Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.
Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.
Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.
Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.
Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.
Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.
Material weakness in internal control over financial reporting: Material audit adjustment
Criteria: Management is responsible for maintaining its accounting records in accordance with generally accepted
accounting principles (GAAP).
Condition: Two contributions with donor restrictions were recorded as without donor restriction.
Context: Identified by the auditor during testing of revenue in the financial statement audit.
Cause: Internal controls did not identify all contributions which included donor restrictions.
Effect or Potential Effect: As a result of this condition, $70,000 was reclassified from revenue and net assets without
donor restrictions to revenue and net assets with donor restrictions.
Recommendation: We recommend the Organization provide review for all grant agreements to ensure amounts
restricted by the donor are recorded with donor restriction.
Responsible Official’s Response: Agree. Corrective Action will be for the AIOA Controller to consult with and
collaborate with the AIOA CFO on the determination of the revenue treatment of grants and contributions received
from private foundations to ascertain the existence of conditions and/or donor imposed restrictions.
Material weakness in internal control over financial reporting: Material audit adjustment
Criteria: Management is responsible for maintaining its accounting records in accordance with generally accepted
accounting principles (GAAP).
Condition: Two contributions with donor restrictions were recorded as without donor restriction.
Context: Identified by the auditor during testing of revenue in the financial statement audit.
Cause: Internal controls did not identify all contributions which included donor restrictions.
Effect or Potential Effect: As a result of this condition, $70,000 was reclassified from revenue and net assets without
donor restrictions to revenue and net assets with donor restrictions.
Recommendation: We recommend the Organization provide review for all grant agreements to ensure amounts
restricted by the donor are recorded with donor restriction.
Responsible Official’s Response: Agree. Corrective Action will be for the AIOA Controller to consult with and
collaborate with the AIOA CFO on the determination of the revenue treatment of grants and contributions received
from private foundations to ascertain the existence of conditions and/or donor imposed restrictions.
Material weakness in internal control over financial reporting: Material audit adjustment
Criteria: Management is responsible for maintaining its accounting records in accordance with generally accepted
accounting principles (GAAP).
Condition: Two contributions with donor restrictions were recorded as without donor restriction.
Context: Identified by the auditor during testing of revenue in the financial statement audit.
Cause: Internal controls did not identify all contributions which included donor restrictions.
Effect or Potential Effect: As a result of this condition, $70,000 was reclassified from revenue and net assets without
donor restrictions to revenue and net assets with donor restrictions.
Recommendation: We recommend the Organization provide review for all grant agreements to ensure amounts
restricted by the donor are recorded with donor restriction.
Responsible Official’s Response: Agree. Corrective Action will be for the AIOA Controller to consult with and
collaborate with the AIOA CFO on the determination of the revenue treatment of grants and contributions received
from private foundations to ascertain the existence of conditions and/or donor imposed restrictions.
Material weakness in internal control over financial reporting: Material audit adjustment
Criteria: Management is responsible for maintaining its accounting records in accordance with generally accepted
accounting principles (GAAP).
Condition: Two contributions with donor restrictions were recorded as without donor restriction.
Context: Identified by the auditor during testing of revenue in the financial statement audit.
Cause: Internal controls did not identify all contributions which included donor restrictions.
Effect or Potential Effect: As a result of this condition, $70,000 was reclassified from revenue and net assets without
donor restrictions to revenue and net assets with donor restrictions.
Recommendation: We recommend the Organization provide review for all grant agreements to ensure amounts
restricted by the donor are recorded with donor restriction.
Responsible Official’s Response: Agree. Corrective Action will be for the AIOA Controller to consult with and
collaborate with the AIOA CFO on the determination of the revenue treatment of grants and contributions received
from private foundations to ascertain the existence of conditions and/or donor imposed restrictions.
Material weakness in internal control over financial reporting: Material audit adjustment
Criteria: Management is responsible for maintaining its accounting records in accordance with generally accepted
accounting principles (GAAP).
Condition: Two contributions with donor restrictions were recorded as without donor restriction.
Context: Identified by the auditor during testing of revenue in the financial statement audit.
Cause: Internal controls did not identify all contributions which included donor restrictions.
Effect or Potential Effect: As a result of this condition, $70,000 was reclassified from revenue and net assets without
donor restrictions to revenue and net assets with donor restrictions.
Recommendation: We recommend the Organization provide review for all grant agreements to ensure amounts
restricted by the donor are recorded with donor restriction.
Responsible Official’s Response: Agree. Corrective Action will be for the AIOA Controller to consult with and
collaborate with the AIOA CFO on the determination of the revenue treatment of grants and contributions received
from private foundations to ascertain the existence of conditions and/or donor imposed restrictions.
Material weakness in internal control over financial reporting: Material audit adjustment
Criteria: Management is responsible for maintaining its accounting records in accordance with generally accepted
accounting principles (GAAP).
Condition: Two contributions with donor restrictions were recorded as without donor restriction.
Context: Identified by the auditor during testing of revenue in the financial statement audit.
Cause: Internal controls did not identify all contributions which included donor restrictions.
Effect or Potential Effect: As a result of this condition, $70,000 was reclassified from revenue and net assets without
donor restrictions to revenue and net assets with donor restrictions.
Recommendation: We recommend the Organization provide review for all grant agreements to ensure amounts
restricted by the donor are recorded with donor restriction.
Responsible Official’s Response: Agree. Corrective Action will be for the AIOA Controller to consult with and
collaborate with the AIOA CFO on the determination of the revenue treatment of grants and contributions received
from private foundations to ascertain the existence of conditions and/or donor imposed restrictions.
Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.
Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.
Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.
Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.
Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.
Significant Deficiency in Internal Control over Compliance: Approval of Executive Director’s
Expenditures.
Information on the Federal Program: Assistance Listing Number 16.526 ‐ Office on Violence Against Women:
Training and Technical Assistance Initiative and 16.557 Office on Violence Against Women: Tribal Domestic
Violence and Sexual Assault Coalitions Program
Award Numbers: 15JOVW‐21‐GG‐02267‐MUMU, 2018‐TA‐AX‐K002
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs and Cost Principles
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.3030 of Subpart D, “Post Federal Award Requirements Standards for Financial Program
Management,” of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal
control over the federal award that provides reasonable assurance that the entity is managing the federal award in
compliance with federal statutes, regulations, and the terms and conditions of the federal award, including
Activities Allowed or Unallowed and Allowable Costs and Cost Principles.
Condition: Processes and procedures in place to approve expenditures did not include timely approval of expenses
initiated by the Executive Director.
Cause: The Executive Director or Operations Director approves all expenditures, however a process was not in place
for a Circle Keeper (board member) to regularly review expenditures initiated by the Executive Director during 2022.
Effect or Potential Effect: Unallowable costs or activities could be charged to federal grants.
Questioned Cost: None
Context: One of eleven items selected ($252 of $23,074 direct expenses tested) for assistance listing 16.526 and
one of twenty‐four items selected ($377 of $21,809 direct expenses tested) for assistance listing 16.557 had not
been approved as of the date of testing.
Recommendation: We recommend the Organization provide evidence of the Executive Director’s expenses to a
Circle Keeper for approval on a regular basis.Responsible Official’s Response: Agree. The two expenditures initiated by the Executive Director that did not have
the required approval of the Keeper of Finances was an oversight and not in line with the Financial Policies and
Procedures. We have determined an update is necessary to the procedures in the Financial Policies and Procedures
manual to address the use of MIWSAC credit/debit cards for expenditures. We have updated Part III, Sections 2 and
4, which is included with the corrective action.
Further, we will request the Circle Keepers to adopt these changes to the Financial Policies and Procedures at their
next scheduled meeting. And, we will advise staff of the expense approval oversights revealed by the audit along
with the updated procedures added to the Financial Policies and Procedures manual. This communication will be
provided in writing as a memo to all staff.
Material weakness in internal control over financial reporting: Material audit adjustment
Criteria: Management is responsible for maintaining its accounting records in accordance with generally accepted
accounting principles (GAAP).
Condition: Two contributions with donor restrictions were recorded as without donor restriction.
Context: Identified by the auditor during testing of revenue in the financial statement audit.
Cause: Internal controls did not identify all contributions which included donor restrictions.
Effect or Potential Effect: As a result of this condition, $70,000 was reclassified from revenue and net assets without
donor restrictions to revenue and net assets with donor restrictions.
Recommendation: We recommend the Organization provide review for all grant agreements to ensure amounts
restricted by the donor are recorded with donor restriction.
Responsible Official’s Response: Agree. Corrective Action will be for the AIOA Controller to consult with and
collaborate with the AIOA CFO on the determination of the revenue treatment of grants and contributions received
from private foundations to ascertain the existence of conditions and/or donor imposed restrictions.
Material weakness in internal control over financial reporting: Material audit adjustment
Criteria: Management is responsible for maintaining its accounting records in accordance with generally accepted
accounting principles (GAAP).
Condition: Two contributions with donor restrictions were recorded as without donor restriction.
Context: Identified by the auditor during testing of revenue in the financial statement audit.
Cause: Internal controls did not identify all contributions which included donor restrictions.
Effect or Potential Effect: As a result of this condition, $70,000 was reclassified from revenue and net assets without
donor restrictions to revenue and net assets with donor restrictions.
Recommendation: We recommend the Organization provide review for all grant agreements to ensure amounts
restricted by the donor are recorded with donor restriction.
Responsible Official’s Response: Agree. Corrective Action will be for the AIOA Controller to consult with and
collaborate with the AIOA CFO on the determination of the revenue treatment of grants and contributions received
from private foundations to ascertain the existence of conditions and/or donor imposed restrictions.
Material weakness in internal control over financial reporting: Material audit adjustment
Criteria: Management is responsible for maintaining its accounting records in accordance with generally accepted
accounting principles (GAAP).
Condition: Two contributions with donor restrictions were recorded as without donor restriction.
Context: Identified by the auditor during testing of revenue in the financial statement audit.
Cause: Internal controls did not identify all contributions which included donor restrictions.
Effect or Potential Effect: As a result of this condition, $70,000 was reclassified from revenue and net assets without
donor restrictions to revenue and net assets with donor restrictions.
Recommendation: We recommend the Organization provide review for all grant agreements to ensure amounts
restricted by the donor are recorded with donor restriction.
Responsible Official’s Response: Agree. Corrective Action will be for the AIOA Controller to consult with and
collaborate with the AIOA CFO on the determination of the revenue treatment of grants and contributions received
from private foundations to ascertain the existence of conditions and/or donor imposed restrictions.
Material weakness in internal control over financial reporting: Material audit adjustment
Criteria: Management is responsible for maintaining its accounting records in accordance with generally accepted
accounting principles (GAAP).
Condition: Two contributions with donor restrictions were recorded as without donor restriction.
Context: Identified by the auditor during testing of revenue in the financial statement audit.
Cause: Internal controls did not identify all contributions which included donor restrictions.
Effect or Potential Effect: As a result of this condition, $70,000 was reclassified from revenue and net assets without
donor restrictions to revenue and net assets with donor restrictions.
Recommendation: We recommend the Organization provide review for all grant agreements to ensure amounts
restricted by the donor are recorded with donor restriction.
Responsible Official’s Response: Agree. Corrective Action will be for the AIOA Controller to consult with and
collaborate with the AIOA CFO on the determination of the revenue treatment of grants and contributions received
from private foundations to ascertain the existence of conditions and/or donor imposed restrictions.
Material weakness in internal control over financial reporting: Material audit adjustment
Criteria: Management is responsible for maintaining its accounting records in accordance with generally accepted
accounting principles (GAAP).
Condition: Two contributions with donor restrictions were recorded as without donor restriction.
Context: Identified by the auditor during testing of revenue in the financial statement audit.
Cause: Internal controls did not identify all contributions which included donor restrictions.
Effect or Potential Effect: As a result of this condition, $70,000 was reclassified from revenue and net assets without
donor restrictions to revenue and net assets with donor restrictions.
Recommendation: We recommend the Organization provide review for all grant agreements to ensure amounts
restricted by the donor are recorded with donor restriction.
Responsible Official’s Response: Agree. Corrective Action will be for the AIOA Controller to consult with and
collaborate with the AIOA CFO on the determination of the revenue treatment of grants and contributions received
from private foundations to ascertain the existence of conditions and/or donor imposed restrictions.
Material weakness in internal control over financial reporting: Material audit adjustment
Criteria: Management is responsible for maintaining its accounting records in accordance with generally accepted
accounting principles (GAAP).
Condition: Two contributions with donor restrictions were recorded as without donor restriction.
Context: Identified by the auditor during testing of revenue in the financial statement audit.
Cause: Internal controls did not identify all contributions which included donor restrictions.
Effect or Potential Effect: As a result of this condition, $70,000 was reclassified from revenue and net assets without
donor restrictions to revenue and net assets with donor restrictions.
Recommendation: We recommend the Organization provide review for all grant agreements to ensure amounts
restricted by the donor are recorded with donor restriction.
Responsible Official’s Response: Agree. Corrective Action will be for the AIOA Controller to consult with and
collaborate with the AIOA CFO on the determination of the revenue treatment of grants and contributions received
from private foundations to ascertain the existence of conditions and/or donor imposed restrictions.