HUMBOLDT COUNTY SCHOOL DISTRICTLocal Government

2022-001: U.S. Department of EducationSpecial Education Cluster (IDEA):Special Education - Grants to States, CFDA 84.027Special Education - Preschool Grants, CFDA 84.173Allowable Costs/Cost PrinciplesSignificant Deficiency in Internal Control Over ComplianceGrant AwardNumber:Affects all grant awards included in the Special Education Cluster (IDEA)under CFDA 84.027 and 84.173 on the Schedule of Expenditure of FederalAwards passed through the State of Nevada Department of Education.Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, UniformAdministrative Requirements, Cost Principles, and Audit Requirements forFederal Awards (Uniform guidance) requires that charges to federal awardsfor salaries and wages be based on records that accurately reflect the workperformed and that the system of internal controls include processes toensure that time was spent consistent with the planned allocation.Condition, Cause,and Effect/ PotentialEffect:The District did not maintain evidence of internal control procedures relatedto ensuring that time actually spent on Local Plan, grant award 22-639-07000, was consistent with the planned activities for those individuals whostarted work on the project during the school year, which could result inunallowable costs being charged to the grant.Questioned Costs: None noted.Context: Based on a nonstatistical sample of all 24 employees whose salary and wagecosts were charge to the Local Plan, we found that the District did notmaintain documentation to support their review of actual time spent on theprogram for four of the employees. In all such cases, the employee beganwork on the program at some point after the first payroll of the year.Repeat Finding fromPrior Year: NoRecommendation: We recommend the District enhance control procedures to ensure that allpayroll charges to federal grants are reviewed and documented to ensure thattime charged to grants was consistent with the planned allocation.Views of ResponsibleOfficials:Management agrees with this finding and will review the internal controlsover payroll charge documentation.

2022-002: U.S. Department of the TreasuryCoronavirus Relief Fund (CRF)COVID-19 ? Supplemental Coronavirus Relief Funding for School Districts,CFDA 21.019Period of Performance - NoncomplianceGrant AwardNumber:21-340-07000 passed through the State of Nevada Department of Education.Criteria: The OMB Compliance Supplement requires that charges to federal awardsconsist of only allowable costs incurred during the approved budget period of afederal award?s period of performance and any costs incurred before the federalawarding agency or pass-through entity made the federal award that wereauthorized by the federal awarding agency or pass-through entity (2 CFRsections 200.308 and 200.309.Condition, Cause,and Effect/Potential Effect:While the District?s expenditures for the program are consistent with the March1, 2020 through December 31, 2021 Period of Performance for this federalprogram, the expenditures charged occurred prior to the date of sub-grant awardprovided by the State of Nevada Department of Education. The subgrant awardstates that the Period of Performance for the Sub-grant award would beDecember 10, 2021 ? December 31, 2021, and was signed by the pass-throughentity on December 21, 2021. Prior to acceptance, the District informed thepass-through entity that they intended to use the funds as reimbursement forcosts incurred during July through October of 2021, and pass-through entitypersonnel verbally assured District management that this would be acceptable.However, the pass-through entity did not amend the sub-grant period ofperformance, resulting in non-compliance with the sub-grant award.Questioned Costs: None noted.Context: Based on a nonstatistical sample of all costs charged to the program, it wasfound that all costs were incurred prior to the sub-grant award period. This wasan isolated instance resulting from a unique situation that arose and was out ofthe District?s control, and is not the result of a systematic problem.Repeat Findingfrom Prior Year: NoRecommendation: We recommend that the District obtain written documentation of any promisedrevisions to sub-grant awards prior to expending funds from the pass-throughentity in the future.Views ofResponsibleOfficials:Management agrees with this finding, however, since this was an un-correctedadministrative error on the part of the pass-through entity, and not due to actionsof District management, we were not able to avoid spending outside the narrowsub-grant?s period of performance.

2019-001: U.S. Department of Education Special Education Cluster (IDEA): Special Education - Grants to States, CFDA 84.027 Special Education - Preschool Grants, CFDA 84.173 Procurement, Suspension, and Debarment Significant Deficiency in Internal Control Over Compliance Grant Award Numbers and Project Titles, all passed through the Nevada Department of Education: Special Education - Grants to States, Local Plan 19-639-07000 Special Education DIG 19-641-07000 Special Education Teacher Transition Specialist 19-667-07000 Physical and Occupational Therapy 19-667-07001 IDEA Implementation 19-667-07005 Special Education - Preschool Grants, Early Childhood Aide Time 19-675-07003 Early Childhood Speech Therapy 19-675-07002 Early Childhood Program 19-665-07000 Criteria: Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform guidance) requires non-federal entities other than States to follow their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR sections 200.318 through 200.326. This includes using the small purchase methods only for procurements that meet the applicable criteria under 2 CFR sections 200.320(b). Condition, Cause, and Effect/ Potential Effect: The District did not maintain evidence of internal control procedures over procurement with respect to the costs paid through the IDEA Implementation Special Project. The District?s controls over compliance with procurement standards related to small purchases were not evident during the fiscal year ended June 30, 2019. While the support for compliance with procurement procedures was obtained from the State, therefore resulting in no reportable non-compliance, the current system of internal control with respect to these costs may allow non-compliance with procurement procedures in this program. Questioned Costs: None noted. Context: A nonstatistical sample of the procurement transactions funded through the IDEA Implementation Special Project revealed that the District was relying on the State for procurement controls and not utilizing their own internal control procedures. Recommendation: We recommend the District review internal controls to ensure all procurement transactions are executed under the policy adopted and that documentation of such is maintained in the District files. Views of Responsible Officials and Planned Corrective Actions: Management agrees with this finding and will review the internal controls over procurement related to federal disbursements, and will maintain evidence of control processes utilized.