Audit 302897

Finding 2023-003 Material Weakness in Internal Control over Compliance – Eligibility Identification of federal program: 84.299 Indian Education - Special Programs for Indian Children Criteria or specific requirement: The Grant Award Notification states that the grantee must provide services to Indian students meeting the definition of Indian in section 6151 of ESEA. Condition: To ensure that Chugachmiut provides services only to eligible individuals Chugachmiut developed an internal policy in which the Program Manager reviews the participant's application, tribal affiliation, and personal statement of need prior to services being offered to the applicant. We noted that evidence of this review occurring was not retained by Chugachmiut Cause: Chugachmiut did not have controls in place to ensure that all documentation to support participant eligibility was retained. Effect or potential effect: Chugachmiut has a risk of potentially including ineligible participants in the program without sufficient documented oversight of participant applications. Questioned Costs: None Context: It was specifically noted that all participants who participated in the program were found to be eligible for program services. However, it was not evident that the control process established in Chugachmiut’s policies and procedures was operating and there does not appear to be a retention process for key eligibility documentation for the applicants and participants in the program. Identification of Repeat Finding: Not applicable. Recommendations: Management should implement a process to ensure that review of participant applications, participant interviews, and application documents are tracked and retained by Chugachmiut. Views of Responsible Officials: See Corrective Action Plan

Finding 2023-002 Significant Deficiency in Internal Control over Compliance and Noncompliance – Procurement, Suspension, and Debarment Standards. Identification of federal program: 84.356 Alaska Native Educational Program. Criteria or specific requirement: § 200.318(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 200.317 through 200.327. § 200.318(i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: It was noted that Chugachmiut has documented procurement policies consistent with the Uniform Guidance, however Chugachmiut did not maintain evidence that they followed their own documented procurement policy for procurements greater than the micro-purchase threshold. Cause: Chugachmiut does not have an administrative review process to ensure that the procurement documentation supporting purchases greater than the micropurchase threshold are maintained in accordance with Chugachmiut’s procurement policies. Effect or potential effect: Chugachmiut is out of compliance with Uniform Guidance procurement standards. Questioned Costs: None Context: For this program, it was noted during the auditor’s review of certain contracts exceeding the micro-purchase threshold that procurement was not followed for a purchase charged to this federal program. It was noted that the contract was documented as a sole source contract; however it was not evident that the contract met the criteria to be appropriately considered as such. Management has since performed an internal review of their procurement policies and has made certain changes in roles and responsibilities to ensure that procurement standards are appropriately followed. Identification of Repeat Finding: Not applicable. Recommendations: We recommend that as a part of Chugachmiut’s internal control structure over compliance with Uniform Guidance, that Chugachmiut prepare a checklist, reflective of Chugachmiut’s approved procurement policies, to be completed before procurements can be awarded and all documents supporting that checklist be filed together. Views of Responsible Officials: See Corrective Action Plan

Finding 2023-003 Material Weakness in Internal Control over Compliance – Eligibility Identification of federal program: 84.299 Indian Education - Special Programs for Indian Children Criteria or specific requirement: The Grant Award Notification states that the grantee must provide services to Indian students meeting the definition of Indian in section 6151 of ESEA. Condition: To ensure that Chugachmiut provides services only to eligible individuals Chugachmiut developed an internal policy in which the Program Manager reviews the participant's application, tribal affiliation, and personal statement of need prior to services being offered to the applicant. We noted that evidence of this review occurring was not retained by Chugachmiut Cause: Chugachmiut did not have controls in place to ensure that all documentation to support participant eligibility was retained. Effect or potential effect: Chugachmiut has a risk of potentially including ineligible participants in the program without sufficient documented oversight of participant applications. Questioned Costs: None Context: It was specifically noted that all participants who participated in the program were found to be eligible for program services. However, it was not evident that the control process established in Chugachmiut’s policies and procedures was operating and there does not appear to be a retention process for key eligibility documentation for the applicants and participants in the program. Identification of Repeat Finding: Not applicable. Recommendations: Management should implement a process to ensure that review of participant applications, participant interviews, and application documents are tracked and retained by Chugachmiut. Views of Responsible Officials: See Corrective Action Plan

Finding 2023-002 Significant Deficiency in Internal Control over Compliance and Noncompliance – Procurement, Suspension, and Debarment Standards. Identification of federal program: 84.356 Alaska Native Educational Program. Criteria or specific requirement: § 200.318(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity’s documented procurement procedures must conform to the procurement standards identified in 200.317 through 200.327. § 200.318(i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Condition: It was noted that Chugachmiut has documented procurement policies consistent with the Uniform Guidance, however Chugachmiut did not maintain evidence that they followed their own documented procurement policy for procurements greater than the micro-purchase threshold. Cause: Chugachmiut does not have an administrative review process to ensure that the procurement documentation supporting purchases greater than the micropurchase threshold are maintained in accordance with Chugachmiut’s procurement policies. Effect or potential effect: Chugachmiut is out of compliance with Uniform Guidance procurement standards. Questioned Costs: None Context: For this program, it was noted during the auditor’s review of certain contracts exceeding the micro-purchase threshold that procurement was not followed for a purchase charged to this federal program. It was noted that the contract was documented as a sole source contract; however it was not evident that the contract met the criteria to be appropriately considered as such. Management has since performed an internal review of their procurement policies and has made certain changes in roles and responsibilities to ensure that procurement standards are appropriately followed. Identification of Repeat Finding: Not applicable. Recommendations: We recommend that as a part of Chugachmiut’s internal control structure over compliance with Uniform Guidance, that Chugachmiut prepare a checklist, reflective of Chugachmiut’s approved procurement policies, to be completed before procurements can be awarded and all documents supporting that checklist be filed together. Views of Responsible Officials: See Corrective Action Plan