountability and Transparency Act. In addition, we recommend that the County conduct formal training to ensure that management has sufficient knowledge of the applicable reporting requirements. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2021-001: Federal Funding Accountability and Transparency Act ? Significant Deficiency Program: Edward Byrne Memorial Justice Assistance Grant Program Direct award program Assistance Listing No.: 16.738 Federal Agency: Department of Justice Award No.: 2017-DJ-BX-0400, 2018-DJ-BX-0468, 2019-DJ-BX0831, 2018-DG-BX-k005, 19-JAG-15, 20-JAG-12 Award Year: Fiscal year 2020-2021 Category of Finding: Reporting Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). In addition, Title 2 CFR Appendix A to Part 170 a.2.ii. requires that for subaward information, [the County] needs to report no later than the end of the month following the month in which the obligation was made. (For example, if the obligation was made on November 7, 2010, the obligation must be reported by no later than December 31, 2010.) Condition: For the Edward Byrne Memorial Justice Assistance Grant Program (JAG), the County did not submit the required key data elements in FSRS in timely manner. The County did not comply with the requirement to report the information no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award modification was made. We selected seven of the thirty-six subawards for compliance testing and noted five subawards did not meet the reporting deadline by their required due dates resulting in late reporting ranging from a month to 25 months. The total amount of the five subawards not reported timely was $494,636. In addition, there was one subaward where the County reported the wrong obligation date in the FSRS. The date recorded in FSRS was March 19, 2019, while based on the source document, the date that was supposed to be recorded was September 1, 2019. Transactions Tested Subaward not reported Report not timely Subaward amounts incorrect Subaward missing key elements 7 0 5 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amounts incorrect Subaward missing key elements $581,769 0 $494,636 0 0 Cause: Controls over reporting of Federal Funding Accountability and Transparency Act were not designed and implemented to ensure timely submission of the report. In addition, there seemed to be a lack of knowledge of the compliance requirements regarding the reporting of the subawards. Effect: The County did not have effective controls in place to timely submit report information no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Questioned Costs: None. Context: During our walkthrough of the internal control assessment of the Federal Funding Accountability and Transparency Act (FFATA) reporting for the grant, we had noted there were no evidence of internal control in place to ensure the FFATA reporting was reported timely in the FSRS portal. We selected a sample of four out of thirty-six subawards pertaining to the Edward Byrne Memorial Justice Assistance Grant Program (JAG). Out of the four subawards selected, three of them were not reported timely as required by the reporting requirement under the criteria. Based on this initial observation, Crowe selected three additional subawards and noted that two out of these additional three were also untimely. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management establish and maintain effective internal control ensuring timely submission required under the Federal Funding Accountability and Transparency Act. In addition, we recommend that the County conduct formal training to ensure that management has sufficient knowledge of the applicable reporting requirements. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2021-001: Federal Funding Accountability and Transparency Act ? Significant Deficiency Program: Edward Byrne Memorial Justice Assistance Grant Program Direct program; Passed through Nevada Department of Public Safety AL No.: 16.738 Federal Agency: Department of Justice Award No.: 2017-DJ-BX-0400, 2018-DJ-BX-0468, 2019-DJ-BX0831, 19-JAG-15, 20-JAG-12 Award Year: Fiscal year 2020-2021 Finding 2021-001: Federal Funding Accountability and Transparency Act ? Significant Deficiency Program: Technology Innovation for Public Safety (TIPS) Addressing Precipitous Increases in Crime AL No.: 16.738 Federal Agency: Department of Justice Award No.: 2018-DG-BX-K005 Award Year: Fiscal year 2019-2020 To remedy the condition, cause, and effect resulting in the finding regarding timely FFATA (Federal Funding Accountability and Transparency Act) reporting into FSRS (FFATA Subaward Reporting System), see our team?s strategy to ensure that proper internal controls are in place moving forward: FFATA Timeliness Strategy A formal review process is being established over the FFATA reporting for all Social Service grants that includes the recurring task of reporting information monthly into FSRS no later than the last day of the month following the month in which any obligation or modification was made. This process is inclusive of all grants and projects with federal funding. ? Financial Office Specialist or Grants Coordinator completes the draft FFATA no later than the 15th of the month for the previous month for any contract execution or amendment and provides FFATA report, tracking sheet, checklist, and backup documentation to designated Senior Grants Coordinator. ? Senior Grants Coordinator reviews FFATA documentation, makes any required updates or edits, and approves FFATA for submission within 5 business days of receiving draft report. ? Financial Office Specialist or Grants Coordinator completes FFATA reporting into FSRS no later than the 25th of the month following the month in which an obligation or modification was made and ensures all files, reports, and back-up documentation are saved in the corresponding program file. ? Financial Office Specialist(s), Grants Coordinator(s) and Senior Grants Coordinator(s) will review FFATA reporting bi-monthly with management, and with other team members as needed. A routing log will be used to track the reviews and approvals of each step indicated above. Department of Social Service 1600 Pinto Lane ? Las Vegas NV 89106 (702) 455-4270 ? Fax (702) 455-5950 Timothy Burch, Administrator Kristin Cooper, Assistant Director ? Randy Reinoso, Assistant Director? Margaret LeBlanc, Assistant Director BOARD OF COUNTY COMMISSIONERS JAMES B. GIBSON Chair, JUSTIN JONES Vice Chair MARILYN KIRKPATRICK ? MICHAEL NAFT ? ROSS MILLER ? WILLIAM McCURDY II ? TICK SEGERBLOM YOLANDA KING, County Manager These steps will be formalized in CCSS Standard Operating Procedures (SOP) on or before April 28, 2022. At that time all personnel responsible for the FFATA Reporting will be trained on the SOP. Newly hired personnel responsible for FFATA reporting will be trained on the FFATA Reporting SOP within 30 days of hire. This will be formalized in their assigned training plan. The Senior Grants Coordinator will be responsible for ensuring that all assigned preparers and reviewers have completed this training within the established timeframes. Sincerely, Kristin Cooper, Assistant Director Clark County Social Service KRC@ClarkCountyNV.gov 702.455.5025 CC: Timothy Burch, Margaret LeBlanc, Anna Danchik, Colleen Boyle, Elizabeth Vorce, Michele Fuller-Hallauer, Emma Macayan-Hatley, Emma Garcia, Karen Schneider, Marylin Schoen, Claudia Young, Tara Ulmer, Brenda Herbstman, Mary Cannizzaro, Mary Duff
The County did not have an effective system of internal control in place to ensure segregation of duties for processing and review and to ensure the applications submitted were adequately documented for eligibility and calculation of benefit over a subset of disbursements in the CARES Housing Assistance Program (CHAP). During our internal control walkthrough, we identified that Clark County Social Services Department Employees would directly process applications related to CHAP applications which is separate from the process which utilized 3rd party contractors for preparation before review by Clark County. This process occurred when specific applications were identified as higher priority such as Court Cases involving evictions. Upon discussion with management, it was determined that the Social Services Department employee processed the application but there was not a subsequent independent review of applications for eligibility requirements and for allowability before disbursement for all applications subject to this process. In addition, of the 61 participant files selected for testing, we noted 4 cases where management did not have adequate documentation to support the allowable costs/activity and eligibility requirements. Cause: The Clark County Social Services Department was required to quickly develop a procedure to process applications for higher priority Cares Housing Assistance Program (CHAP) applications, such as those related to evictions moving through the Clark County Court system. As a result, the procedure was not properly designed to ensure adequate controls over the application review process. Effect: Transactions that follow a process without adequate segregation of duties may lead to noncompliant disbursements. Without strong internal controls over participant eligibility, ineligible participants may benefit from federally funded programs. Lack of a separate independent review over these transactions involving allowability and eligibility determinations could result in additional noncompliance with federal requirements. Questioned Costs: $28,205. Context: We obtained a listing of expenditures from the Emergency Rental Assistance related to CHAP that went through the Social Services Department process. Using a sampling approach, we selected 61 sample items from 1,074 participant files to verify eligibility and recalculate benefits in accordance with the policy. We found that 4 of the 61 cases selected did not have adequate supporting documentation such as income verification support for all household members and adequate support for benefit amounts, which resulted in $28,205 in known questioned costs of the $362,087 disbursements sampled. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that the County revise its procedure for reviewing Emergency Rental Assistance applications processed by the Social Services Department to include a separate independent review surrounding determinations of eligibility and allowability for disbursements to applicants prior to disbursement. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2021-002: Allowable Costs and Eligibility ? Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of the Treasury ? Direct Award Program Award No.: 1505-0266, 24599, USDT-ERAP2021, ERA0117, 2021 CAA CCSS Award Year: Fiscal year 2020-2021 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Allowable Costs - 2 CFR Part 200.403 Factors affecting allowability of costs except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also ? 200.306(b). (g) Be adequately documented. See also ?? 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3). 501(c)(2)(A) of the Consolidated Appropriations Act and section 3201(d)(1)(A) of ARPA Financial assistance to households includes payment of rent, rental arrears, utilities and home energy costs, utility and home energy costs arrears, and other expenses related to housing. Eligibility - Consolidated Appropriations Act, 2021, for ERA 1 in sections 501(c)(2)(C)(ii) of the Act concerning documentation of payments to households, sections 501(f)(2)(A) and (B) of the Act concerning signature requirements for applications and documentation required for tenants, section 501(k)(1) concerning area median income determinations, and sections 501(k)(3)(A)(I) and (II) concerning eligible household determinations and attestation requirements. Grantees must require all applications for assistance to include an attestation from the applicant household that all information included is correct and complete. In all cases, grantees must document their policies and procedures for determining household eligibility to include policies and procedures for determining the prioritization of households in compliance with the statute and maintain records of their determinations. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The County did not have an effective system of internal control in place to ensure segregation of duties for processing and review and to ensure the applications submitted were adequately documented for eligibility and calculation of benefit over a subset of disbursements in the CARES Housing Assistance Program (CHAP). During our internal control walkthrough, we identified that Clark County Social Services Department Employees would directly process applications related to CHAP applications which is separate from the process which utilized 3rd party contractors for preparation before review by Clark County. This process occurred when specific applications were identified as higher priority such as Court Cases involving evictions. Upon discussion with management, it was determined that the Social Services Department employee processed the application but there was not a subsequent independent review of applications for eligibility requirements and for allowability before disbursement for all applications subject to this process. In addition, of the 61 participant files selected for testing, we noted 4 cases where management did not have adequate documentation to support the allowable costs/activity and eligibility requirements. Cause: The Clark County Social Services Department was required to quickly develop a procedure to process applications for higher priority Cares Housing Assistance Program (CHAP) applications, such as those related to evictions moving through the Clark County Court system. As a result, the procedure was not properly designed to ensure adequate controls over the application review process. Effect: Transactions that follow a process without adequate segregation of duties may lead to noncompliant disbursements. Without strong internal controls over participant eligibility, ineligible participants may benefit from federally funded programs. Lack of a separate independent review over these transactions involving allowability and eligibility determinations could result in additional noncompliance with federal requirements. Questioned Costs: $28,205. Context: We obtained a listing of expenditures from the Emergency Rental Assistance related to CHAP that went through the Social Services Department process. Using a sampling approach, we selected 61 sample items from 1,074 participant files to verify eligibility and recalculate benefits in accordance with the policy. We found that 4 of the 61 cases selected did not have adequate supporting documentation such as income verification support for all household members and adequate support for benefit amounts, which resulted in $28,205 in known questioned costs of the $362,087 disbursements sampled. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that the County revise its procedure for reviewing Emergency Rental Assistance applications processed by the Social Services Department to include a separate independent review surrounding determinations of eligibility and allowability for disbursements to applicants prior to disbursement. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2021-002: Allowable Costs and Eligibility - Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of the Treasury Award No.: 1505-0266, 24599, USDT-ERAP2021 Award Year: Fiscal year 2020-2021 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility The County acknowledges and agrees with the finding. To ensure proper internal controls are in place for cases processed directly by Clark County Department of Social Service employees, the Department is implementing an independent review of allowability and eligibility determinations prior to the disbursement of funds. Evidence of secondary review will be suficiently documented in each case. A review checklist, standard operating procedures, and staf training has been developed and is scheduled for implementation. Sincerely, Timothy Burch Administrator
FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.
For the Edward Byrne Memorial Justice Assistance Grant Program (JAG), the County did not submit the required key data elements in FSRS in timely manner. The County did not comply with the requirement to report the information no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award modification was made. We selected seven of the thirty-six subawards for compliance testing and noted five subawards did not meet the reporting deadline by their required due dates resulting in late reporting ranging from a month to 25 months. The total amount of the five subawards not reported timely was $494,636. In addition, there was one subaward where the County reported the wrong obligation date in the FSRS. The date recorded in FSRS was March 19, 2019, while based on the source document, the date that was supposed to be recorded was September 1, 2019. Transactions Tested Subaward not reported Report not timely Subaward amounts incorrect Subaward missing key elements 7 0 5 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amounts incorrect Subaward missing key elements $581,769 0 $494,636 0 0 Cause: Controls over reporting of Federal Funding Accountability and Transparency Act were not designed and implemented to ensure timely submission of the report. In addition, there seemed to be a lack of knowledge of the compliance requirements regarding the reporting of the subawards. Effect: The County did not have effective controls in place to timely submit report information no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Questioned Costs: None. Context: During our walkthrough of the internal control assessment of the Federal Funding Accountability and Transparency Act (FFATA) reporting for the grant, we had noted there were no evidence of internal control in place to ensure the FFATA reporting was reported timely in the FSRS portal. We selected a sample of four out of thirty-six subawards pertaining to the Edward Byrne Memorial Justice Assistance Grant Program (JAG). Out of the four subawards selected, three of them were not reported timely as required by the reporting requirement under the criteria. Based on this initial observation, Crowe selected three additional subawards and noted that two out of these additional three were also untimely. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management establish and maintain effective internal control ensuring timely submission required under the Federal Funding Accountability and Transparency Act. In addition, we recommend that the County conduct formal training to ensure that management has sufficient knowledge of the applicable reporting requirements. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2021-001: Federal Funding Accountability and Transparency Act ? Significant Deficiency Program: Edward Byrne Memorial Justice Assistance Grant Program Direct award program Assistance Listing No.: 16.738 Federal Agency: Department of Justice Award No.: 2017-DJ-BX-0400, 2018-DJ-BX-0468, 2019-DJ-BX0831, 2018-DG-BX-k005, 19-JAG-15, 20-JAG-12 Award Year: Fiscal year 2020-2021 Category of Finding: Reporting Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). In addition, Title 2 CFR Appendix A to Part 170 a.2.ii. requires that for subaward information, [the County] needs to report no later than the end of the month following the month in which the obligation was made. (For example, if the obligation was made on November 7, 2010, the obligation must be reported by no later than December 31, 2010.) Condition: For the Edward Byrne Memorial Justice Assistance Grant Program (JAG), the County did not submit the required key data elements in FSRS in timely manner. The County did not comply with the requirement to report the information no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award modification was made. We selected seven of the thirty-six subawards for compliance testing and noted five subawards did not meet the reporting deadline by their required due dates resulting in late reporting ranging from a month to 25 months. The total amount of the five subawards not reported timely was $494,636. In addition, there was one subaward where the County reported the wrong obligation date in the FSRS. The date recorded in FSRS was March 19, 2019, while based on the source document, the date that was supposed to be recorded was September 1, 2019. Transactions Tested Subaward not reported Report not timely Subaward amounts incorrect Subaward missing key elements 7 0 5 0 0 Dollar Amount of Tested Transactions Subaward not reported Report not timely Subaward amounts incorrect Subaward missing key elements $581,769 0 $494,636 0 0 Cause: Controls over reporting of Federal Funding Accountability and Transparency Act were not designed and implemented to ensure timely submission of the report. In addition, there seemed to be a lack of knowledge of the compliance requirements regarding the reporting of the subawards. Effect: The County did not have effective controls in place to timely submit report information no later than the last day of the month following the month in which the subaward/subaward amendment obligation was made or the subcontract award/subcontract modification was made. Questioned Costs: None. Context: During our walkthrough of the internal control assessment of the Federal Funding Accountability and Transparency Act (FFATA) reporting for the grant, we had noted there were no evidence of internal control in place to ensure the FFATA reporting was reported timely in the FSRS portal. We selected a sample of four out of thirty-six subawards pertaining to the Edward Byrne Memorial Justice Assistance Grant Program (JAG). Out of the four subawards selected, three of them were not reported timely as required by the reporting requirement under the criteria. Based on this initial observation, Crowe selected three additional subawards and noted that two out of these additional three were also untimely. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that management establish and maintain effective internal control ensuring timely submission required under the Federal Funding Accountability and Transparency Act. In addition, we recommend that the County conduct formal training to ensure that management has sufficient knowledge of the applicable reporting requirements. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2021-001: Federal Funding Accountability and Transparency Act ? Significant Deficiency Program: Edward Byrne Memorial Justice Assistance Grant Program Direct program; Passed through Nevada Department of Public Safety AL No.: 16.738 Federal Agency: Department of Justice Award No.: 2017-DJ-BX-0400, 2018-DJ-BX-0468, 2019-DJ-BX0831, 19-JAG-15, 20-JAG-12 Award Year: Fiscal year 2020-2021 Finding 2021-001: Federal Funding Accountability and Transparency Act ? Significant Deficiency Program: Technology Innovation for Public Safety (TIPS) Addressing Precipitous Increases in Crime AL No.: 16.738 Federal Agency: Department of Justice Award No.: 2018-DG-BX-K005 Award Year: Fiscal year 2019-2020 To remedy the condition, cause, and effect resulting in the finding regarding timely FFATA (Federal Funding Accountability and Transparency Act) reporting into FSRS (FFATA Subaward Reporting System), see our team?s strategy to ensure that proper internal controls are in place moving forward: FFATA Timeliness Strategy A formal review process is being established over the FFATA reporting for all Social Service grants that includes the recurring task of reporting information monthly into FSRS no later than the last day of the month following the month in which any obligation or modification was made. This process is inclusive of all grants and projects with federal funding. ? Financial Office Specialist or Grants Coordinator completes the draft FFATA no later than the 15th of the month for the previous month for any contract execution or amendment and provides FFATA report, tracking sheet, checklist, and backup documentation to designated Senior Grants Coordinator. ? Senior Grants Coordinator reviews FFATA documentation, makes any required updates or edits, and approves FFATA for submission within 5 business days of receiving draft report. ? Financial Office Specialist or Grants Coordinator completes FFATA reporting into FSRS no later than the 25th of the month following the month in which an obligation or modification was made and ensures all files, reports, and back-up documentation are saved in the corresponding program file. ? Financial Office Specialist(s), Grants Coordinator(s) and Senior Grants Coordinator(s) will review FFATA reporting bi-monthly with management, and with other team members as needed. A routing log will be used to track the reviews and approvals of each step indicated above. Department of Social Service 1600 Pinto Lane ? Las Vegas NV 89106 (702) 455-4270 ? Fax (702) 455-5950 Timothy Burch, Administrator Kristin Cooper, Assistant Director ? Randy Reinoso, Assistant Director? Margaret LeBlanc, Assistant Director BOARD OF COUNTY COMMISSIONERS JAMES B. GIBSON Chair, JUSTIN JONES Vice Chair MARILYN KIRKPATRICK ? MICHAEL NAFT ? ROSS MILLER ? WILLIAM McCURDY II ? TICK SEGERBLOM YOLANDA KING, County Manager These steps will be formalized in CCSS Standard Operating Procedures (SOP) on or before April 28, 2022. At that time all personnel responsible for the FFATA Reporting will be trained on the SOP. Newly hired personnel responsible for FFATA reporting will be trained on the FFATA Reporting SOP within 30 days of hire. This will be formalized in their assigned training plan. The Senior Grants Coordinator will be responsible for ensuring that all assigned preparers and reviewers have completed this training within the established timeframes. Sincerely, Kristin Cooper, Assistant Director Clark County Social Service KRC@ClarkCountyNV.gov 702.455.5025 CC: Timothy Burch, Margaret LeBlanc, Anna Danchik, Colleen Boyle, Elizabeth Vorce, Michele Fuller-Hallauer, Emma Macayan-Hatley, Emma Garcia, Karen Schneider, Marylin Schoen, Claudia Young, Tara Ulmer, Brenda Herbstman, Mary Cannizzaro, Mary Duff
The County did not have an effective system of internal control in place to ensure segregation of duties for processing and review and to ensure the applications submitted were adequately documented for eligibility and calculation of benefit over a subset of disbursements in the CARES Housing Assistance Program (CHAP). During our internal control walkthrough, we identified that Clark County Social Services Department Employees would directly process applications related to CHAP applications which is separate from the process which utilized 3rd party contractors for preparation before review by Clark County. This process occurred when specific applications were identified as higher priority such as Court Cases involving evictions. Upon discussion with management, it was determined that the Social Services Department employee processed the application but there was not a subsequent independent review of applications for eligibility requirements and for allowability before disbursement for all applications subject to this process. In addition, of the 61 participant files selected for testing, we noted 4 cases where management did not have adequate documentation to support the allowable costs/activity and eligibility requirements. Cause: The Clark County Social Services Department was required to quickly develop a procedure to process applications for higher priority Cares Housing Assistance Program (CHAP) applications, such as those related to evictions moving through the Clark County Court system. As a result, the procedure was not properly designed to ensure adequate controls over the application review process. Effect: Transactions that follow a process without adequate segregation of duties may lead to noncompliant disbursements. Without strong internal controls over participant eligibility, ineligible participants may benefit from federally funded programs. Lack of a separate independent review over these transactions involving allowability and eligibility determinations could result in additional noncompliance with federal requirements. Questioned Costs: $28,205. Context: We obtained a listing of expenditures from the Emergency Rental Assistance related to CHAP that went through the Social Services Department process. Using a sampling approach, we selected 61 sample items from 1,074 participant files to verify eligibility and recalculate benefits in accordance with the policy. We found that 4 of the 61 cases selected did not have adequate supporting documentation such as income verification support for all household members and adequate support for benefit amounts, which resulted in $28,205 in known questioned costs of the $362,087 disbursements sampled. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that the County revise its procedure for reviewing Emergency Rental Assistance applications processed by the Social Services Department to include a separate independent review surrounding determinations of eligibility and allowability for disbursements to applicants prior to disbursement. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2021-002: Allowable Costs and Eligibility ? Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of the Treasury ? Direct Award Program Award No.: 1505-0266, 24599, USDT-ERAP2021, ERA0117, 2021 CAA CCSS Award Year: Fiscal year 2020-2021 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Allowable Costs - 2 CFR Part 200.403 Factors affecting allowability of costs except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items. (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity. (d) Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if any other cost incurred for the same purpose in like circumstances has been allocated to the Federal award as an indirect cost. (e) Be determined in accordance with generally accepted accounting principles (GAAP), except, for state and local governments and Indian tribes only, as otherwise provided for in this part. (f) Not be included as a cost or used to meet cost sharing or matching requirements of any other federally-financed program in either the current or a prior period. See also ? 200.306(b). (g) Be adequately documented. See also ?? 200.300 through 200.309 of this part. (h) Cost must be incurred during the approved budget period. The Federal awarding agency is authorized, at its discretion, to waive prior written approvals to carry forward unobligated balances to subsequent budget periods pursuant to ? 200.308(e)(3). 501(c)(2)(A) of the Consolidated Appropriations Act and section 3201(d)(1)(A) of ARPA Financial assistance to households includes payment of rent, rental arrears, utilities and home energy costs, utility and home energy costs arrears, and other expenses related to housing. Eligibility - Consolidated Appropriations Act, 2021, for ERA 1 in sections 501(c)(2)(C)(ii) of the Act concerning documentation of payments to households, sections 501(f)(2)(A) and (B) of the Act concerning signature requirements for applications and documentation required for tenants, section 501(k)(1) concerning area median income determinations, and sections 501(k)(3)(A)(I) and (II) concerning eligible household determinations and attestation requirements. Grantees must require all applications for assistance to include an attestation from the applicant household that all information included is correct and complete. In all cases, grantees must document their policies and procedures for determining household eligibility to include policies and procedures for determining the prioritization of households in compliance with the statute and maintain records of their determinations. In addition, 2 CFR 200.303 requires nonfederal entities to, among other things, establish and maintain effective internal control over the federal award that provides reasonable assurance that the nonfederal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition: The County did not have an effective system of internal control in place to ensure segregation of duties for processing and review and to ensure the applications submitted were adequately documented for eligibility and calculation of benefit over a subset of disbursements in the CARES Housing Assistance Program (CHAP). During our internal control walkthrough, we identified that Clark County Social Services Department Employees would directly process applications related to CHAP applications which is separate from the process which utilized 3rd party contractors for preparation before review by Clark County. This process occurred when specific applications were identified as higher priority such as Court Cases involving evictions. Upon discussion with management, it was determined that the Social Services Department employee processed the application but there was not a subsequent independent review of applications for eligibility requirements and for allowability before disbursement for all applications subject to this process. In addition, of the 61 participant files selected for testing, we noted 4 cases where management did not have adequate documentation to support the allowable costs/activity and eligibility requirements. Cause: The Clark County Social Services Department was required to quickly develop a procedure to process applications for higher priority Cares Housing Assistance Program (CHAP) applications, such as those related to evictions moving through the Clark County Court system. As a result, the procedure was not properly designed to ensure adequate controls over the application review process. Effect: Transactions that follow a process without adequate segregation of duties may lead to noncompliant disbursements. Without strong internal controls over participant eligibility, ineligible participants may benefit from federally funded programs. Lack of a separate independent review over these transactions involving allowability and eligibility determinations could result in additional noncompliance with federal requirements. Questioned Costs: $28,205. Context: We obtained a listing of expenditures from the Emergency Rental Assistance related to CHAP that went through the Social Services Department process. Using a sampling approach, we selected 61 sample items from 1,074 participant files to verify eligibility and recalculate benefits in accordance with the policy. We found that 4 of the 61 cases selected did not have adequate supporting documentation such as income verification support for all household members and adequate support for benefit amounts, which resulted in $28,205 in known questioned costs of the $362,087 disbursements sampled. Identification of a repeat finding: Not a repeat finding. Recommendation: We recommend that the County revise its procedure for reviewing Emergency Rental Assistance applications processed by the Social Services Department to include a separate independent review surrounding determinations of eligibility and allowability for disbursements to applicants prior to disbursement. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2021-002: Allowable Costs and Eligibility - Material Weakness Program: Emergency Rental Assistance Assistance Listing No.: 21.023 Federal Agency: Department of the Treasury Award No.: 1505-0266, 24599, USDT-ERAP2021 Award Year: Fiscal year 2020-2021 Category of Finding: Activities Allowed or Unallowed, Allowable Costs, and Eligibility The County acknowledges and agrees with the finding. To ensure proper internal controls are in place for cases processed directly by Clark County Department of Social Service employees, the Department is implementing an independent review of allowability and eligibility determinations prior to the disbursement of funds. Evidence of secondary review will be suficiently documented in each case. A review checklist, standard operating procedures, and staf training has been developed and is scheduled for implementation. Sincerely, Timothy Burch Administrator
FAC accepted this audit on March 29, 2021 — management decision was due September 29, 2021.
Time certifications verifying time and effort performance on the grant for one employee, consisting of seven payroll transactions, did not have the immediate supervisor?s signatures that would indicate that an independent review and approval had taken place. It is worth noting that the employee time was accurate and the activity was deemed allowable. In addition to the review and approval of the time certification, management had not designed an internal control to reconcile the personnel included in the time certifications to the accounting system. It should be noted that while the evidence of this reconciliation was not present, the same personnel noted within the time certifications were the same personnel ultimately charged to the program. Cause: Controls over time certification of activity charged to the Federal Programs were not operating effectively to ensure timely and appropriate completion of the report. In addition, the grant administrator did not have access to the accounting system to be able to ensure that the grant was only charged for the employee performing the work as noted in the time certifications. Effect: The Federal program could be charged for service time and employee effort which was not performed on the grant. Questioned Costs: None Context: During our walkthrough of the internal controls assessments of the payroll transactions for JAG, we had noted that there was no evidence of internal control in place to ensure that time certifications for personnel who were charged to the JAG program were being reconciled to the general ledger system. Additionally, we had selected a small population of 21 payroll transactions, from a complete population of 106 transactions to ensure that the compliance requirements were being met. We had noted that seven out of 21 payroll transactions did not have the immediate supervisor?s signatures in the time certifications as indication of review and approval. Identification of a repeat finding: Yes, repeated from fiscal year ended June 30, 2019. Refer to Finding 2019-001. Recommendation: Time certifications of employees working on grant funded programs should be reviewed timely and regularly. The independent reviewer should provide sign off as reviewer as evidence of review. In addition, management should establish an internal control to reconcile the salaries and wages amounts charged to the federal program in the accounting system for the Justice Assistance Grants departments to the time and effort certifications. Management should also verify that the charges and the time certifications are for the exact employees who worked on the program. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2020-001: Allowable Costs ? Material Weakness Program: Edward Byrne Memorial Justice Assistance Grant Program Direct program Passed through Nevada Department of Public Safety CFDA No.: 16.738 Federal Agency: Department of Justice Award No.: 2016-DJ-BX-0412, 2017-DJ-BX-0400, 2018-DG-BX-K005, 17-JAG-14, 19-JAG-15, 19-JAG-17, 17-JAG-58 Award Year: Fiscal year 2019-2020 Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Title 2, Subtitle A, Chapter II, Part 200 Subpart E, paragraph 430 of the Code of Federal Regulations stipulates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both Federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non- Federal entity's written policy; ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity ? Comply with the established accounting policies and practices of the non-Federal entity. Condition: Time certifications verifying time and effort performance on the grant for one employee, consisting of seven payroll transactions, did not have the immediate supervisor?s signatures that would indicate that an independent review and approval had taken place. It is worth noting that the employee time was accurate and the activity was deemed allowable. In addition to the review and approval of the time certification, management had not designed an internal control to reconcile the personnel included in the time certifications to the accounting system. It should be noted that while the evidence of this reconciliation was not present, the same personnel noted within the time certifications were the same personnel ultimately charged to the program. Cause: Controls over time certification of activity charged to the Federal Programs were not operating effectively to ensure timely and appropriate completion of the report. In addition, the grant administrator did not have access to the accounting system to be able to ensure that the grant was only charged for the employee performing the work as noted in the time certifications. Effect: The Federal program could be charged for service time and employee effort which was not performed on the grant. Questioned Costs: None Context: During our walkthrough of the internal controls assessments of the payroll transactions for JAG, we had noted that there was no evidence of internal control in place to ensure that time certifications for personnel who were charged to the JAG program were being reconciled to the general ledger system. Additionally, we had selected a small population of 21 payroll transactions, from a complete population of 106 transactions to ensure that the compliance requirements were being met. We had noted that seven out of 21 payroll transactions did not have the immediate supervisor?s signatures in the time certifications as indication of review and approval. Identification of a repeat finding: Yes, repeated from fiscal year ended June 30, 2019. Refer to Finding 2019-001. Recommendation: Time certifications of employees working on grant funded programs should be reviewed timely and regularly. The independent reviewer should provide sign off as reviewer as evidence of review. In addition, management should establish an internal control to reconcile the salaries and wages amounts charged to the federal program in the accounting system for the Justice Assistance Grants departments to the time and effort certifications. Management should also verify that the charges and the time certifications are for the exact employees who worked on the program. Management Response: See Corrective Action Plan.
CORRECTIVE ACTION PLAN Finding 2020-001: Allowable Costs ? Material Weakness Program: Edward Byrne Memorial Justice Assistance Grant Program Direct program Passed through Nevada Department of Public Safety CFDA No.: 16.738 Federal Agency: Department of Justice Award No.: 2016-DJ-BX-0412, 2017-DJ-BX-0400, 2018-DG-BX-K005, 17-JAG-14, 19-JAG-15, 19-JAG-17, 17-JAG-58 Award Year: Fiscal year 2019-2020 To remedy the condition, cause, and effect resulting in the repeated finding regarding timesheet certifications and reconciliations, see our team?s strategy to ensure that proper internal controls are in place moving forward: JAG ? Time Certification and Reconciliation Strategy ? Administrative Specialist reviews journal entries pertaining to departmental salaries applied to the JAG grant (District Attorney?s office, Juvenile Justice Services, Department of Family Services). ? Grants Coordinator collects from impacted Departments their employee time/activity documentation that they use to enter salaries charged against the JAG grant, required by the 20th of each month for the immediate previous month. ? Grants Coordinator signs off on certifications upon review of each and forwards these to Administrative Specialist. ? Administrative Specialist reconciles timesheet certifications against County accounting report totals and signs off that they have been reviewed/reconciled. o Administrative Specialist reconciles employee names on the timesheets with employee names on County account reports; includes total salaries charged. o Administrative Specialist also reviews applicable additional entries immediately prior to closeout ? General Ledger o Sr. Financial Office Specialist independently reviews Administrative Specialist?s reconciliations and signs off on each after the reviews. Reviews are shared with Manager (Karen Schneider) upon completion. We hope to have the matter resolved by no later than April 30, 2021.
2019-001
FAC accepted this audit on November 19, 2019 — management decision was due May 19, 2020.
1. Payroll transactions for three employees during three payroll periods were not supported by appropriate documentation. We identified that the employee charged to the grant was different than the employees who signed Activity Reports verifying time and effort performance on the grant. The District Attorney?s office (DA) received authorization to swap senior personnel into the program in place of the less senior employees originally budgeted to the program per the grant agreements. The senior personnel then performed on the grant per the agreed upon terms of the grant. However, the DA?s office then charged the grant in the accounting system for the salary of the junior personnel rather than for the salaries of the senior personnel performing on the program. All time and effort requirements of the grant budget were satisfied by the work of the senior personnel, and the compensation for the employees performing the activities was in excess of the amount charged to the program, so we did not observe any questioned costs related to this finding. 2. Time certifications verifying time and effort performance on the grant for six employees during three payroll periods were not completed in a timely manner. Time certifications for six employees were completed in October 2019 and February 2020 for activity performed during fiscal year ended June 30, 2019. Supervisors for the respective six employees confirmed that all time and effort requirements of the grant were met. Cause: 1. Controls over employee compensation charged to the Federal programs were not properly designed to ensure that the grant was only charged for the employee performing the work. 2. Controls over time certifications of activity charged to the Federal programs were not operating effectively to ensure the timely completion of the report. Effect: The Federal program could be charged for service time and employee effort which was not performed on the grant. Questioned Costs: None Context: 1. For the three employees who were charged to the grant but did not perform activities for the grant, a nonstatistical sample of 3 payroll periods from a complete population of 26 payroll periods charged to the Justice Assistance Grant program was tested for compliance and control functionality. 2. For the six employee time certifications that were not performed or not performed in a timely manner, a nonstatistical sample of 3 payroll periods from a complete population of 26 payroll periods charged to the Justice Assistance Grant program was tested for compliance and control functionality. Identification of a repeat finding: 1. Yes, repeated from fiscal year ended June 30, 2018. 2. No. Recommendation: 1. We recommend management revise their process for charging salaries and wages to Federal programs so that such charges are for the exact employees who worked on the program. 2. Time certifications of employees working on grant funded programs should be prepared timely and regularly and submitted to the grant coordinator. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2019-001: Allowable Costs ? Material Weakness Program: Edward Byrne Memorial Justice Assistance Grant Program Direct program Passed through Nevada Department of Public Safety CFDA No.: 16.738 Federal Agency: Department of Justice Award No.: 2015-DJ-0997, 2016-DJ-BX-0412, 2017-DJ-BX-0400, 2018-DG-BX-K005, 17-JAG-13, 17-JAG-14, 18-JAG-09 Award Year: Fiscal year 2018-2019 Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Title 2, Subtitle A, Chapter II, Part 200 Subpart E, paragraph 430 of the Code of Federal Regulations stipulates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both Federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non- Federal entity's written policy; ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity ? Comply with the established accounting policies and practices of the non-Federal entity. Condition: 1. Payroll transactions for three employees during three payroll periods were not supported by appropriate documentation. We identified that the employee charged to the grant was different than the employees who signed Activity Reports verifying time and effort performance on the grant. The District Attorney?s office (DA) received authorization to swap senior personnel into the program in place of the less senior employees originally budgeted to the program per the grant agreements. The senior personnel then performed on the grant per the agreed upon terms of the grant. However, the DA?s office then charged the grant in the accounting system for the salary of the junior personnel rather than for the salaries of the senior personnel performing on the program. All time and effort requirements of the grant budget were satisfied by the work of the senior personnel, and the compensation for the employees performing the activities was in excess of the amount charged to the program, so we did not observe any questioned costs related to this finding. 2. Time certifications verifying time and effort performance on the grant for six employees during three payroll periods were not completed in a timely manner. Time certifications for six employees were completed in October 2019 and February 2020 for activity performed during fiscal year ended June 30, 2019. Supervisors for the respective six employees confirmed that all time and effort requirements of the grant were met. Cause: 1. Controls over employee compensation charged to the Federal programs were not properly designed to ensure that the grant was only charged for the employee performing the work. 2. Controls over time certifications of activity charged to the Federal programs were not operating effectively to ensure the timely completion of the report. Effect: The Federal program could be charged for service time and employee effort which was not performed on the grant. Questioned Costs: None Context: 1. For the three employees who were charged to the grant but did not perform activities for the grant, a nonstatistical sample of 3 payroll periods from a complete population of 26 payroll periods charged to the Justice Assistance Grant program was tested for compliance and control functionality. 2. For the six employee time certifications that were not performed or not performed in a timely manner, a nonstatistical sample of 3 payroll periods from a complete population of 26 payroll periods charged to the Justice Assistance Grant program was tested for compliance and control functionality. Identification of a repeat finding: 1. Yes, repeated from fiscal year ended June 30, 2018. 2. No. Recommendation: 1. We recommend management revise their process for charging salaries and wages to Federal programs so that such charges are for the exact employees who worked on the program. 2. Time certifications of employees working on grant funded programs should be prepared timely and regularly and submitted to the grant coordinator. Management Response: See Corrective Action Plan.
This finding has been remedied. Currently, the County charges the JAG grant for the salary and benefits of the employees who are working on this program.
2018-001
Four payroll periods tested with a total of two program related employees in each period, were not supported by appropriate documentation for the two employees. In each instance, the employee whose name was charged to the grant was different than the employee who signed Certification Letters verifying time and effort performance on the Program. The District Attorney?s office (DA) received authorization to swap senior personnel into the program in place of the employees originally budgeted to the program per the grant agreements. The senior personnel then performed on the grant per the agreed upon terms of the grant. However, the DA?s office charged the grant in the accounting system for the salary of the originally budgeted employee rather than for the salaries of the senior personnel performing on the program. Cause: Controls over employee compensation charged to the Federal programs were not properly designed to ensure that the grant was only charged for the employee performing the work. Effect: The Federal program could be charged for service time and employee effort which was not performed on the grant. Questioned Costs: None Context: Nonstatistical sample of 8 payroll periods with the same four employees from a complete population of 26 payroll periods charged to the High Intensity Drug Trafficking Areas Program was tested for compliance and control functionality. Identification of a repeat finding: Yes, repeated from fiscal year ended June 30, 2018. Recommendation: We recommend management revise the process for charging salaries and wages to Federal programs so that such charges are for the exact employees who worked on the program. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2019-002: Allowable Costs ? Material Weakness Program: High Intensity Drug Trafficking Areas Program Direct Program CFDA No.: 95.001 Federal Agency: Executive office of the President Award No.: G16NV0001A, G17NV0001A, G18NV0001A, G19NV0001A, Award Year: Fiscal year 2018-2019 Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Title 2, Subtitle A, Chapter II, Part 200 Subpart E, paragraph 430 of the Code of Federal Regulations stipulates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both Federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non- Federal entity's written policy; ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity ? Comply with the established accounting policies and practices of the non-Federal entity. Condition: Four payroll periods tested with a total of two program related employees in each period, were not supported by appropriate documentation for the two employees. In each instance, the employee whose name was charged to the grant was different than the employee who signed Certification Letters verifying time and effort performance on the Program. The District Attorney?s office (DA) received authorization to swap senior personnel into the program in place of the employees originally budgeted to the program per the grant agreements. The senior personnel then performed on the grant per the agreed upon terms of the grant. However, the DA?s office charged the grant in the accounting system for the salary of the originally budgeted employee rather than for the salaries of the senior personnel performing on the program. Cause: Controls over employee compensation charged to the Federal programs were not properly designed to ensure that the grant was only charged for the employee performing the work. Effect: The Federal program could be charged for service time and employee effort which was not performed on the grant. Questioned Costs: None Context: Nonstatistical sample of 8 payroll periods with the same four employees from a complete population of 26 payroll periods charged to the High Intensity Drug Trafficking Areas Program was tested for compliance and control functionality. Identification of a repeat finding: Yes, repeated from fiscal year ended June 30, 2018. Recommendation: We recommend management revise the process for charging salaries and wages to Federal programs so that such charges are for the exact employees who worked on the program. Management Response: See Corrective Action Plan.
We continue our efforts to remedy this finding. As recently as February 2020, we continued to work with Crowe and our HIDTA partners to find alternative corrective measure to address the finding. Unfortunately, that effort has proven unsuccessful. Therefore, the Court will charge the HIDTA grant for the salary and benefits of the employees who are working on that program. In addition, the County will augment the salary and benefits for each position by the amount available HIDTA funds are exceeded. Finally, there will be a ?Limited Permanent? position associated with each of the grant-funded positions to comply with the terms of the Agreement Between the County of Clark and the Clark County Prosecutors Association July 1, 2017, to June 30, 2020. I met with County Comptroller Anna Danchik on March 9, 2020, to effectuate this process and we continue to work together to correct the finding. We hope to have the matter resolved by June 2020
2018-001
FAC accepted this audit on March 26, 2020 — management decision was due September 26, 2020.
1. Payroll transactions for three employees during three payroll periods were not supported by appropriate documentation. We identified that the employee charged to the grant was different than the employees who signed Activity Reports verifying time and effort performance on the grant. The District Attorney?s office (DA) received authorization to swap senior personnel into the program in place of the less senior employees originally budgeted to the program per the grant agreements. The senior personnel then performed on the grant per the agreed upon terms of the grant. However, the DA?s office then charged the grant in the accounting system for the salary of the junior personnel rather than for the salaries of the senior personnel performing on the program. All time and effort requirements of the grant budget were satisfied by the work of the senior personnel, and the compensation for the employees performing the activities was in excess of the amount charged to the program, so we did not observe any questioned costs related to this finding. 2. Time certifications verifying time and effort performance on the grant for six employees during three payroll periods were not completed in a timely manner. Time certifications for six employees were completed in October 2019 and February 2020 for activity performed during fiscal year ended June 30, 2019. Supervisors for the respective six employees confirmed that all time and effort requirements of the grant were met. Cause: 1. Controls over employee compensation charged to the Federal programs were not properly designed to ensure that the grant was only charged for the employee performing the work. 2. Controls over time certifications of activity charged to the Federal programs were not operating effectively to ensure the timely completion of the report. Effect: The Federal program could be charged for service time and employee effort which was not performed on the grant. Questioned Costs: None Context: 1. For the three employees who were charged to the grant but did not perform activities for the grant, a nonstatistical sample of 3 payroll periods from a complete population of 26 payroll periods charged to the Justice Assistance Grant program was tested for compliance and control functionality. 2. For the six employee time certifications that were not performed or not performed in a timely manner, a nonstatistical sample of 3 payroll periods from a complete population of 26 payroll periods charged to the Justice Assistance Grant program was tested for compliance and control functionality. Identification of a repeat finding: 1. Yes, repeated from fiscal year ended June 30, 2018. 2. No. Recommendation: 1. We recommend management revise their process for charging salaries and wages to Federal programs so that such charges are for the exact employees who worked on the program. 2. Time certifications of employees working on grant funded programs should be prepared timely and regularly and submitted to the grant coordinator. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2019-001: Allowable Costs ? Material Weakness Program: Edward Byrne Memorial Justice Assistance Grant Program Direct program Passed through Nevada Department of Public Safety CFDA No.: 16.738 Federal Agency: Department of Justice Award No.: 2015-DJ-0997, 2016-DJ-BX-0412, 2017-DJ-BX-0400, 2018-DG-BX-K005, 17-JAG-13, 17-JAG-14, 18-JAG-09 Award Year: Fiscal year 2018-2019 Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Title 2, Subtitle A, Chapter II, Part 200 Subpart E, paragraph 430 of the Code of Federal Regulations stipulates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both Federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non- Federal entity's written policy; ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity ? Comply with the established accounting policies and practices of the non-Federal entity. Condition: 1. Payroll transactions for three employees during three payroll periods were not supported by appropriate documentation. We identified that the employee charged to the grant was different than the employees who signed Activity Reports verifying time and effort performance on the grant. The District Attorney?s office (DA) received authorization to swap senior personnel into the program in place of the less senior employees originally budgeted to the program per the grant agreements. The senior personnel then performed on the grant per the agreed upon terms of the grant. However, the DA?s office then charged the grant in the accounting system for the salary of the junior personnel rather than for the salaries of the senior personnel performing on the program. All time and effort requirements of the grant budget were satisfied by the work of the senior personnel, and the compensation for the employees performing the activities was in excess of the amount charged to the program, so we did not observe any questioned costs related to this finding. 2. Time certifications verifying time and effort performance on the grant for six employees during three payroll periods were not completed in a timely manner. Time certifications for six employees were completed in October 2019 and February 2020 for activity performed during fiscal year ended June 30, 2019. Supervisors for the respective six employees confirmed that all time and effort requirements of the grant were met. Cause: 1. Controls over employee compensation charged to the Federal programs were not properly designed to ensure that the grant was only charged for the employee performing the work. 2. Controls over time certifications of activity charged to the Federal programs were not operating effectively to ensure the timely completion of the report. Effect: The Federal program could be charged for service time and employee effort which was not performed on the grant. Questioned Costs: None Context: 1. For the three employees who were charged to the grant but did not perform activities for the grant, a nonstatistical sample of 3 payroll periods from a complete population of 26 payroll periods charged to the Justice Assistance Grant program was tested for compliance and control functionality. 2. For the six employee time certifications that were not performed or not performed in a timely manner, a nonstatistical sample of 3 payroll periods from a complete population of 26 payroll periods charged to the Justice Assistance Grant program was tested for compliance and control functionality. Identification of a repeat finding: 1. Yes, repeated from fiscal year ended June 30, 2018. 2. No. Recommendation: 1. We recommend management revise their process for charging salaries and wages to Federal programs so that such charges are for the exact employees who worked on the program. 2. Time certifications of employees working on grant funded programs should be prepared timely and regularly and submitted to the grant coordinator. Management Response: See Corrective Action Plan.
This finding has been remedied. Currently, the County charges the JAG grant for the salary and benefits of the employees who are working on this program.
2018-001
Four payroll periods tested with a total of two program related employees in each period, were not supported by appropriate documentation for the two employees. In each instance, the employee whose name was charged to the grant was different than the employee who signed Certification Letters verifying time and effort performance on the Program. The District Attorney?s office (DA) received authorization to swap senior personnel into the program in place of the employees originally budgeted to the program per the grant agreements. The senior personnel then performed on the grant per the agreed upon terms of the grant. However, the DA?s office charged the grant in the accounting system for the salary of the originally budgeted employee rather than for the salaries of the senior personnel performing on the program. Cause: Controls over employee compensation charged to the Federal programs were not properly designed to ensure that the grant was only charged for the employee performing the work. Effect: The Federal program could be charged for service time and employee effort which was not performed on the grant. Questioned Costs: None Context: Nonstatistical sample of 8 payroll periods with the same four employees from a complete population of 26 payroll periods charged to the High Intensity Drug Trafficking Areas Program was tested for compliance and control functionality. Identification of a repeat finding: Yes, repeated from fiscal year ended June 30, 2018. Recommendation: We recommend management revise the process for charging salaries and wages to Federal programs so that such charges are for the exact employees who worked on the program. Management Response: See Corrective Action Plan.
Show full finding ▾Hide full finding ▴Finding 2019-002: Allowable Costs ? Material Weakness Program: High Intensity Drug Trafficking Areas Program Direct Program CFDA No.: 95.001 Federal Agency: Executive office of the President Award No.: G16NV0001A, G17NV0001A, G18NV0001A, G19NV0001A, Award Year: Fiscal year 2018-2019 Criteria or Specific Requirement: As a condition of receiving Federal awards, non-Federal entities agree to comply with laws, regulations, and the provisions of grant agreements and contracts, and to maintain internal control to provide reasonable assurance of compliance with these requirements. Title 2, Subtitle A, Chapter II, Part 200 Subpart E, paragraph 430 of the Code of Federal Regulations stipulates that charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: ? Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated; ? Be incorporated into the official records of the non-Federal entity; ? Reasonably reflect the total activity for which the employee is compensated by the non-Federal entity, not exceeding 100% of compensated activities; ? Encompass both Federally assisted, and all other activities compensated by the non-Federal entity on an integrated basis, but may include the use of subsidiary records as defined in the non- Federal entity's written policy; ? Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity ? Comply with the established accounting policies and practices of the non-Federal entity. Condition: Four payroll periods tested with a total of two program related employees in each period, were not supported by appropriate documentation for the two employees. In each instance, the employee whose name was charged to the grant was different than the employee who signed Certification Letters verifying time and effort performance on the Program. The District Attorney?s office (DA) received authorization to swap senior personnel into the program in place of the employees originally budgeted to the program per the grant agreements. The senior personnel then performed on the grant per the agreed upon terms of the grant. However, the DA?s office charged the grant in the accounting system for the salary of the originally budgeted employee rather than for the salaries of the senior personnel performing on the program. Cause: Controls over employee compensation charged to the Federal programs were not properly designed to ensure that the grant was only charged for the employee performing the work. Effect: The Federal program could be charged for service time and employee effort which was not performed on the grant. Questioned Costs: None Context: Nonstatistical sample of 8 payroll periods with the same four employees from a complete population of 26 payroll periods charged to the High Intensity Drug Trafficking Areas Program was tested for compliance and control functionality. Identification of a repeat finding: Yes, repeated from fiscal year ended June 30, 2018. Recommendation: We recommend management revise the process for charging salaries and wages to Federal programs so that such charges are for the exact employees who worked on the program. Management Response: See Corrective Action Plan.
We continue our efforts to remedy this finding. As recently as February 2020, we continued to work with Crowe and our HIDTA partners to find alternative corrective measure to address the finding. Unfortunately, that effort has proven unsuccessful. Therefore, the Court will charge the HIDTA grant for the salary and benefits of the employees who are working on that program. In addition, the County will augment the salary and benefits for each position by the amount available HIDTA funds are exceeded. Finally, there will be a ?Limited Permanent? position associated with each of the grant-funded positions to comply with the terms of the Agreement Between the County of Clark and the Clark County Prosecutors Association July 1, 2017, to June 30, 2020. I met with County Comptroller Anna Danchik on March 9, 2020, to effectuate this process and we continue to work together to correct the finding. We hope to have the matter resolved by June 2020
2018-001
FAC accepted this audit on March 28, 2019 — management decision was due September 28, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on February 5, 2019 — management decision was due August 5, 2019.
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on February 27, 2018 — management decision was due August 27, 2018.
FAC accepted this audit on March 28, 2018 — management decision was due September 28, 2018.
FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.
FAC accepted this audit on December 14, 2016 — management decision was due June 14, 2017.
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