Audit 299210

2021-004 — Late Audit Report Federal program information: Funding agency: All Title: All ALN: All Award period: Various Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (June 30, 2022). Condition: CBNHC’s fiscal year 2021 single audit reporting package was not submitted by the due date of June 30, 2022. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: CBNHC was unable to completely reconcile certain general ledger accounts timely, which resulted in significant audit adjustments. As a result, the audit started late and was not issued within the reporting deadline. Auditor’s Recommendations: The Accounting department should be analyzed, and functions/duties re-assigned and/or additional personnel hired to ensure that monthly and annual account reconciliations are performed timely to ensure that the data collection form and reporting package are submitted by the due date. Management’s Response: As documented in response to finding 2021-001, a timeline was produced to demonstrate that CBNHC was extremely short-staffed, which caused it to fall behind in its accounting functions. CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. The reconciliation of the general ledger and closing of the financials fell behind. CBNHC subsequently relied on an accounting consultant to assist in reconciling its books and preparing its financial statements. However, there were limitations in CBNHC’s ability to reconcile its specialized medical insurance billings and PRC program expenditures due to lack of knowledge of the health care management system, namely the Resource Patient Management System (RPMS). CBNHC has since hired RPMS experienced personnel and is current in managing the monthly close of the patient financial system. CBNHC will continue with a late audit report finding for fiscal year 2022, with the goal of being on track for its fiscal year 2023 reporting.

2021-004 — Late Audit Report Federal program information: Funding agency: All Title: All ALN: All Award period: Various Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (June 30, 2022). Condition: CBNHC’s fiscal year 2021 single audit reporting package was not submitted by the due date of June 30, 2022. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: CBNHC was unable to completely reconcile certain general ledger accounts timely, which resulted in significant audit adjustments. As a result, the audit started late and was not issued within the reporting deadline. Auditor’s Recommendations: The Accounting department should be analyzed, and functions/duties re-assigned and/or additional personnel hired to ensure that monthly and annual account reconciliations are performed timely to ensure that the data collection form and reporting package are submitted by the due date. Management’s Response: As documented in response to finding 2021-001, a timeline was produced to demonstrate that CBNHC was extremely short-staffed, which caused it to fall behind in its accounting functions. CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. The reconciliation of the general ledger and closing of the financials fell behind. CBNHC subsequently relied on an accounting consultant to assist in reconciling its books and preparing its financial statements. However, there were limitations in CBNHC’s ability to reconcile its specialized medical insurance billings and PRC program expenditures due to lack of knowledge of the health care management system, namely the Resource Patient Management System (RPMS). CBNHC has since hired RPMS experienced personnel and is current in managing the monthly close of the patient financial system. CBNHC will continue with a late audit report finding for fiscal year 2022, with the goal of being on track for its fiscal year 2023 reporting.

2021-004 — Late Audit Report Federal program information: Funding agency: All Title: All ALN: All Award period: Various Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (June 30, 2022). Condition: CBNHC’s fiscal year 2021 single audit reporting package was not submitted by the due date of June 30, 2022. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: CBNHC was unable to completely reconcile certain general ledger accounts timely, which resulted in significant audit adjustments. As a result, the audit started late and was not issued within the reporting deadline. Auditor’s Recommendations: The Accounting department should be analyzed, and functions/duties re-assigned and/or additional personnel hired to ensure that monthly and annual account reconciliations are performed timely to ensure that the data collection form and reporting package are submitted by the due date. Management’s Response: As documented in response to finding 2021-001, a timeline was produced to demonstrate that CBNHC was extremely short-staffed, which caused it to fall behind in its accounting functions. CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. The reconciliation of the general ledger and closing of the financials fell behind. CBNHC subsequently relied on an accounting consultant to assist in reconciling its books and preparing its financial statements. However, there were limitations in CBNHC’s ability to reconcile its specialized medical insurance billings and PRC program expenditures due to lack of knowledge of the health care management system, namely the Resource Patient Management System (RPMS). CBNHC has since hired RPMS experienced personnel and is current in managing the monthly close of the patient financial system. CBNHC will continue with a late audit report finding for fiscal year 2022, with the goal of being on track for its fiscal year 2023 reporting.

2021-004 — Late Audit Report Federal program information: Funding agency: All Title: All ALN: All Award period: Various Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (June 30, 2022). Condition: CBNHC’s fiscal year 2021 single audit reporting package was not submitted by the due date of June 30, 2022. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: CBNHC was unable to completely reconcile certain general ledger accounts timely, which resulted in significant audit adjustments. As a result, the audit started late and was not issued within the reporting deadline. Auditor’s Recommendations: The Accounting department should be analyzed, and functions/duties re-assigned and/or additional personnel hired to ensure that monthly and annual account reconciliations are performed timely to ensure that the data collection form and reporting package are submitted by the due date. Management’s Response: As documented in response to finding 2021-001, a timeline was produced to demonstrate that CBNHC was extremely short-staffed, which caused it to fall behind in its accounting functions. CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. The reconciliation of the general ledger and closing of the financials fell behind. CBNHC subsequently relied on an accounting consultant to assist in reconciling its books and preparing its financial statements. However, there were limitations in CBNHC’s ability to reconcile its specialized medical insurance billings and PRC program expenditures due to lack of knowledge of the health care management system, namely the Resource Patient Management System (RPMS). CBNHC has since hired RPMS experienced personnel and is current in managing the monthly close of the patient financial system. CBNHC will continue with a late audit report finding for fiscal year 2022, with the goal of being on track for its fiscal year 2023 reporting.

2021-005 — Reporting Federal/state program information: Funding agency: U.S. Department of Health and Human Services Title: Indian Self-Determination ALN: 93.441 Award period: 10/1/2020 – 9/30/2021 Criteria: The Annual Funding Agreement (AFA) with I.H.S. requires CBNHC to submit Federal Financial Reports (SF-425) within 30 days after the close of each quarter, except for the fourth quarter, which will be submitted within 90 days after the close of the federal fiscal year. Additionally, a brief annual narrative report will also be submitted within 90 days after the close of the federal fiscal year. Condition: The quarterly SF-425 reports for all quarters of fiscal year 2021 were not prepared or submitted to I.H.S. Additionally, the annual narrative report was not prepared or submitted for fiscal year 2021. Context: All four quarterly SF-425 reports and the annual narrative report for the Indian Self-Determination program. Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which impacted the preparation and submission of required reports. Effect: CBNHC is not in compliance with reporting requirements for the Indian Self-Determination program. Auditor’s Recommendations: CBNHC should develop internal controls to ensure all program reports are properly completed and submitted by the required due dates. Management’s Response: CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. In addition to staff shortages, CBNHC’s priority was on emergency response to the To’Hajiilee community. These events caused CBNHC to fall behind in maintaining its financials and other administrative tasks. The SF-425 and narrative reporting as required under the I.H.S. Annual Funding Agreement were not submitted. CBNHC takes seriously its contractual obligations and is actively working toward compliance in its reporting requirements.

2021-006 — Special Tests and Provisions – Background Checks Federal/state program information: Funding agency: U.S. Department of Health and Human Services Title: Indian Self-Determination ALN: 93.441 Award period: 10/1/2020 – 9/30/2021 Criteria: The AFA with I.H.S. requires CBNHC to conduct fingerprinting and background checks of employees, contractors, and patient care providers as required by applicable law (including 25 U.S.C. Section 3207 and 1647 (a)(b) and 42 C.F.R. Sections 136.401 to 136.418) and in accordance with the policies and procedures of CBNHC. Condition: CBNHC did not maintain records of the start/hire date, fingerprint charts, completed background check, and the suitability determination/adjudication for one employee. For one other employee, the suitability determination/adjudication was not completed until almost five years after their hire date (although the background check was completed within three months of their hire date). Context: Two of six employees tested for the Indian Self-Determination program. Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused turnover in the Human Resources department at CBNHC. Effect: CBNHC is not in compliance with background check requirements for the Indian Self-Determination program. Auditor’s Recommendations: CBNHC should implement its policies and procedures regarding background checks to ensure that all employees and contractors are subject to fingerprinting and background checks. Management’s Response: CBNHC experienced substantial staffing shortages and struggled with the impacts of the COVID-19 pandemic throughout fiscal year 2021. During this time, CBNHC continued with its recruiting of staff to carry out the human resource duties and responsibilities required for regulatory compliance; however, continued management vacancies and COVID-19 severely impacted its ability to obtain necessary human resources and other key staff. The Controller continued in the role of Acting CEO for the first half of fiscal year 2021 and formally assumed the CEO position as of March 18, 2021. The Acting CEO remained responsible for operations of the organization, the Finance Department, and Human Resources during this time. The Human Resources Director position was vacant throughout most of fiscal year 2021 and was finally filled in August 2021. The recruiting challenges and continued effects of the pandemic left CBNHC leadership severely short-staffed, causing significant delays in processing required background checks. The status of the approved Human Resources and associated administrative positions and their status at the close of fiscal year 2021 is summarized as follows: • Chief Executive Officer (Position Status: Vacant from June 11, 2020 – March 18, 2021) – Responsible for providing administrative oversight for all aspects of the efficient operations of CNBHC and serves as the administrative authority for the organization and its health programs. Interim CEO duties were assigned to the Controller, who formally accepted the position in March 2021. • Controller (Position Status: Vacant from March 18, 2021 – September 30, 2021) – Responsible for management, oversight, and administration of the CBNHC accounting, finance, payroll and tax functions, advises executive leadership on financial management and strategic planning; develops, modifies and enforces financial accounting safeguards. The Acting CEO was serving as Acting Controller. The Controller was appointed Acting CEO in February 2020 and formally accepted the position in March 2021. • Human Resource Director (Position Status: Vacant from October 1, 2020 – August 30, 2021) – Guides and manages the overall provision of Human Resources services, policies, and benefit programs for CBNHC. The Human Resources Director will assist in confirming payroll set-up, including rates and deductions, and will participate in reviewing benefit invoices to ensure accuracy. As noted above, the Human Resources Director (previously Manager) was vacant for most of fiscal year 2021, with the Controller maintaining responsibilities of the CEO, Controller, and Human Resources Director. Additionally, vendors that process and finalize CBNHC background checks experienced severe backlogs due to delays across the nation’s court systems in the aftermath of the pandemic and associated shutdowns. These delays contributed to further delays in CBNHC receiving adjudication and background results.

2021-007 — Equipment and Real Property Management Federal/state program information: Funding agency: U.S. Department of Health and Human Services Title: Indian Self-Determination ALN: 93.441 Award period: 10/1/2020 – 9/30/2021 Criteria: 2 CFR section 200.313 requires that (1) equipment be used in the program or project for which it was acquired as long as needed, (2) property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, and cost of the property, and (3) a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Additionally, CBNHC’s Financial Policies and Procedures require a physical inventory of property be taken annually and reconciled to the general ledger. Condition: CBNHC has not completed a physical inventory of property and equipment in the last two years. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic. Additionally, CBNHC is not implementing their Financial Policies and Procedures to ensure that a physical inventory has been taken annually and reconciled to the general ledger. Effect: CBNHC is not in compliance with equipment and real property management requirements for the Indian Self-Determination program. Auditor’s Recommendations: CBNHC should implement its Financial Policies and Procedures and plan a physical inventory of its property as quickly as possible. The results of the physical inventory should be reconciled to the general ledger. Management’s Response: CBNHC did not have the adequate financial or administrative staff to perform a physical inventory and therefore has not been keeping with its Financial Policies and Procedures and performing an annual physical inventory.

2021-004 — Late Audit Report Federal program information: Funding agency: All Title: All ALN: All Award period: Various Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (June 30, 2022). Condition: CBNHC’s fiscal year 2021 single audit reporting package was not submitted by the due date of June 30, 2022. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: CBNHC was unable to completely reconcile certain general ledger accounts timely, which resulted in significant audit adjustments. As a result, the audit started late and was not issued within the reporting deadline. Auditor’s Recommendations: The Accounting department should be analyzed, and functions/duties re-assigned and/or additional personnel hired to ensure that monthly and annual account reconciliations are performed timely to ensure that the data collection form and reporting package are submitted by the due date. Management’s Response: As documented in response to finding 2021-001, a timeline was produced to demonstrate that CBNHC was extremely short-staffed, which caused it to fall behind in its accounting functions. CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. The reconciliation of the general ledger and closing of the financials fell behind. CBNHC subsequently relied on an accounting consultant to assist in reconciling its books and preparing its financial statements. However, there were limitations in CBNHC’s ability to reconcile its specialized medical insurance billings and PRC program expenditures due to lack of knowledge of the health care management system, namely the Resource Patient Management System (RPMS). CBNHC has since hired RPMS experienced personnel and is current in managing the monthly close of the patient financial system. CBNHC will continue with a late audit report finding for fiscal year 2022, with the goal of being on track for its fiscal year 2023 reporting.

2021-004 — Late Audit Report Federal program information: Funding agency: All Title: All ALN: All Award period: Various Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (June 30, 2022). Condition: CBNHC’s fiscal year 2021 single audit reporting package was not submitted by the due date of June 30, 2022. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: CBNHC was unable to completely reconcile certain general ledger accounts timely, which resulted in significant audit adjustments. As a result, the audit started late and was not issued within the reporting deadline. Auditor’s Recommendations: The Accounting department should be analyzed, and functions/duties re-assigned and/or additional personnel hired to ensure that monthly and annual account reconciliations are performed timely to ensure that the data collection form and reporting package are submitted by the due date. Management’s Response: As documented in response to finding 2021-001, a timeline was produced to demonstrate that CBNHC was extremely short-staffed, which caused it to fall behind in its accounting functions. CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. The reconciliation of the general ledger and closing of the financials fell behind. CBNHC subsequently relied on an accounting consultant to assist in reconciling its books and preparing its financial statements. However, there were limitations in CBNHC’s ability to reconcile its specialized medical insurance billings and PRC program expenditures due to lack of knowledge of the health care management system, namely the Resource Patient Management System (RPMS). CBNHC has since hired RPMS experienced personnel and is current in managing the monthly close of the patient financial system. CBNHC will continue with a late audit report finding for fiscal year 2022, with the goal of being on track for its fiscal year 2023 reporting.

2021-004 — Late Audit Report Federal program information: Funding agency: All Title: All ALN: All Award period: Various Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (June 30, 2022). Condition: CBNHC’s fiscal year 2021 single audit reporting package was not submitted by the due date of June 30, 2022. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: CBNHC was unable to completely reconcile certain general ledger accounts timely, which resulted in significant audit adjustments. As a result, the audit started late and was not issued within the reporting deadline. Auditor’s Recommendations: The Accounting department should be analyzed, and functions/duties re-assigned and/or additional personnel hired to ensure that monthly and annual account reconciliations are performed timely to ensure that the data collection form and reporting package are submitted by the due date. Management’s Response: As documented in response to finding 2021-001, a timeline was produced to demonstrate that CBNHC was extremely short-staffed, which caused it to fall behind in its accounting functions. CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. The reconciliation of the general ledger and closing of the financials fell behind. CBNHC subsequently relied on an accounting consultant to assist in reconciling its books and preparing its financial statements. However, there were limitations in CBNHC’s ability to reconcile its specialized medical insurance billings and PRC program expenditures due to lack of knowledge of the health care management system, namely the Resource Patient Management System (RPMS). CBNHC has since hired RPMS experienced personnel and is current in managing the monthly close of the patient financial system. CBNHC will continue with a late audit report finding for fiscal year 2022, with the goal of being on track for its fiscal year 2023 reporting.

2021-004 — Late Audit Report Federal program information: Funding agency: All Title: All ALN: All Award period: Various Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (June 30, 2022). Condition: CBNHC’s fiscal year 2021 single audit reporting package was not submitted by the due date of June 30, 2022. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: CBNHC was unable to completely reconcile certain general ledger accounts timely, which resulted in significant audit adjustments. As a result, the audit started late and was not issued within the reporting deadline. Auditor’s Recommendations: The Accounting department should be analyzed, and functions/duties re-assigned and/or additional personnel hired to ensure that monthly and annual account reconciliations are performed timely to ensure that the data collection form and reporting package are submitted by the due date. Management’s Response: As documented in response to finding 2021-001, a timeline was produced to demonstrate that CBNHC was extremely short-staffed, which caused it to fall behind in its accounting functions. CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. The reconciliation of the general ledger and closing of the financials fell behind. CBNHC subsequently relied on an accounting consultant to assist in reconciling its books and preparing its financial statements. However, there were limitations in CBNHC’s ability to reconcile its specialized medical insurance billings and PRC program expenditures due to lack of knowledge of the health care management system, namely the Resource Patient Management System (RPMS). CBNHC has since hired RPMS experienced personnel and is current in managing the monthly close of the patient financial system. CBNHC will continue with a late audit report finding for fiscal year 2022, with the goal of being on track for its fiscal year 2023 reporting.

2021-004 — Late Audit Report Federal program information: Funding agency: All Title: All ALN: All Award period: Various Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (June 30, 2022). Condition: CBNHC’s fiscal year 2021 single audit reporting package was not submitted by the due date of June 30, 2022. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: CBNHC was unable to completely reconcile certain general ledger accounts timely, which resulted in significant audit adjustments. As a result, the audit started late and was not issued within the reporting deadline. Auditor’s Recommendations: The Accounting department should be analyzed, and functions/duties re-assigned and/or additional personnel hired to ensure that monthly and annual account reconciliations are performed timely to ensure that the data collection form and reporting package are submitted by the due date. Management’s Response: As documented in response to finding 2021-001, a timeline was produced to demonstrate that CBNHC was extremely short-staffed, which caused it to fall behind in its accounting functions. CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. The reconciliation of the general ledger and closing of the financials fell behind. CBNHC subsequently relied on an accounting consultant to assist in reconciling its books and preparing its financial statements. However, there were limitations in CBNHC’s ability to reconcile its specialized medical insurance billings and PRC program expenditures due to lack of knowledge of the health care management system, namely the Resource Patient Management System (RPMS). CBNHC has since hired RPMS experienced personnel and is current in managing the monthly close of the patient financial system. CBNHC will continue with a late audit report finding for fiscal year 2022, with the goal of being on track for its fiscal year 2023 reporting.

2021-004 — Late Audit Report Federal program information: Funding agency: All Title: All ALN: All Award period: Various Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (June 30, 2022). Condition: CBNHC’s fiscal year 2021 single audit reporting package was not submitted by the due date of June 30, 2022. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: CBNHC was unable to completely reconcile certain general ledger accounts timely, which resulted in significant audit adjustments. As a result, the audit started late and was not issued within the reporting deadline. Auditor’s Recommendations: The Accounting department should be analyzed, and functions/duties re-assigned and/or additional personnel hired to ensure that monthly and annual account reconciliations are performed timely to ensure that the data collection form and reporting package are submitted by the due date. Management’s Response: As documented in response to finding 2021-001, a timeline was produced to demonstrate that CBNHC was extremely short-staffed, which caused it to fall behind in its accounting functions. CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. The reconciliation of the general ledger and closing of the financials fell behind. CBNHC subsequently relied on an accounting consultant to assist in reconciling its books and preparing its financial statements. However, there were limitations in CBNHC’s ability to reconcile its specialized medical insurance billings and PRC program expenditures due to lack of knowledge of the health care management system, namely the Resource Patient Management System (RPMS). CBNHC has since hired RPMS experienced personnel and is current in managing the monthly close of the patient financial system. CBNHC will continue with a late audit report finding for fiscal year 2022, with the goal of being on track for its fiscal year 2023 reporting.

2021-005 — Reporting Federal/state program information: Funding agency: U.S. Department of Health and Human Services Title: Indian Self-Determination ALN: 93.441 Award period: 10/1/2020 – 9/30/2021 Criteria: The Annual Funding Agreement (AFA) with I.H.S. requires CBNHC to submit Federal Financial Reports (SF-425) within 30 days after the close of each quarter, except for the fourth quarter, which will be submitted within 90 days after the close of the federal fiscal year. Additionally, a brief annual narrative report will also be submitted within 90 days after the close of the federal fiscal year. Condition: The quarterly SF-425 reports for all quarters of fiscal year 2021 were not prepared or submitted to I.H.S. Additionally, the annual narrative report was not prepared or submitted for fiscal year 2021. Context: All four quarterly SF-425 reports and the annual narrative report for the Indian Self-Determination program. Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which impacted the preparation and submission of required reports. Effect: CBNHC is not in compliance with reporting requirements for the Indian Self-Determination program. Auditor’s Recommendations: CBNHC should develop internal controls to ensure all program reports are properly completed and submitted by the required due dates. Management’s Response: CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. In addition to staff shortages, CBNHC’s priority was on emergency response to the To’Hajiilee community. These events caused CBNHC to fall behind in maintaining its financials and other administrative tasks. The SF-425 and narrative reporting as required under the I.H.S. Annual Funding Agreement were not submitted. CBNHC takes seriously its contractual obligations and is actively working toward compliance in its reporting requirements.

2021-006 — Special Tests and Provisions – Background Checks Federal/state program information: Funding agency: U.S. Department of Health and Human Services Title: Indian Self-Determination ALN: 93.441 Award period: 10/1/2020 – 9/30/2021 Criteria: The AFA with I.H.S. requires CBNHC to conduct fingerprinting and background checks of employees, contractors, and patient care providers as required by applicable law (including 25 U.S.C. Section 3207 and 1647 (a)(b) and 42 C.F.R. Sections 136.401 to 136.418) and in accordance with the policies and procedures of CBNHC. Condition: CBNHC did not maintain records of the start/hire date, fingerprint charts, completed background check, and the suitability determination/adjudication for one employee. For one other employee, the suitability determination/adjudication was not completed until almost five years after their hire date (although the background check was completed within three months of their hire date). Context: Two of six employees tested for the Indian Self-Determination program. Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused turnover in the Human Resources department at CBNHC. Effect: CBNHC is not in compliance with background check requirements for the Indian Self-Determination program. Auditor’s Recommendations: CBNHC should implement its policies and procedures regarding background checks to ensure that all employees and contractors are subject to fingerprinting and background checks. Management’s Response: CBNHC experienced substantial staffing shortages and struggled with the impacts of the COVID-19 pandemic throughout fiscal year 2021. During this time, CBNHC continued with its recruiting of staff to carry out the human resource duties and responsibilities required for regulatory compliance; however, continued management vacancies and COVID-19 severely impacted its ability to obtain necessary human resources and other key staff. The Controller continued in the role of Acting CEO for the first half of fiscal year 2021 and formally assumed the CEO position as of March 18, 2021. The Acting CEO remained responsible for operations of the organization, the Finance Department, and Human Resources during this time. The Human Resources Director position was vacant throughout most of fiscal year 2021 and was finally filled in August 2021. The recruiting challenges and continued effects of the pandemic left CBNHC leadership severely short-staffed, causing significant delays in processing required background checks. The status of the approved Human Resources and associated administrative positions and their status at the close of fiscal year 2021 is summarized as follows: • Chief Executive Officer (Position Status: Vacant from June 11, 2020 – March 18, 2021) – Responsible for providing administrative oversight for all aspects of the efficient operations of CNBHC and serves as the administrative authority for the organization and its health programs. Interim CEO duties were assigned to the Controller, who formally accepted the position in March 2021. • Controller (Position Status: Vacant from March 18, 2021 – September 30, 2021) – Responsible for management, oversight, and administration of the CBNHC accounting, finance, payroll and tax functions, advises executive leadership on financial management and strategic planning; develops, modifies and enforces financial accounting safeguards. The Acting CEO was serving as Acting Controller. The Controller was appointed Acting CEO in February 2020 and formally accepted the position in March 2021. • Human Resource Director (Position Status: Vacant from October 1, 2020 – August 30, 2021) – Guides and manages the overall provision of Human Resources services, policies, and benefit programs for CBNHC. The Human Resources Director will assist in confirming payroll set-up, including rates and deductions, and will participate in reviewing benefit invoices to ensure accuracy. As noted above, the Human Resources Director (previously Manager) was vacant for most of fiscal year 2021, with the Controller maintaining responsibilities of the CEO, Controller, and Human Resources Director. Additionally, vendors that process and finalize CBNHC background checks experienced severe backlogs due to delays across the nation’s court systems in the aftermath of the pandemic and associated shutdowns. These delays contributed to further delays in CBNHC receiving adjudication and background results.

2021-007 — Equipment and Real Property Management Federal/state program information: Funding agency: U.S. Department of Health and Human Services Title: Indian Self-Determination ALN: 93.441 Award period: 10/1/2020 – 9/30/2021 Criteria: 2 CFR section 200.313 requires that (1) equipment be used in the program or project for which it was acquired as long as needed, (2) property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the federal award identification number), who holds title, the acquisition date, and cost of the property, and (3) a physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. Additionally, CBNHC’s Financial Policies and Procedures require a physical inventory of property be taken annually and reconciled to the general ledger. Condition: CBNHC has not completed a physical inventory of property and equipment in the last two years. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic. Additionally, CBNHC is not implementing their Financial Policies and Procedures to ensure that a physical inventory has been taken annually and reconciled to the general ledger. Effect: CBNHC is not in compliance with equipment and real property management requirements for the Indian Self-Determination program. Auditor’s Recommendations: CBNHC should implement its Financial Policies and Procedures and plan a physical inventory of its property as quickly as possible. The results of the physical inventory should be reconciled to the general ledger. Management’s Response: CBNHC did not have the adequate financial or administrative staff to perform a physical inventory and therefore has not been keeping with its Financial Policies and Procedures and performing an annual physical inventory.

2021-004 — Late Audit Report Federal program information: Funding agency: All Title: All ALN: All Award period: Various Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (June 30, 2022). Condition: CBNHC’s fiscal year 2021 single audit reporting package was not submitted by the due date of June 30, 2022. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: CBNHC was unable to completely reconcile certain general ledger accounts timely, which resulted in significant audit adjustments. As a result, the audit started late and was not issued within the reporting deadline. Auditor’s Recommendations: The Accounting department should be analyzed, and functions/duties re-assigned and/or additional personnel hired to ensure that monthly and annual account reconciliations are performed timely to ensure that the data collection form and reporting package are submitted by the due date. Management’s Response: As documented in response to finding 2021-001, a timeline was produced to demonstrate that CBNHC was extremely short-staffed, which caused it to fall behind in its accounting functions. CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. The reconciliation of the general ledger and closing of the financials fell behind. CBNHC subsequently relied on an accounting consultant to assist in reconciling its books and preparing its financial statements. However, there were limitations in CBNHC’s ability to reconcile its specialized medical insurance billings and PRC program expenditures due to lack of knowledge of the health care management system, namely the Resource Patient Management System (RPMS). CBNHC has since hired RPMS experienced personnel and is current in managing the monthly close of the patient financial system. CBNHC will continue with a late audit report finding for fiscal year 2022, with the goal of being on track for its fiscal year 2023 reporting.

2021-004 — Late Audit Report Federal program information: Funding agency: All Title: All ALN: All Award period: Various Criteria: According to 2 CFR Part 200.512, the annual single audit must be completed and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period (June 30, 2022). Condition: CBNHC’s fiscal year 2021 single audit reporting package was not submitted by the due date of June 30, 2022. Context: N/A Questioned Costs: None Cause: CBNHC was significantly impacted by the COVID-19 pandemic, which caused significant delays in completion of the year-end reconciliations of the financial statements and the schedule of expenditures of federal awards. Effect: CBNHC was unable to completely reconcile certain general ledger accounts timely, which resulted in significant audit adjustments. As a result, the audit started late and was not issued within the reporting deadline. Auditor’s Recommendations: The Accounting department should be analyzed, and functions/duties re-assigned and/or additional personnel hired to ensure that monthly and annual account reconciliations are performed timely to ensure that the data collection form and reporting package are submitted by the due date. Management’s Response: As documented in response to finding 2021-001, a timeline was produced to demonstrate that CBNHC was extremely short-staffed, which caused it to fall behind in its accounting functions. CBNHC continued to experience operational disruptions caused by turnover of key administrative positions and the COVID-19 pandemic. The reconciliation of the general ledger and closing of the financials fell behind. CBNHC subsequently relied on an accounting consultant to assist in reconciling its books and preparing its financial statements. However, there were limitations in CBNHC’s ability to reconcile its specialized medical insurance billings and PRC program expenditures due to lack of knowledge of the health care management system, namely the Resource Patient Management System (RPMS). CBNHC has since hired RPMS experienced personnel and is current in managing the monthly close of the patient financial system. CBNHC will continue with a late audit report finding for fiscal year 2022, with the goal of being on track for its fiscal year 2023 reporting.