Audit 26976

Condition/Context UCUT applied an outdated Indirect cost rate agreement (ICRA) to its reimbursement requests. The updated indirect cost rate was effective as of June 10, 2022 which reduced the ICRA by 12.51%. Criteria 2 CFR Part 200, Appendix VII, section D1 states that All departments or agencies of the governmental unit desiring to claim indirect costs under Federal awards must prepare an indirect cost rate proposal and related documentation to support those costs. The approved indirect costs rate agreement received by UCUT indicated a indirect cost rate that should be applied to a base that included total direct costs, less capital expenditures and passthrough funds. Per 2 CFR 200.303 a 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 statutes, 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). Cause UCUT received an updated ICRA and did not update the amounts utilized in the reimbursement requests. Questioned Costs None. $22,070 Effect UCUT requested an additional $22,070 of indirect costs from the grantor. Recommendation We recommend that the Tribe review its policies and procedures to ensure that it reports expenditures on the SEFA when (1) FEMA has approved the nonfederal entity?s PW, and (2) it has incurred the eligible expenditures. Federal awards expended in years subsequent to the fiscal year in which the PW is approved are to be recorded on the nonfederal entity?s SEFA in those subsequent years.

Condition/Context UCUT submitted one of the four Pisces Status Reports was submitted 18 days after the due date. Criteria Per 2 CFR 200 Section 329(c1), states that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. Section E:185 of the subrecipient grant agreement states that the Produce Pieces Status Report is due 15 days after the reporting quarter ends. 2 CFR Section 200.303, Internal controls, states: The non-Federal entity must: (a) 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 statutes, 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 the Sponsoring Organizations of the Treadway Commission (COSO). Cause Proper internal control processes and procedures were not in place to provide timely submission of the Pisces Status Report. Questioned Costs None. None Effect The grantor did not receive performance information in a timely manner. Recommendation We recommend that UCUT strengthen its internal control procedures to ensure timely report submission.

Condition/Context UCUT applied an outdated Indirect cost rate agreement (ICRA) to its reimbursement requests. The updated indirect cost rate was effective as of June 10, 2022 which reduced the ICRA by 12.51%. Criteria 2 CFR Part 200, Appendix VII, section D1 states that All departments or agencies of the governmental unit desiring to claim indirect costs under Federal awards must prepare an indirect cost rate proposal and related documentation to support those costs. The approved indirect costs rate agreement received by UCUT indicated a indirect cost rate that should be applied to a base that included total direct costs, less capital expenditures and passthrough funds. Per 2 CFR 200.303 a 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 statutes, 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). Cause UCUT received an updated ICRA and did not update the amounts utilized in the reimbursement requests. Questioned Costs None. $22,070 Effect UCUT requested an additional $22,070 of indirect costs from the grantor. Recommendation We recommend that the Tribe review its policies and procedures to ensure that it reports expenditures on the SEFA when (1) FEMA has approved the nonfederal entity?s PW, and (2) it has incurred the eligible expenditures. Federal awards expended in years subsequent to the fiscal year in which the PW is approved are to be recorded on the nonfederal entity?s SEFA in those subsequent years.

Condition/Context UCUT submitted one of the four Pisces Status Reports was submitted 18 days after the due date. Criteria Per 2 CFR 200 Section 329(c1), states that the non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. Section E:185 of the subrecipient grant agreement states that the Produce Pieces Status Report is due 15 days after the reporting quarter ends. 2 CFR Section 200.303, Internal controls, states: The non-Federal entity must: (a) 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 statutes, 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 the Sponsoring Organizations of the Treadway Commission (COSO). Cause Proper internal control processes and procedures were not in place to provide timely submission of the Pisces Status Report. Questioned Costs None. None Effect The grantor did not receive performance information in a timely manner. Recommendation We recommend that UCUT strengthen its internal control procedures to ensure timely report submission.