Federal Agencies: US Department of Treasury and Department of the Interior
Federal Programs: CARES Act (CARES), ARPA, ERA and BIA Compact, respectively
Assistance Listing Numbers: 21.019, 21.027, 21.023 and 15.022, respectively
Award Numbers: None, None, ERA0672, GT-OSGT043-16, respectively
Award Years: 2021 (CARES), 2021 (ARPA), 2021 (ERA) and 2021 (BIA Compact), respectively
Type of Finding: Material weakness in internal control over compliance and material noncompliance.
Criteria: Uniform Guidance requires that the reporting package must be submitted within the earlier of nine months after year end or 30 days after the report issuance in accordance with the provisions of 2 CFR Section 200, subpart F, section 200.512.
Condition and Context: The Council did not adhere to the Uniform Guidance requirement of submitting the reporting package within the earlier of submitting the reporting package within the earlier 30 days after receipt of the audit report or nine months later the audit period.
Cause: Lack of internal control over Uniform Guidance reporting requirements.
Effect: The Council was not in compliance with reporting requirements.
Questioned Costs: None noted.
Repeat Finding: Yes, this is a repeat finding 2020-001. Since it is a repeat finding we believe this to be systematic issue.
Recommendation: We recommend that the Council comply with Uniform Guidance reporting requirements.
Management’s Response: Management agrees with this finding. See Corrective Action Plan
Federal Agencies: US Department of Treasury and Department of the Interior
Federal Programs: CARES Act (CARES), ARPA, ERA and BIA Compact, respectively
Assistance Listing Numbers: 21.019, 21.027, 21.023 and 15.022, respectively
Award Numbers: None, None, ERA0672, GT-OSGT043-16, respectively
Award Years: 2021 (CARES), 2021 (ARPA), 2021 (ERA) and 2021 (BIA Compact), respectively
Type of Finding: Material weakness in internal control over compliance and material noncompliance.
Criteria: Uniform Guidance requires that the reporting package must be submitted within the earlier of nine months after year end or 30 days after the report issuance in accordance with the provisions of 2 CFR Section 200, subpart F, section 200.512.
Condition and Context: The Council did not adhere to the Uniform Guidance requirement of submitting the reporting package within the earlier of submitting the reporting package within the earlier 30 days after receipt of the audit report or nine months later the audit period.
Cause: Lack of internal control over Uniform Guidance reporting requirements.
Effect: The Council was not in compliance with reporting requirements.
Questioned Costs: None noted.
Repeat Finding: Yes, this is a repeat finding 2020-001. Since it is a repeat finding we believe this to be systematic issue.
Recommendation: We recommend that the Council comply with Uniform Guidance reporting requirements.
Management’s Response: Management agrees with this finding. See Corrective Action Plan
Federal Agencies: US Department of Treasury and Department of the Interior
Federal Programs: CARES Act (CARES), ARPA, ERA and BIA Compact, respectively
Assistance Listing Numbers: 21.019, 21.027, 21.023 and 15.022, respectively
Award Numbers: None, None, ERA0672, GT-OSGT043-16, respectively
Award Years: 2021 (CARES), 2021 (ARPA), 2021 (ERA) and 2021 (BIA Compact), respectively
Type of Finding: Material weakness in internal control over compliance and material noncompliance.
Criteria: Uniform Guidance requires that the reporting package must be submitted within the earlier of nine months after year end or 30 days after the report issuance in accordance with the provisions of 2 CFR Section 200, subpart F, section 200.512.
Condition and Context: The Council did not adhere to the Uniform Guidance requirement of submitting the reporting package within the earlier of submitting the reporting package within the earlier 30 days after receipt of the audit report or nine months later the audit period.
Cause: Lack of internal control over Uniform Guidance reporting requirements.
Effect: The Council was not in compliance with reporting requirements.
Questioned Costs: None noted.
Repeat Finding: Yes, this is a repeat finding 2020-001. Since it is a repeat finding we believe this to be systematic issue.
Recommendation: We recommend that the Council comply with Uniform Guidance reporting requirements.
Management’s Response: Management agrees with this finding. See Corrective Action Plan
Federal Agency: US Department of the Interior
Federal Program: BIA Compact
Assistance Listing Number: 15.022
Award Number: GT-OSGT043-16
Award Year: 2021
Type of Finding: Material weakness in internal control over compliance and material noncompliance.
Criteria: Funds received in advance are required to be (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 bank failure.
Condition and Context: During our testing of special tests and provisions, management was unable to provide sufficient documentation to indicate that advance funds were being held in allowable investment securities or within fully insured and/or collateralized bank accounts.
Cause: Lack of internal control over compliance and material noncompliance with the special tests and provisions requirement of the program.
Effect: The lack of internal control over advance funds resulted in material noncompliance with the special tests and provisions requirements of the program.
Questioned Costs: None noted.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the Council adheres to its internal control policies to ensure compliance requirements are met.
Management’s Response: Management concurs with the finding. See Corrective Action Plan.
Federal Agencies: U.S. Department of the Treasury
Federal Programs: Emergency Rental Assistance Program
Assistance Listing Numbers: 21.023
Award Numbers: ERA0672
Award Years: 2021
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: Adequate internal control over reporting should be in place to ensure that quarterly financial reports are reviewed and approved by a member of management prior to submission. Such approval processes should be clearly documented and maintained. These reports should also be in agreement with the underlying accounting system.
Condition and Context: During our testing of quarterly financial reporting, the council was unable to produce sufficient documentation to indicate that quarterly financial reports were reviewed and approved by management prior to submission. Additionally, the two quarterly reports that were reviewed did not agree to the Council’s general ledger.
Cause: Lack of internal control over reporting.
Effect: Lack of internal control over reporting could result in inaccurate and unauthorized reporting of program expenditures.
Questioned Costs: None noted.
Repeat Finding: This is not a repeat finding for the major federal program noted above, therefore, we believe this is not a systemic issue.
Recommendation: We recommend that management strictly adheres to adopted internal control procedures related to grant reporting.
Management’s Response: Management agrees with this finding. See Corrective Action Plan.
Federal Agency: US Department of the Interior
Federal Program: BIA Compact
Assistance Listing Number: 15.022
Award Number: GT-OSGT043-16
Award Year: 2021
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: Adequate internal control over payroll transactions should be in place to ensure that personnel files are complete with all necessary documentation, which includes proof of approved pay rates.
Condition and Context: During our testing of payroll transactions, we noted 10 out of a sample of 25 payroll transactions which lacked necessary documentation to support management’s approval of the employee’s rate of pay.
Cause: Lack of internal control over payroll transactions, specifically related to personnel files.
Effect: The lack of supporting documentation or approval for rates of pay allows for the potential for misstatement of expenditures or for employees to have incorrect rates of pay.
Questioned Costs: None noted.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the Council adheres to its internal control policies to ensure accurate reporting of payroll transactions.
Management’s Response: Management concurs with the finding. See Corrective Action Plan.
Federal Agencies: US Department of Treasury and Department of the Interior
Federal Programs: CARES Act (CARES), ARPA, ERA and BIA Compact, respectively
Assistance Listing Numbers: 21.019, 21.027, 21.023 and 15.022, respectively
Award Numbers: None, None, ERA0672, GT-OSGT043-16, respectively
Award Years: 2021 (CARES), 2021 (ARPA), 2021 (ERA) and 2021 (BIA Compact), respectively
Type of Finding: Material weakness in internal control over compliance and material noncompliance.
Criteria: Uniform Guidance requires that the reporting package must be submitted within the earlier of nine months after year end or 30 days after the report issuance in accordance with the provisions of 2 CFR Section 200, subpart F, section 200.512.
Condition and Context: The Council did not adhere to the Uniform Guidance requirement of submitting the reporting package within the earlier of submitting the reporting package within the earlier 30 days after receipt of the audit report or nine months later the audit period.
Cause: Lack of internal control over Uniform Guidance reporting requirements.
Effect: The Council was not in compliance with reporting requirements.
Questioned Costs: None noted.
Repeat Finding: Yes, this is a repeat finding 2020-001. Since it is a repeat finding we believe this to be systematic issue.
Recommendation: We recommend that the Council comply with Uniform Guidance reporting requirements.
Management’s Response: Management agrees with this finding. See Corrective Action Plan
Federal Agencies: US Department of Treasury and Department of the Interior
Federal Programs: CARES Act (CARES), ARPA, ERA and BIA Compact, respectively
Assistance Listing Numbers: 21.019, 21.027, 21.023 and 15.022, respectively
Award Numbers: None, None, ERA0672, GT-OSGT043-16, respectively
Award Years: 2021 (CARES), 2021 (ARPA), 2021 (ERA) and 2021 (BIA Compact), respectively
Type of Finding: Material weakness in internal control over compliance and material noncompliance.
Criteria: Uniform Guidance requires that the reporting package must be submitted within the earlier of nine months after year end or 30 days after the report issuance in accordance with the provisions of 2 CFR Section 200, subpart F, section 200.512.
Condition and Context: The Council did not adhere to the Uniform Guidance requirement of submitting the reporting package within the earlier of submitting the reporting package within the earlier 30 days after receipt of the audit report or nine months later the audit period.
Cause: Lack of internal control over Uniform Guidance reporting requirements.
Effect: The Council was not in compliance with reporting requirements.
Questioned Costs: None noted.
Repeat Finding: Yes, this is a repeat finding 2020-001. Since it is a repeat finding we believe this to be systematic issue.
Recommendation: We recommend that the Council comply with Uniform Guidance reporting requirements.
Management’s Response: Management agrees with this finding. See Corrective Action Plan
Federal Agencies: US Department of Treasury and Department of the Interior
Federal Programs: CARES Act (CARES), ARPA, ERA and BIA Compact, respectively
Assistance Listing Numbers: 21.019, 21.027, 21.023 and 15.022, respectively
Award Numbers: None, None, ERA0672, GT-OSGT043-16, respectively
Award Years: 2021 (CARES), 2021 (ARPA), 2021 (ERA) and 2021 (BIA Compact), respectively
Type of Finding: Material weakness in internal control over compliance and material noncompliance.
Criteria: Uniform Guidance requires that the reporting package must be submitted within the earlier of nine months after year end or 30 days after the report issuance in accordance with the provisions of 2 CFR Section 200, subpart F, section 200.512.
Condition and Context: The Council did not adhere to the Uniform Guidance requirement of submitting the reporting package within the earlier of submitting the reporting package within the earlier 30 days after receipt of the audit report or nine months later the audit period.
Cause: Lack of internal control over Uniform Guidance reporting requirements.
Effect: The Council was not in compliance with reporting requirements.
Questioned Costs: None noted.
Repeat Finding: Yes, this is a repeat finding 2020-001. Since it is a repeat finding we believe this to be systematic issue.
Recommendation: We recommend that the Council comply with Uniform Guidance reporting requirements.
Management’s Response: Management agrees with this finding. See Corrective Action Plan
Federal Agencies: US Department of Treasury and Department of the Interior
Federal Programs: CARES Act (CARES), ARPA, ERA and BIA Compact, respectively
Assistance Listing Numbers: 21.019, 21.027, 21.023 and 15.022, respectively
Award Numbers: None, None, ERA0672, GT-OSGT043-16, respectively
Award Years: 2021 (CARES), 2021 (ARPA), 2021 (ERA) and 2021 (BIA Compact), respectively
Type of Finding: Material weakness in internal control over compliance and material noncompliance.
Criteria: Uniform Guidance requires that the reporting package must be submitted within the earlier of nine months after year end or 30 days after the report issuance in accordance with the provisions of 2 CFR Section 200, subpart F, section 200.512.
Condition and Context: The Council did not adhere to the Uniform Guidance requirement of submitting the reporting package within the earlier of submitting the reporting package within the earlier 30 days after receipt of the audit report or nine months later the audit period.
Cause: Lack of internal control over Uniform Guidance reporting requirements.
Effect: The Council was not in compliance with reporting requirements.
Questioned Costs: None noted.
Repeat Finding: Yes, this is a repeat finding 2020-001. Since it is a repeat finding we believe this to be systematic issue.
Recommendation: We recommend that the Council comply with Uniform Guidance reporting requirements.
Management’s Response: Management agrees with this finding. See Corrective Action Plan
Federal Agency: US Department of the Interior
Federal Program: BIA Compact
Assistance Listing Number: 15.022
Award Number: GT-OSGT043-16
Award Year: 2021
Type of Finding: Material weakness in internal control over compliance and material noncompliance.
Criteria: Funds received in advance are required to be (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 bank failure.
Condition and Context: During our testing of special tests and provisions, management was unable to provide sufficient documentation to indicate that advance funds were being held in allowable investment securities or within fully insured and/or collateralized bank accounts.
Cause: Lack of internal control over compliance and material noncompliance with the special tests and provisions requirement of the program.
Effect: The lack of internal control over advance funds resulted in material noncompliance with the special tests and provisions requirements of the program.
Questioned Costs: None noted.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the Council adheres to its internal control policies to ensure compliance requirements are met.
Management’s Response: Management concurs with the finding. See Corrective Action Plan.
Federal Agencies: U.S. Department of the Treasury
Federal Programs: Emergency Rental Assistance Program
Assistance Listing Numbers: 21.023
Award Numbers: ERA0672
Award Years: 2021
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: Adequate internal control over reporting should be in place to ensure that quarterly financial reports are reviewed and approved by a member of management prior to submission. Such approval processes should be clearly documented and maintained. These reports should also be in agreement with the underlying accounting system.
Condition and Context: During our testing of quarterly financial reporting, the council was unable to produce sufficient documentation to indicate that quarterly financial reports were reviewed and approved by management prior to submission. Additionally, the two quarterly reports that were reviewed did not agree to the Council’s general ledger.
Cause: Lack of internal control over reporting.
Effect: Lack of internal control over reporting could result in inaccurate and unauthorized reporting of program expenditures.
Questioned Costs: None noted.
Repeat Finding: This is not a repeat finding for the major federal program noted above, therefore, we believe this is not a systemic issue.
Recommendation: We recommend that management strictly adheres to adopted internal control procedures related to grant reporting.
Management’s Response: Management agrees with this finding. See Corrective Action Plan.
Federal Agency: US Department of the Interior
Federal Program: BIA Compact
Assistance Listing Number: 15.022
Award Number: GT-OSGT043-16
Award Year: 2021
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: Adequate internal control over payroll transactions should be in place to ensure that personnel files are complete with all necessary documentation, which includes proof of approved pay rates.
Condition and Context: During our testing of payroll transactions, we noted 10 out of a sample of 25 payroll transactions which lacked necessary documentation to support management’s approval of the employee’s rate of pay.
Cause: Lack of internal control over payroll transactions, specifically related to personnel files.
Effect: The lack of supporting documentation or approval for rates of pay allows for the potential for misstatement of expenditures or for employees to have incorrect rates of pay.
Questioned Costs: None noted.
Repeat Finding: This is not a repeat finding.
Recommendation: We recommend the Council adheres to its internal control policies to ensure accurate reporting of payroll transactions.
Management’s Response: Management concurs with the finding. See Corrective Action Plan.
Federal Agencies: US Department of Treasury and Department of the Interior
Federal Programs: CARES Act (CARES), ARPA, ERA and BIA Compact, respectively
Assistance Listing Numbers: 21.019, 21.027, 21.023 and 15.022, respectively
Award Numbers: None, None, ERA0672, GT-OSGT043-16, respectively
Award Years: 2021 (CARES), 2021 (ARPA), 2021 (ERA) and 2021 (BIA Compact), respectively
Type of Finding: Material weakness in internal control over compliance and material noncompliance.
Criteria: Uniform Guidance requires that the reporting package must be submitted within the earlier of nine months after year end or 30 days after the report issuance in accordance with the provisions of 2 CFR Section 200, subpart F, section 200.512.
Condition and Context: The Council did not adhere to the Uniform Guidance requirement of submitting the reporting package within the earlier of submitting the reporting package within the earlier 30 days after receipt of the audit report or nine months later the audit period.
Cause: Lack of internal control over Uniform Guidance reporting requirements.
Effect: The Council was not in compliance with reporting requirements.
Questioned Costs: None noted.
Repeat Finding: Yes, this is a repeat finding 2020-001. Since it is a repeat finding we believe this to be systematic issue.
Recommendation: We recommend that the Council comply with Uniform Guidance reporting requirements.
Management’s Response: Management agrees with this finding. See Corrective Action Plan