Audit 292271

Program Information: See the audit finding for chart/table Criteria or specific requirement: AL # 15.021 Investment and Deposit of Advance Funds - A tribe, tribal organization, or consortia receiving advance payments under the ISDEAA or the Tribally Controlled Schools Act may invest advance payments (some recipients refer to these advance payments as “deferred revenue”) before such funds are expended for the purposes of the grant, contract, or funding agreement, so long as such funds are (1) invested only in obligations of the United States or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed or insured by the United States; or (2) deposited only in accounts that are insured by an agency or instrumentality of the United States, or are fully collateralized to ensure protection of the advance funds, even in the event of a bank failure (25 USC 450e-3). AL # 93.600 Head Start uses specific terms related to real property and facilities, which are defined at 45 CFR section 1305.2, including construction, facility, Federal interest, major renovation, and modular unit. Facilities activities (purchase, construction, major renovation, subordination of a Federal interest, refinancing, and disposition) are initiated through the submission of Form SF-429 (cover sheet) and applicable Attachments B (Request to Acquire, Improve or Furnish) or C (Disposition or Encumbrance Request). Condition/Context: AL # 15.021 During testing of Investment and Deposit of Advance funds, it was noted that advanced funds are not fully collateralized or insured. AL # 93.600 The Department was unable to provide documentation of SF-429 reporting to verify it was completed and submitted on time. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: AL # 15.021 The Tribe did not have an effective control system in place to ensure that federal funds were fully protected and insured. AL # 93.600 The Department did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported or that the SF-429 was submitted. Effect: Without obtaining all information required by the grant, the Department is not following the grant guidelines and is operating the grant out of compliance. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-009. Recommendation: We recommend the necessary resources be allocated to develop, implement, and monitor policies and procedures to achieve its objectives related to operations, reporting, and compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by: a. States, local governments, and Indian tribes b. Institutions of higher education (IHEs) c. Nonprofit organizations Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under Federal awards; 4. 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. 7. Be adequately documented. AL #21.027 Recipients may use Fund payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 U.S.C. § 802 and 42 U.S.C. § 803 respectively), Treasury’s Interim Final Rule at 31 C.F.R. §§ 35.7 and 35.8. Condition/Context: During testing the following was noted: AL # 15.021 • 1 out of 13 non-payroll transactions was missing supporting documentation. AL # 15.033 • 1 of 12 IIIs did not have approval documented or support provided. • 6 of 47 payroll transactions did not have a timesheet provided. AL # 93.441 • 6 of 9 non-payroll samples did not have adequate documentation. • 4 of 51 payroll samples did not have an approved timesheet provided. • 7 of 51 payroll samples did not use the approved payrate. • 1 of 51 samples did not have a PAN to verify the approved rate. AL # 93.600 • 1 of 60 transactions was missing supporting documentation. AL # 21.027 • 2 of 2 III’s were missing sufficient documentation to support the cost. Additionally, one of these transactions appeared to be a principal payment on a loan. • 49 of 54 non-payroll samples were missing sufficient documentation to support the cost. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: There were not sufficient controls implemented to appropriately review and monitor activity and ensure amounts were properly recorded in the general ledger. Effect: Disbursement transactions are being processed without proper documentation. Questioned Costs: AL # 15.021 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 15.033 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 93.441 - Known - $28,309 AL # 93.600 - Known – $3,363 AL # 21.027 - Known - $1,094,753 Repeat Finding: Yes – 2020-010 (AL #’s 15.021, 15.033, 93.441, and 93.600). Recommendation: We recommend the Department update its policies to mention the retention aspect of disbursement processing and follow their written policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: According to federal regulations, property records must be maintained to include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the program was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, a physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years. Condition/Context: A physical inventory of equipment was not performed during fiscal year 2021 or in the prior year. There are no controls in place to ensure the inventory records are agreed to the capital assets ledger. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient internal controls over physical inventory and property management may have contributed to this finding. Effect: Without a physical inventory of capital assets that agree to the general ledger, it is possible that assets could be misappropriated without detection or disposed of improperly. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-006. Recommendation: A physical inventory should be conducted and reconciled to the general ledger and the capital asset listing at least every two years. Inventory records should include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: AL #93.600 SF-429 – Real Property Status Report and SF-429-A General Reporting (OMB No. 4040-0016) - These forms are filed annually based upon the end of the budget period. A separate SF-429-A must be completed for each parcel of real property reported and accompany the annual SF-429. SF-425 – Federal Financial Quarterly & Annual Reports – These reports are filed on an annual and quarterly basis. It requires recipients to provide comprehensive information ensure compliance with budgetary terms, federal regulations, and agency guidelines. AL #15.033 Tribal Transportation Program Report – This report is filed annually. Beginning in 2019, it replaced the annual narrative reports. It requires recipients to provide a financial report, non-construction activities report, and a project report for each project active during the reporting period. AL #21.027 Interim Report – The Interim Report will include a recipient’s expenditures through July 31, 2021 by category and at the summary level. The reporting requirements vary by type of recipient, the total allocation amount, and the date which the recipient first received its allocation. This is a one-time report. Project and Expenditure Report - Per the treasury, "The following recipients are required to submit annual Project and Expenditure Reports: Tribal governments that are allocated less than $30 million in SLFRF funding. For these recipients, the initial Project and Expenditure Report will cover from March 3, 2021 to March 31, 2022 and must be submitted to Treasury by April 30, 2022." Condition/Context: AL #93.600 The Tribe was unable to provide 4 of 4 SF-425 Quarterly reports, 2 of 2 Annual SF-425 reports, and 2 of 2 SF-429 annual reports. AL #15.033 The Tribe was unable to provide the Tribal Transportation Program Report. AL #21.027 The Tribe was unable to provide the Interim Report and the Project and Expenditure Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Due to turnover in key personnel and lack of internal controls, the Department did not have the ability to provide supporting documentation or the reports submitted. Effect: The Department is out of compliance with federal reporting requirements and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-008 (AL #’s 93.600 and 15.033). Recommendation: The Department should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by: a. States, local governments, and Indian tribes b. Institutions of higher education (IHEs) c. Nonprofit organizations Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under Federal awards; 4. 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. 7. Be adequately documented. AL #21.027 Recipients may use Fund payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 U.S.C. § 802 and 42 U.S.C. § 803 respectively), Treasury’s Interim Final Rule at 31 C.F.R. §§ 35.7 and 35.8. Condition/Context: During testing the following was noted: AL # 15.021 • 1 out of 13 non-payroll transactions was missing supporting documentation. AL # 15.033 • 1 of 12 IIIs did not have approval documented or support provided. • 6 of 47 payroll transactions did not have a timesheet provided. AL # 93.441 • 6 of 9 non-payroll samples did not have adequate documentation. • 4 of 51 payroll samples did not have an approved timesheet provided. • 7 of 51 payroll samples did not use the approved payrate. • 1 of 51 samples did not have a PAN to verify the approved rate. AL # 93.600 • 1 of 60 transactions was missing supporting documentation. AL # 21.027 • 2 of 2 III’s were missing sufficient documentation to support the cost. Additionally, one of these transactions appeared to be a principal payment on a loan. • 49 of 54 non-payroll samples were missing sufficient documentation to support the cost. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: There were not sufficient controls implemented to appropriately review and monitor activity and ensure amounts were properly recorded in the general ledger. Effect: Disbursement transactions are being processed without proper documentation. Questioned Costs: AL # 15.021 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 15.033 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 93.441 - Known - $28,309 AL # 93.600 - Known – $3,363 AL # 21.027 - Known - $1,094,753 Repeat Finding: Yes – 2020-010 (AL #’s 15.021, 15.033, 93.441, and 93.600). Recommendation: We recommend the Department update its policies to mention the retention aspect of disbursement processing and follow their written policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The Tribe's procurement policies and procedures require at least three price quotations for purchases over $10,000. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition/Context: AL #15.033 Procurement: • 2 of 12 IIIs and 2 of 2 samples did not have documentation that bids/quotes were received prior to payment. Debarment: • 11 of 12 IIIs did not have support to verify suspension and debarment searches were done and reviewed/approved. AL #93.441 Debarment: • 2 of 2 samples did not have support to verify suspension and debarment searches were done and reviewed/approved. AL #21.027 Procurement: • 1 of 1 sample did not have documentation that bids/quotes were received prior to payment. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient oversight may have led to procurement and suspension and debarment policies not being followed. Effect: The Tribe could be subject to questioned costs or other sanctions from funding agencies if they determine that programs did not assure full and open competition for the procurements or that suspension and debarment searches are not occurring. Questioned Costs: Procurement: Due to lack of sufficient documentation, we were unable to determine questioned costs. Debarment: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-012 (AL #’s 15.033 and 93.441). Recommendation: Established procurement, suspension and debarment policies and procedures should be enforced requiring bid documentation and suspension and debarment documentation be retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: According to federal regulations, property records must be maintained to include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the program was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, a physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years. Condition/Context: A physical inventory of equipment was not performed during fiscal year 2021 or in the prior year. There are no controls in place to ensure the inventory records are agreed to the capital assets ledger. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient internal controls over physical inventory and property management may have contributed to this finding. Effect: Without a physical inventory of capital assets that agree to the general ledger, it is possible that assets could be misappropriated without detection or disposed of improperly. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-006. Recommendation: A physical inventory should be conducted and reconciled to the general ledger and the capital asset listing at least every two years. Inventory records should include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by: a. States, local governments, and Indian tribes b. Institutions of higher education (IHEs) c. Nonprofit organizations Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under Federal awards; 4. 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. 7. Be adequately documented. AL #21.027 Recipients may use Fund payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 U.S.C. § 802 and 42 U.S.C. § 803 respectively), Treasury’s Interim Final Rule at 31 C.F.R. §§ 35.7 and 35.8. Condition/Context: During testing the following was noted: AL # 15.021 • 1 out of 13 non-payroll transactions was missing supporting documentation. AL # 15.033 • 1 of 12 IIIs did not have approval documented or support provided. • 6 of 47 payroll transactions did not have a timesheet provided. AL # 93.441 • 6 of 9 non-payroll samples did not have adequate documentation. • 4 of 51 payroll samples did not have an approved timesheet provided. • 7 of 51 payroll samples did not use the approved payrate. • 1 of 51 samples did not have a PAN to verify the approved rate. AL # 93.600 • 1 of 60 transactions was missing supporting documentation. AL # 21.027 • 2 of 2 III’s were missing sufficient documentation to support the cost. Additionally, one of these transactions appeared to be a principal payment on a loan. • 49 of 54 non-payroll samples were missing sufficient documentation to support the cost. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: There were not sufficient controls implemented to appropriately review and monitor activity and ensure amounts were properly recorded in the general ledger. Effect: Disbursement transactions are being processed without proper documentation. Questioned Costs: AL # 15.021 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 15.033 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 93.441 - Known - $28,309 AL # 93.600 - Known – $3,363 AL # 21.027 - Known - $1,094,753 Repeat Finding: Yes – 2020-010 (AL #’s 15.021, 15.033, 93.441, and 93.600). Recommendation: We recommend the Department update its policies to mention the retention aspect of disbursement processing and follow their written policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: Indian Health Services, 42 CFR 136.61, requires the Department to bill third-party insurance for services provided and use the income for health care or health care related activities. Condition/Context: The Department was unable to provide support for program income to ensure they were spending third-party funds on allowable costs for the following: • 2 of 10 IIIs and 2 of 12 nonpayroll samples did not have all management approvals. • 2 of 10 IIIs were not coded to the proper fund on the purchase requisition. • 1 of 12 nonpayroll samples did not have a PO provided to verify management approval and fund coding. • 16 of 48 payroll samples did use the approved payrate. • 3 of 12 nonpayroll samples did not have adequate support. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient oversight and internal controls over this requirement may have contributed to this finding. Effect: We were unable to determine whether program income is being used for allowable activities. Additionally, lack of sufficient documentation may cause the funding agency to question costs. Questioned Costs: N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. Repeat Finding: Yes – 2020-011. Recommendation: We recommend the Department continue to strengthen and reinforce its internal control policies and procedures and to ensure that monthly accounting reconciliations are performed and reviewed timely to produce accurate financial data related to third-party income and related expenses. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The Tribe's procurement policies and procedures require at least three price quotations for purchases over $10,000. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition/Context: AL #15.033 Procurement: • 2 of 12 IIIs and 2 of 2 samples did not have documentation that bids/quotes were received prior to payment. Debarment: • 11 of 12 IIIs did not have support to verify suspension and debarment searches were done and reviewed/approved. AL #93.441 Debarment: • 2 of 2 samples did not have support to verify suspension and debarment searches were done and reviewed/approved. AL #21.027 Procurement: • 1 of 1 sample did not have documentation that bids/quotes were received prior to payment. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient oversight may have led to procurement and suspension and debarment policies not being followed. Effect: The Tribe could be subject to questioned costs or other sanctions from funding agencies if they determine that programs did not assure full and open competition for the procurements or that suspension and debarment searches are not occurring. Questioned Costs: Procurement: Due to lack of sufficient documentation, we were unable to determine questioned costs. Debarment: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-012 (AL #’s 15.033 and 93.441). Recommendation: Established procurement, suspension and debarment policies and procedures should be enforced requiring bid documentation and suspension and debarment documentation be retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: Federal regulations require that grantees verify eligibility before providing services, and maintain records documenting such eligibility. Condition/Context: The Department was unable to provide support for 40 of 40 samples. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of record retention and the inability to locate information for prior years due to staff turnover. Effect: Individuals that are not eligible for services may have received services. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: No. Recommendation: All programs with eligibility requirements should reexamine processes and controls over participant eligibility to ensure all documentation is obtained and retained for all participants, regardless of whether the program staff are familiar with the program participant or not. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: According to federal regulations, property records must be maintained to include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the program was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, a physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years. Condition/Context: A physical inventory of equipment was not performed during fiscal year 2021 or in the prior year. There are no controls in place to ensure the inventory records are agreed to the capital assets ledger. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient internal controls over physical inventory and property management may have contributed to this finding. Effect: Without a physical inventory of capital assets that agree to the general ledger, it is possible that assets could be misappropriated without detection or disposed of improperly. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-006. Recommendation: A physical inventory should be conducted and reconciled to the general ledger and the capital asset listing at least every two years. Inventory records should include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: Proper internal controls related to compliance of Matching, Level of Effort and Earmarking for AL# 93.600 - Head Start, require that grantees must ensure that at least 10 percent of its total funded enrollment is filled by children eligible for service under the Individuals with Disabilities Education Act, unless a waiver has been approved in writing by OHS (42 USC 9835(d) and 45 CFR section 1302.14(b)). Condition/Context: The Department was unable to provide documentation on the number of children served that qualified for the Individuals with Disabilities Education Act; thus, the Department was not in compliance with this Compliance Requirement. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of oversight, record retention, and the ability to locate information for prior years due to turnover. Effect: We were unable to determine whether the Department met their targeted earmarking requirement for the school year. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-007. Recommendation: We recommend management emphasizes all documentation is obtained, properly completed, and retained so they can be easily accessed and presented. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: AL #93.600 SF-429 – Real Property Status Report and SF-429-A General Reporting (OMB No. 4040-0016) - These forms are filed annually based upon the end of the budget period. A separate SF-429-A must be completed for each parcel of real property reported and accompany the annual SF-429. SF-425 – Federal Financial Quarterly & Annual Reports – These reports are filed on an annual and quarterly basis. It requires recipients to provide comprehensive information ensure compliance with budgetary terms, federal regulations, and agency guidelines. AL #15.033 Tribal Transportation Program Report – This report is filed annually. Beginning in 2019, it replaced the annual narrative reports. It requires recipients to provide a financial report, non-construction activities report, and a project report for each project active during the reporting period. AL #21.027 Interim Report – The Interim Report will include a recipient’s expenditures through July 31, 2021 by category and at the summary level. The reporting requirements vary by type of recipient, the total allocation amount, and the date which the recipient first received its allocation. This is a one-time report. Project and Expenditure Report - Per the treasury, "The following recipients are required to submit annual Project and Expenditure Reports: Tribal governments that are allocated less than $30 million in SLFRF funding. For these recipients, the initial Project and Expenditure Report will cover from March 3, 2021 to March 31, 2022 and must be submitted to Treasury by April 30, 2022." Condition/Context: AL #93.600 The Tribe was unable to provide 4 of 4 SF-425 Quarterly reports, 2 of 2 Annual SF-425 reports, and 2 of 2 SF-429 annual reports. AL #15.033 The Tribe was unable to provide the Tribal Transportation Program Report. AL #21.027 The Tribe was unable to provide the Interim Report and the Project and Expenditure Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Due to turnover in key personnel and lack of internal controls, the Department did not have the ability to provide supporting documentation or the reports submitted. Effect: The Department is out of compliance with federal reporting requirements and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-008 (AL #’s 93.600 and 15.033). Recommendation: The Department should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: AL # 15.021 Investment and Deposit of Advance Funds - A tribe, tribal organization, or consortia receiving advance payments under the ISDEAA or the Tribally Controlled Schools Act may invest advance payments (some recipients refer to these advance payments as “deferred revenue”) before such funds are expended for the purposes of the grant, contract, or funding agreement, so long as such funds are (1) invested only in obligations of the United States or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed or insured by the United States; or (2) deposited only in accounts that are insured by an agency or instrumentality of the United States, or are fully collateralized to ensure protection of the advance funds, even in the event of a bank failure (25 USC 450e-3). AL # 93.600 Head Start uses specific terms related to real property and facilities, which are defined at 45 CFR section 1305.2, including construction, facility, Federal interest, major renovation, and modular unit. Facilities activities (purchase, construction, major renovation, subordination of a Federal interest, refinancing, and disposition) are initiated through the submission of Form SF-429 (cover sheet) and applicable Attachments B (Request to Acquire, Improve or Furnish) or C (Disposition or Encumbrance Request). Condition/Context: AL # 15.021 During testing of Investment and Deposit of Advance funds, it was noted that advanced funds are not fully collateralized or insured. AL # 93.600 The Department was unable to provide documentation of SF-429 reporting to verify it was completed and submitted on time. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: AL # 15.021 The Tribe did not have an effective control system in place to ensure that federal funds were fully protected and insured. AL # 93.600 The Department did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported or that the SF-429 was submitted. Effect: Without obtaining all information required by the grant, the Department is not following the grant guidelines and is operating the grant out of compliance. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-009. Recommendation: We recommend the necessary resources be allocated to develop, implement, and monitor policies and procedures to achieve its objectives related to operations, reporting, and compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by: a. States, local governments, and Indian tribes b. Institutions of higher education (IHEs) c. Nonprofit organizations Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under Federal awards; 4. 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. 7. Be adequately documented. AL #21.027 Recipients may use Fund payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 U.S.C. § 802 and 42 U.S.C. § 803 respectively), Treasury’s Interim Final Rule at 31 C.F.R. §§ 35.7 and 35.8. Condition/Context: During testing the following was noted: AL # 15.021 • 1 out of 13 non-payroll transactions was missing supporting documentation. AL # 15.033 • 1 of 12 IIIs did not have approval documented or support provided. • 6 of 47 payroll transactions did not have a timesheet provided. AL # 93.441 • 6 of 9 non-payroll samples did not have adequate documentation. • 4 of 51 payroll samples did not have an approved timesheet provided. • 7 of 51 payroll samples did not use the approved payrate. • 1 of 51 samples did not have a PAN to verify the approved rate. AL # 93.600 • 1 of 60 transactions was missing supporting documentation. AL # 21.027 • 2 of 2 III’s were missing sufficient documentation to support the cost. Additionally, one of these transactions appeared to be a principal payment on a loan. • 49 of 54 non-payroll samples were missing sufficient documentation to support the cost. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: There were not sufficient controls implemented to appropriately review and monitor activity and ensure amounts were properly recorded in the general ledger. Effect: Disbursement transactions are being processed without proper documentation. Questioned Costs: AL # 15.021 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 15.033 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 93.441 - Known - $28,309 AL # 93.600 - Known – $3,363 AL # 21.027 - Known - $1,094,753 Repeat Finding: Yes – 2020-010 (AL #’s 15.021, 15.033, 93.441, and 93.600). Recommendation: We recommend the Department update its policies to mention the retention aspect of disbursement processing and follow their written policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: AL #93.600 SF-429 – Real Property Status Report and SF-429-A General Reporting (OMB No. 4040-0016) - These forms are filed annually based upon the end of the budget period. A separate SF-429-A must be completed for each parcel of real property reported and accompany the annual SF-429. SF-425 – Federal Financial Quarterly & Annual Reports – These reports are filed on an annual and quarterly basis. It requires recipients to provide comprehensive information ensure compliance with budgetary terms, federal regulations, and agency guidelines. AL #15.033 Tribal Transportation Program Report – This report is filed annually. Beginning in 2019, it replaced the annual narrative reports. It requires recipients to provide a financial report, non-construction activities report, and a project report for each project active during the reporting period. AL #21.027 Interim Report – The Interim Report will include a recipient’s expenditures through July 31, 2021 by category and at the summary level. The reporting requirements vary by type of recipient, the total allocation amount, and the date which the recipient first received its allocation. This is a one-time report. Project and Expenditure Report - Per the treasury, "The following recipients are required to submit annual Project and Expenditure Reports: Tribal governments that are allocated less than $30 million in SLFRF funding. For these recipients, the initial Project and Expenditure Report will cover from March 3, 2021 to March 31, 2022 and must be submitted to Treasury by April 30, 2022." Condition/Context: AL #93.600 The Tribe was unable to provide 4 of 4 SF-425 Quarterly reports, 2 of 2 Annual SF-425 reports, and 2 of 2 SF-429 annual reports. AL #15.033 The Tribe was unable to provide the Tribal Transportation Program Report. AL #21.027 The Tribe was unable to provide the Interim Report and the Project and Expenditure Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Due to turnover in key personnel and lack of internal controls, the Department did not have the ability to provide supporting documentation or the reports submitted. Effect: The Department is out of compliance with federal reporting requirements and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-008 (AL #’s 93.600 and 15.033). Recommendation: The Department should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by: a. States, local governments, and Indian tribes b. Institutions of higher education (IHEs) c. Nonprofit organizations Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under Federal awards; 4. 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. 7. Be adequately documented. AL #21.027 Recipients may use Fund payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 U.S.C. § 802 and 42 U.S.C. § 803 respectively), Treasury’s Interim Final Rule at 31 C.F.R. §§ 35.7 and 35.8. Condition/Context: During testing the following was noted: AL # 15.021 • 1 out of 13 non-payroll transactions was missing supporting documentation. AL # 15.033 • 1 of 12 IIIs did not have approval documented or support provided. • 6 of 47 payroll transactions did not have a timesheet provided. AL # 93.441 • 6 of 9 non-payroll samples did not have adequate documentation. • 4 of 51 payroll samples did not have an approved timesheet provided. • 7 of 51 payroll samples did not use the approved payrate. • 1 of 51 samples did not have a PAN to verify the approved rate. AL # 93.600 • 1 of 60 transactions was missing supporting documentation. AL # 21.027 • 2 of 2 III’s were missing sufficient documentation to support the cost. Additionally, one of these transactions appeared to be a principal payment on a loan. • 49 of 54 non-payroll samples were missing sufficient documentation to support the cost. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: There were not sufficient controls implemented to appropriately review and monitor activity and ensure amounts were properly recorded in the general ledger. Effect: Disbursement transactions are being processed without proper documentation. Questioned Costs: AL # 15.021 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 15.033 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 93.441 - Known - $28,309 AL # 93.600 - Known – $3,363 AL # 21.027 - Known - $1,094,753 Repeat Finding: Yes – 2020-010 (AL #’s 15.021, 15.033, 93.441, and 93.600). Recommendation: We recommend the Department update its policies to mention the retention aspect of disbursement processing and follow their written policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The Tribe's procurement policies and procedures require at least three price quotations for purchases over $10,000. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition/Context: AL #15.033 Procurement: • 2 of 12 IIIs and 2 of 2 samples did not have documentation that bids/quotes were received prior to payment. Debarment: • 11 of 12 IIIs did not have support to verify suspension and debarment searches were done and reviewed/approved. AL #93.441 Debarment: • 2 of 2 samples did not have support to verify suspension and debarment searches were done and reviewed/approved. AL #21.027 Procurement: • 1 of 1 sample did not have documentation that bids/quotes were received prior to payment. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient oversight may have led to procurement and suspension and debarment policies not being followed. Effect: The Tribe could be subject to questioned costs or other sanctions from funding agencies if they determine that programs did not assure full and open competition for the procurements or that suspension and debarment searches are not occurring. Questioned Costs: Procurement: Due to lack of sufficient documentation, we were unable to determine questioned costs. Debarment: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-012 (AL #’s 15.033 and 93.441). Recommendation: Established procurement, suspension and debarment policies and procedures should be enforced requiring bid documentation and suspension and debarment documentation be retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: 200.302 Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: All Department of Treasury funding was accounted for in the same fund, and we are unable to break out federal expenditures for each individual Treasury award (21.027 and 21.019) [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Improper records and tracking of federal awards due to staff turnover and lack of controls. Effect: Without being able to account for the Treasury awards separately, the population for each award was unable to be determined. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: No. Recommendation: We recommend management break out expenditures for each award in a way that expenditures can be tracked by program. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: AL # 15.021 Investment and Deposit of Advance Funds - A tribe, tribal organization, or consortia receiving advance payments under the ISDEAA or the Tribally Controlled Schools Act may invest advance payments (some recipients refer to these advance payments as “deferred revenue”) before such funds are expended for the purposes of the grant, contract, or funding agreement, so long as such funds are (1) invested only in obligations of the United States or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed or insured by the United States; or (2) deposited only in accounts that are insured by an agency or instrumentality of the United States, or are fully collateralized to ensure protection of the advance funds, even in the event of a bank failure (25 USC 450e-3). AL # 93.600 Head Start uses specific terms related to real property and facilities, which are defined at 45 CFR section 1305.2, including construction, facility, Federal interest, major renovation, and modular unit. Facilities activities (purchase, construction, major renovation, subordination of a Federal interest, refinancing, and disposition) are initiated through the submission of Form SF-429 (cover sheet) and applicable Attachments B (Request to Acquire, Improve or Furnish) or C (Disposition or Encumbrance Request). Condition/Context: AL # 15.021 During testing of Investment and Deposit of Advance funds, it was noted that advanced funds are not fully collateralized or insured. AL # 93.600 The Department was unable to provide documentation of SF-429 reporting to verify it was completed and submitted on time. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: AL # 15.021 The Tribe did not have an effective control system in place to ensure that federal funds were fully protected and insured. AL # 93.600 The Department did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported or that the SF-429 was submitted. Effect: Without obtaining all information required by the grant, the Department is not following the grant guidelines and is operating the grant out of compliance. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-009. Recommendation: We recommend the necessary resources be allocated to develop, implement, and monitor policies and procedures to achieve its objectives related to operations, reporting, and compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by: a. States, local governments, and Indian tribes b. Institutions of higher education (IHEs) c. Nonprofit organizations Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under Federal awards; 4. 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. 7. Be adequately documented. AL #21.027 Recipients may use Fund payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 U.S.C. § 802 and 42 U.S.C. § 803 respectively), Treasury’s Interim Final Rule at 31 C.F.R. §§ 35.7 and 35.8. Condition/Context: During testing the following was noted: AL # 15.021 • 1 out of 13 non-payroll transactions was missing supporting documentation. AL # 15.033 • 1 of 12 IIIs did not have approval documented or support provided. • 6 of 47 payroll transactions did not have a timesheet provided. AL # 93.441 • 6 of 9 non-payroll samples did not have adequate documentation. • 4 of 51 payroll samples did not have an approved timesheet provided. • 7 of 51 payroll samples did not use the approved payrate. • 1 of 51 samples did not have a PAN to verify the approved rate. AL # 93.600 • 1 of 60 transactions was missing supporting documentation. AL # 21.027 • 2 of 2 III’s were missing sufficient documentation to support the cost. Additionally, one of these transactions appeared to be a principal payment on a loan. • 49 of 54 non-payroll samples were missing sufficient documentation to support the cost. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: There were not sufficient controls implemented to appropriately review and monitor activity and ensure amounts were properly recorded in the general ledger. Effect: Disbursement transactions are being processed without proper documentation. Questioned Costs: AL # 15.021 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 15.033 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 93.441 - Known - $28,309 AL # 93.600 - Known – $3,363 AL # 21.027 - Known - $1,094,753 Repeat Finding: Yes – 2020-010 (AL #’s 15.021, 15.033, 93.441, and 93.600). Recommendation: We recommend the Department update its policies to mention the retention aspect of disbursement processing and follow their written policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: According to federal regulations, property records must be maintained to include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the program was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, a physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years. Condition/Context: A physical inventory of equipment was not performed during fiscal year 2021 or in the prior year. There are no controls in place to ensure the inventory records are agreed to the capital assets ledger. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient internal controls over physical inventory and property management may have contributed to this finding. Effect: Without a physical inventory of capital assets that agree to the general ledger, it is possible that assets could be misappropriated without detection or disposed of improperly. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-006. Recommendation: A physical inventory should be conducted and reconciled to the general ledger and the capital asset listing at least every two years. Inventory records should include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: AL #93.600 SF-429 – Real Property Status Report and SF-429-A General Reporting (OMB No. 4040-0016) - These forms are filed annually based upon the end of the budget period. A separate SF-429-A must be completed for each parcel of real property reported and accompany the annual SF-429. SF-425 – Federal Financial Quarterly & Annual Reports – These reports are filed on an annual and quarterly basis. It requires recipients to provide comprehensive information ensure compliance with budgetary terms, federal regulations, and agency guidelines. AL #15.033 Tribal Transportation Program Report – This report is filed annually. Beginning in 2019, it replaced the annual narrative reports. It requires recipients to provide a financial report, non-construction activities report, and a project report for each project active during the reporting period. AL #21.027 Interim Report – The Interim Report will include a recipient’s expenditures through July 31, 2021 by category and at the summary level. The reporting requirements vary by type of recipient, the total allocation amount, and the date which the recipient first received its allocation. This is a one-time report. Project and Expenditure Report - Per the treasury, "The following recipients are required to submit annual Project and Expenditure Reports: Tribal governments that are allocated less than $30 million in SLFRF funding. For these recipients, the initial Project and Expenditure Report will cover from March 3, 2021 to March 31, 2022 and must be submitted to Treasury by April 30, 2022." Condition/Context: AL #93.600 The Tribe was unable to provide 4 of 4 SF-425 Quarterly reports, 2 of 2 Annual SF-425 reports, and 2 of 2 SF-429 annual reports. AL #15.033 The Tribe was unable to provide the Tribal Transportation Program Report. AL #21.027 The Tribe was unable to provide the Interim Report and the Project and Expenditure Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Due to turnover in key personnel and lack of internal controls, the Department did not have the ability to provide supporting documentation or the reports submitted. Effect: The Department is out of compliance with federal reporting requirements and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-008 (AL #’s 93.600 and 15.033). Recommendation: The Department should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by: a. States, local governments, and Indian tribes b. Institutions of higher education (IHEs) c. Nonprofit organizations Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under Federal awards; 4. 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. 7. Be adequately documented. AL #21.027 Recipients may use Fund payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 U.S.C. § 802 and 42 U.S.C. § 803 respectively), Treasury’s Interim Final Rule at 31 C.F.R. §§ 35.7 and 35.8. Condition/Context: During testing the following was noted: AL # 15.021 • 1 out of 13 non-payroll transactions was missing supporting documentation. AL # 15.033 • 1 of 12 IIIs did not have approval documented or support provided. • 6 of 47 payroll transactions did not have a timesheet provided. AL # 93.441 • 6 of 9 non-payroll samples did not have adequate documentation. • 4 of 51 payroll samples did not have an approved timesheet provided. • 7 of 51 payroll samples did not use the approved payrate. • 1 of 51 samples did not have a PAN to verify the approved rate. AL # 93.600 • 1 of 60 transactions was missing supporting documentation. AL # 21.027 • 2 of 2 III’s were missing sufficient documentation to support the cost. Additionally, one of these transactions appeared to be a principal payment on a loan. • 49 of 54 non-payroll samples were missing sufficient documentation to support the cost. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: There were not sufficient controls implemented to appropriately review and monitor activity and ensure amounts were properly recorded in the general ledger. Effect: Disbursement transactions are being processed without proper documentation. Questioned Costs: AL # 15.021 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 15.033 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 93.441 - Known - $28,309 AL # 93.600 - Known – $3,363 AL # 21.027 - Known - $1,094,753 Repeat Finding: Yes – 2020-010 (AL #’s 15.021, 15.033, 93.441, and 93.600). Recommendation: We recommend the Department update its policies to mention the retention aspect of disbursement processing and follow their written policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The Tribe's procurement policies and procedures require at least three price quotations for purchases over $10,000. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition/Context: AL #15.033 Procurement: • 2 of 12 IIIs and 2 of 2 samples did not have documentation that bids/quotes were received prior to payment. Debarment: • 11 of 12 IIIs did not have support to verify suspension and debarment searches were done and reviewed/approved. AL #93.441 Debarment: • 2 of 2 samples did not have support to verify suspension and debarment searches were done and reviewed/approved. AL #21.027 Procurement: • 1 of 1 sample did not have documentation that bids/quotes were received prior to payment. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient oversight may have led to procurement and suspension and debarment policies not being followed. Effect: The Tribe could be subject to questioned costs or other sanctions from funding agencies if they determine that programs did not assure full and open competition for the procurements or that suspension and debarment searches are not occurring. Questioned Costs: Procurement: Due to lack of sufficient documentation, we were unable to determine questioned costs. Debarment: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-012 (AL #’s 15.033 and 93.441). Recommendation: Established procurement, suspension and debarment policies and procedures should be enforced requiring bid documentation and suspension and debarment documentation be retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: According to federal regulations, property records must be maintained to include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the program was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, a physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years. Condition/Context: A physical inventory of equipment was not performed during fiscal year 2021 or in the prior year. There are no controls in place to ensure the inventory records are agreed to the capital assets ledger. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient internal controls over physical inventory and property management may have contributed to this finding. Effect: Without a physical inventory of capital assets that agree to the general ledger, it is possible that assets could be misappropriated without detection or disposed of improperly. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-006. Recommendation: A physical inventory should be conducted and reconciled to the general ledger and the capital asset listing at least every two years. Inventory records should include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by: a. States, local governments, and Indian tribes b. Institutions of higher education (IHEs) c. Nonprofit organizations Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under Federal awards; 4. 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. 7. Be adequately documented. AL #21.027 Recipients may use Fund payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 U.S.C. § 802 and 42 U.S.C. § 803 respectively), Treasury’s Interim Final Rule at 31 C.F.R. §§ 35.7 and 35.8. Condition/Context: During testing the following was noted: AL # 15.021 • 1 out of 13 non-payroll transactions was missing supporting documentation. AL # 15.033 • 1 of 12 IIIs did not have approval documented or support provided. • 6 of 47 payroll transactions did not have a timesheet provided. AL # 93.441 • 6 of 9 non-payroll samples did not have adequate documentation. • 4 of 51 payroll samples did not have an approved timesheet provided. • 7 of 51 payroll samples did not use the approved payrate. • 1 of 51 samples did not have a PAN to verify the approved rate. AL # 93.600 • 1 of 60 transactions was missing supporting documentation. AL # 21.027 • 2 of 2 III’s were missing sufficient documentation to support the cost. Additionally, one of these transactions appeared to be a principal payment on a loan. • 49 of 54 non-payroll samples were missing sufficient documentation to support the cost. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: There were not sufficient controls implemented to appropriately review and monitor activity and ensure amounts were properly recorded in the general ledger. Effect: Disbursement transactions are being processed without proper documentation. Questioned Costs: AL # 15.021 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 15.033 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 93.441 - Known - $28,309 AL # 93.600 - Known – $3,363 AL # 21.027 - Known - $1,094,753 Repeat Finding: Yes – 2020-010 (AL #’s 15.021, 15.033, 93.441, and 93.600). Recommendation: We recommend the Department update its policies to mention the retention aspect of disbursement processing and follow their written policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: Indian Health Services, 42 CFR 136.61, requires the Department to bill third-party insurance for services provided and use the income for health care or health care related activities. Condition/Context: The Department was unable to provide support for program income to ensure they were spending third-party funds on allowable costs for the following: • 2 of 10 IIIs and 2 of 12 nonpayroll samples did not have all management approvals. • 2 of 10 IIIs were not coded to the proper fund on the purchase requisition. • 1 of 12 nonpayroll samples did not have a PO provided to verify management approval and fund coding. • 16 of 48 payroll samples did use the approved payrate. • 3 of 12 nonpayroll samples did not have adequate support. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient oversight and internal controls over this requirement may have contributed to this finding. Effect: We were unable to determine whether program income is being used for allowable activities. Additionally, lack of sufficient documentation may cause the funding agency to question costs. Questioned Costs: N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. Repeat Finding: Yes – 2020-011. Recommendation: We recommend the Department continue to strengthen and reinforce its internal control policies and procedures and to ensure that monthly accounting reconciliations are performed and reviewed timely to produce accurate financial data related to third-party income and related expenses. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The Tribe's procurement policies and procedures require at least three price quotations for purchases over $10,000. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition/Context: AL #15.033 Procurement: • 2 of 12 IIIs and 2 of 2 samples did not have documentation that bids/quotes were received prior to payment. Debarment: • 11 of 12 IIIs did not have support to verify suspension and debarment searches were done and reviewed/approved. AL #93.441 Debarment: • 2 of 2 samples did not have support to verify suspension and debarment searches were done and reviewed/approved. AL #21.027 Procurement: • 1 of 1 sample did not have documentation that bids/quotes were received prior to payment. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient oversight may have led to procurement and suspension and debarment policies not being followed. Effect: The Tribe could be subject to questioned costs or other sanctions from funding agencies if they determine that programs did not assure full and open competition for the procurements or that suspension and debarment searches are not occurring. Questioned Costs: Procurement: Due to lack of sufficient documentation, we were unable to determine questioned costs. Debarment: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-012 (AL #’s 15.033 and 93.441). Recommendation: Established procurement, suspension and debarment policies and procedures should be enforced requiring bid documentation and suspension and debarment documentation be retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: Federal regulations require that grantees verify eligibility before providing services, and maintain records documenting such eligibility. Condition/Context: The Department was unable to provide support for 40 of 40 samples. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of record retention and the inability to locate information for prior years due to staff turnover. Effect: Individuals that are not eligible for services may have received services. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: No. Recommendation: All programs with eligibility requirements should reexamine processes and controls over participant eligibility to ensure all documentation is obtained and retained for all participants, regardless of whether the program staff are familiar with the program participant or not. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: According to federal regulations, property records must be maintained to include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, cost of the property, percentage of federal participation in the project costs for the federal award under which the program was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. Further, a physical inventory of the property must be taken, and the results reconciled with the property records at least once every two years. Condition/Context: A physical inventory of equipment was not performed during fiscal year 2021 or in the prior year. There are no controls in place to ensure the inventory records are agreed to the capital assets ledger. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient internal controls over physical inventory and property management may have contributed to this finding. Effect: Without a physical inventory of capital assets that agree to the general ledger, it is possible that assets could be misappropriated without detection or disposed of improperly. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-006. Recommendation: A physical inventory should be conducted and reconciled to the general ledger and the capital asset listing at least every two years. Inventory records should include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of federal participation in the project costs for the federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: Proper internal controls related to compliance of Matching, Level of Effort and Earmarking for AL# 93.600 - Head Start, require that grantees must ensure that at least 10 percent of its total funded enrollment is filled by children eligible for service under the Individuals with Disabilities Education Act, unless a waiver has been approved in writing by OHS (42 USC 9835(d) and 45 CFR section 1302.14(b)). Condition/Context: The Department was unable to provide documentation on the number of children served that qualified for the Individuals with Disabilities Education Act; thus, the Department was not in compliance with this Compliance Requirement. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of oversight, record retention, and the ability to locate information for prior years due to turnover. Effect: We were unable to determine whether the Department met their targeted earmarking requirement for the school year. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-007. Recommendation: We recommend management emphasizes all documentation is obtained, properly completed, and retained so they can be easily accessed and presented. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: AL #93.600 SF-429 – Real Property Status Report and SF-429-A General Reporting (OMB No. 4040-0016) - These forms are filed annually based upon the end of the budget period. A separate SF-429-A must be completed for each parcel of real property reported and accompany the annual SF-429. SF-425 – Federal Financial Quarterly & Annual Reports – These reports are filed on an annual and quarterly basis. It requires recipients to provide comprehensive information ensure compliance with budgetary terms, federal regulations, and agency guidelines. AL #15.033 Tribal Transportation Program Report – This report is filed annually. Beginning in 2019, it replaced the annual narrative reports. It requires recipients to provide a financial report, non-construction activities report, and a project report for each project active during the reporting period. AL #21.027 Interim Report – The Interim Report will include a recipient’s expenditures through July 31, 2021 by category and at the summary level. The reporting requirements vary by type of recipient, the total allocation amount, and the date which the recipient first received its allocation. This is a one-time report. Project and Expenditure Report - Per the treasury, "The following recipients are required to submit annual Project and Expenditure Reports: Tribal governments that are allocated less than $30 million in SLFRF funding. For these recipients, the initial Project and Expenditure Report will cover from March 3, 2021 to March 31, 2022 and must be submitted to Treasury by April 30, 2022." Condition/Context: AL #93.600 The Tribe was unable to provide 4 of 4 SF-425 Quarterly reports, 2 of 2 Annual SF-425 reports, and 2 of 2 SF-429 annual reports. AL #15.033 The Tribe was unable to provide the Tribal Transportation Program Report. AL #21.027 The Tribe was unable to provide the Interim Report and the Project and Expenditure Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Due to turnover in key personnel and lack of internal controls, the Department did not have the ability to provide supporting documentation or the reports submitted. Effect: The Department is out of compliance with federal reporting requirements and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-008 (AL #’s 93.600 and 15.033). Recommendation: The Department should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: AL # 15.021 Investment and Deposit of Advance Funds - A tribe, tribal organization, or consortia receiving advance payments under the ISDEAA or the Tribally Controlled Schools Act may invest advance payments (some recipients refer to these advance payments as “deferred revenue”) before such funds are expended for the purposes of the grant, contract, or funding agreement, so long as such funds are (1) invested only in obligations of the United States or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed or insured by the United States; or (2) deposited only in accounts that are insured by an agency or instrumentality of the United States, or are fully collateralized to ensure protection of the advance funds, even in the event of a bank failure (25 USC 450e-3). AL # 93.600 Head Start uses specific terms related to real property and facilities, which are defined at 45 CFR section 1305.2, including construction, facility, Federal interest, major renovation, and modular unit. Facilities activities (purchase, construction, major renovation, subordination of a Federal interest, refinancing, and disposition) are initiated through the submission of Form SF-429 (cover sheet) and applicable Attachments B (Request to Acquire, Improve or Furnish) or C (Disposition or Encumbrance Request). Condition/Context: AL # 15.021 During testing of Investment and Deposit of Advance funds, it was noted that advanced funds are not fully collateralized or insured. AL # 93.600 The Department was unable to provide documentation of SF-429 reporting to verify it was completed and submitted on time. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: AL # 15.021 The Tribe did not have an effective control system in place to ensure that federal funds were fully protected and insured. AL # 93.600 The Department did not have an effective control system in place to ensure that documentation was retained to support amounts originally reported or that the SF-429 was submitted. Effect: Without obtaining all information required by the grant, the Department is not following the grant guidelines and is operating the grant out of compliance. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-009. Recommendation: We recommend the necessary resources be allocated to develop, implement, and monitor policies and procedures to achieve its objectives related to operations, reporting, and compliance. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by: a. States, local governments, and Indian tribes b. Institutions of higher education (IHEs) c. Nonprofit organizations Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under Federal awards; 4. 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. 7. Be adequately documented. AL #21.027 Recipients may use Fund payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 U.S.C. § 802 and 42 U.S.C. § 803 respectively), Treasury’s Interim Final Rule at 31 C.F.R. §§ 35.7 and 35.8. Condition/Context: During testing the following was noted: AL # 15.021 • 1 out of 13 non-payroll transactions was missing supporting documentation. AL # 15.033 • 1 of 12 IIIs did not have approval documented or support provided. • 6 of 47 payroll transactions did not have a timesheet provided. AL # 93.441 • 6 of 9 non-payroll samples did not have adequate documentation. • 4 of 51 payroll samples did not have an approved timesheet provided. • 7 of 51 payroll samples did not use the approved payrate. • 1 of 51 samples did not have a PAN to verify the approved rate. AL # 93.600 • 1 of 60 transactions was missing supporting documentation. AL # 21.027 • 2 of 2 III’s were missing sufficient documentation to support the cost. Additionally, one of these transactions appeared to be a principal payment on a loan. • 49 of 54 non-payroll samples were missing sufficient documentation to support the cost. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: There were not sufficient controls implemented to appropriately review and monitor activity and ensure amounts were properly recorded in the general ledger. Effect: Disbursement transactions are being processed without proper documentation. Questioned Costs: AL # 15.021 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 15.033 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 93.441 - Known - $28,309 AL # 93.600 - Known – $3,363 AL # 21.027 - Known - $1,094,753 Repeat Finding: Yes – 2020-010 (AL #’s 15.021, 15.033, 93.441, and 93.600). Recommendation: We recommend the Department update its policies to mention the retention aspect of disbursement processing and follow their written policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: AL #93.600 SF-429 – Real Property Status Report and SF-429-A General Reporting (OMB No. 4040-0016) - These forms are filed annually based upon the end of the budget period. A separate SF-429-A must be completed for each parcel of real property reported and accompany the annual SF-429. SF-425 – Federal Financial Quarterly & Annual Reports – These reports are filed on an annual and quarterly basis. It requires recipients to provide comprehensive information ensure compliance with budgetary terms, federal regulations, and agency guidelines. AL #15.033 Tribal Transportation Program Report – This report is filed annually. Beginning in 2019, it replaced the annual narrative reports. It requires recipients to provide a financial report, non-construction activities report, and a project report for each project active during the reporting period. AL #21.027 Interim Report – The Interim Report will include a recipient’s expenditures through July 31, 2021 by category and at the summary level. The reporting requirements vary by type of recipient, the total allocation amount, and the date which the recipient first received its allocation. This is a one-time report. Project and Expenditure Report - Per the treasury, "The following recipients are required to submit annual Project and Expenditure Reports: Tribal governments that are allocated less than $30 million in SLFRF funding. For these recipients, the initial Project and Expenditure Report will cover from March 3, 2021 to March 31, 2022 and must be submitted to Treasury by April 30, 2022." Condition/Context: AL #93.600 The Tribe was unable to provide 4 of 4 SF-425 Quarterly reports, 2 of 2 Annual SF-425 reports, and 2 of 2 SF-429 annual reports. AL #15.033 The Tribe was unable to provide the Tribal Transportation Program Report. AL #21.027 The Tribe was unable to provide the Interim Report and the Project and Expenditure Report. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Due to turnover in key personnel and lack of internal controls, the Department did not have the ability to provide supporting documentation or the reports submitted. Effect: The Department is out of compliance with federal reporting requirements and amounts reported to federal agencies may be inaccurate. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-008 (AL #’s 93.600 and 15.033). Recommendation: The Department should improve the controls over the reporting function, which includes the documentation, review, and approval of all required reports, and effective controls over the preparation of reports, as well as a monitoring function to ensure that controls are in place and operating effectively for report submission. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by: a. States, local governments, and Indian tribes b. Institutions of higher education (IHEs) c. Nonprofit organizations Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under Federal awards; 4. 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. 7. Be adequately documented. AL #21.027 Recipients may use Fund payments for any eligible expenses subject to the restrictions set forth in sections 602 and 603 of the Social Security Act as added by section 9901 of the American Rescue Plan Act of 2021 (codified as 42 U.S.C. § 802 and 42 U.S.C. § 803 respectively), Treasury’s Interim Final Rule at 31 C.F.R. §§ 35.7 and 35.8. Condition/Context: During testing the following was noted: AL # 15.021 • 1 out of 13 non-payroll transactions was missing supporting documentation. AL # 15.033 • 1 of 12 IIIs did not have approval documented or support provided. • 6 of 47 payroll transactions did not have a timesheet provided. AL # 93.441 • 6 of 9 non-payroll samples did not have adequate documentation. • 4 of 51 payroll samples did not have an approved timesheet provided. • 7 of 51 payroll samples did not use the approved payrate. • 1 of 51 samples did not have a PAN to verify the approved rate. AL # 93.600 • 1 of 60 transactions was missing supporting documentation. AL # 21.027 • 2 of 2 III’s were missing sufficient documentation to support the cost. Additionally, one of these transactions appeared to be a principal payment on a loan. • 49 of 54 non-payroll samples were missing sufficient documentation to support the cost. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: There were not sufficient controls implemented to appropriately review and monitor activity and ensure amounts were properly recorded in the general ledger. Effect: Disbursement transactions are being processed without proper documentation. Questioned Costs: AL # 15.021 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 15.033 - Known – N/A, the known plus likely questioned costs did not exceed $25,000, therefore no questioned costs are reported. AL # 93.441 - Known - $28,309 AL # 93.600 - Known – $3,363 AL # 21.027 - Known - $1,094,753 Repeat Finding: Yes – 2020-010 (AL #’s 15.021, 15.033, 93.441, and 93.600). Recommendation: We recommend the Department update its policies to mention the retention aspect of disbursement processing and follow their written policies. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: The Tribe's procurement policies and procedures require at least three price quotations for purchases over $10,000. Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-Federal entity enters into a covered transaction with an entity at a lower tier, the non-Federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition/Context: AL #15.033 Procurement: • 2 of 12 IIIs and 2 of 2 samples did not have documentation that bids/quotes were received prior to payment. Debarment: • 11 of 12 IIIs did not have support to verify suspension and debarment searches were done and reviewed/approved. AL #93.441 Debarment: • 2 of 2 samples did not have support to verify suspension and debarment searches were done and reviewed/approved. AL #21.027 Procurement: • 1 of 1 sample did not have documentation that bids/quotes were received prior to payment. [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Lack of sufficient oversight may have led to procurement and suspension and debarment policies not being followed. Effect: The Tribe could be subject to questioned costs or other sanctions from funding agencies if they determine that programs did not assure full and open competition for the procurements or that suspension and debarment searches are not occurring. Questioned Costs: Procurement: Due to lack of sufficient documentation, we were unable to determine questioned costs. Debarment: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: Yes – 2020-012 (AL #’s 15.033 and 93.441). Recommendation: Established procurement, suspension and debarment policies and procedures should be enforced requiring bid documentation and suspension and debarment documentation be retained. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: See the audit finding for chart/table Criteria or specific requirement: 200.302 Financial management. (a) Each state must expend and account for the Federal award in accordance with state laws and procedures for expending and accounting for the state's own funds. In addition, the state's and the other non-Federal entity's financial management systems, including records documenting compliance with Federal statutes, regulations, and the terms and conditions of the Federal award, must be sufficient to permit the preparation of reports required by general and program-specific terms and conditions; and the tracing of funds to a level of expenditures adequate to establish that such funds have been used according to the Federal statutes, regulations, and the terms and conditions of the Federal award. Condition/Context: All Department of Treasury funding was accounted for in the same fund, and we are unable to break out federal expenditures for each individual Treasury award (21.027 and 21.019) [X] Compliance Finding [ ] Significant Deficiency [X] Material Weakness Cause: Improper records and tracking of federal awards due to staff turnover and lack of controls. Effect: Without being able to account for the Treasury awards separately, the population for each award was unable to be determined. Questioned Costs: Due to lack of sufficient documentation, we were unable to determine questioned costs. Repeat Finding: No. Recommendation: We recommend management break out expenditures for each award in a way that expenditures can be tracked by program. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.