Audit 321688

FY End
2023-12-31
Total Expended
$12.84M
Findings
6
Programs
36
Year: 2023 Accepted: 2024-09-27
Auditor: Moss Adams LLP

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
498888 2023-001 Significant Deficiency - I
498889 2023-001 Significant Deficiency - I
498890 2023-001 Significant Deficiency - I
1075330 2023-001 Significant Deficiency - I
1075331 2023-001 Significant Deficiency - I
1075332 2023-001 Significant Deficiency - I

Programs

ALN Program Spent Major Findings
93.210 Tribal Self-Governance Program: Ihs Compacts/funding Agreements $2.37M - 0
11.438 Pacific Coast Salmon Recovery_pacific Salmon Treaty Program $2.33M Yes 1
21.027 Coronavirus State and Local Fiscal Recovery Funds $1.10M Yes 0
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $685,007 - 0
15.022 Tribal Self-Governance $607,548 - 0
15.035 Forestry on Indian Lands $566,451 - 0
21.032 Local Assistance and Tribal Consistency Fund $390,800 - 0
14.867 Indian Housing Block Grants $348,522 Yes 0
15.041 Environmental Management_indian Programs $337,685 - 0
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $201,397 - 0
15.032 Indian Economic Development $161,150 - 0
93.237 Special Diabetes Program for Indians_diabetes Prevention and Treatment Projects $121,342 - 0
66.034 Surveys, Studies, Research, Investigations, Demonstrations, and Special Purpose Activities Relating to the Clean Air Act $117,604 - 0
93.778 Medical Assistance Program $96,909 - 0
66.808 Solid Waste Management Assistance Grants $78,064 - 0
93.788 Opioid Str $64,799 - 0
93.268 Immunization Cooperative Agreements $51,968 - 0
15.904 Historic Preservation Fund Grants-in-Aid $43,462 - 0
16.710 Public Safety Partnership and Community Policing Grants $40,795 - 0
66.605 Performance Partnership Grants $35,470 - 0
16.596 Tribal Justice Facilities Grant Program for Indian Tribes $34,234 - 0
66.817 State and Tribal Response Program Grants $23,549 - 0
16.608 Tribal Court Assistance Program $23,086 - 0
15.639 Tribal Wildlife Grants Program $17,193 - 0
14.862 Indian Community Development Block Grant Program $13,915 - 0
93.568 Low-Income Home Energy Assistance $10,312 - 0
20.205 Highway Planning and Construction $7,101 - 0
16.841 Voca Tribal Victim Services Set-Aside Program $5,702 - 0
93.499 Low Income Household Water Assistance Program $4,600 - 0
93.071 Medicare Enrollment Assistance Program $4,188 - 0
93.054 National Family Caregiver Support, Title Vi, Part C, Grants to Indian Tribes and Native Hawaiians $3,602 - 0
93.575 Child Care and Development Block Grant $3,277 - 0
15.040 Real Estate Programs_indian Lands $2,934 - 0
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $2,372 - 0
93.047 Special Programs for the Aging_title Vi, Part A, Grants to Indian Tribes_part B, Grants to Native Hawaiians $1,680 - 0
93.556 Promoting Safe and Stable Families $568 - 0

Contacts

Name Title Type
X8QTNZ5GZ6W3 Don Moos Auditee
5414357172 Anita Shah Auditor
No contacts on file

Notes to SEFA

Title: Note 1 – Basis of Presentation Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, or other guidelines as applicable, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: The Tribe has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Instead, the Tribe used its approved indirect cost rate. The accompanying schedule of expenditures of federal awards (the Schedule) includes the grant and contract activity of the Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians (the Tribe). The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) . Because the Schedule presents only a portion of the operations of the Tribes, it is not intended to and does not present the financial position or changes in the net position of the Tribe
Title: Note 2 – Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, or other guidelines as applicable, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: The Tribe has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Instead, the Tribe used its approved indirect cost rate. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, or other guidelines as applicable, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available.
Title: Note 3 – Indirect Cost Rate Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, or other guidelines as applicable, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: The Tribe has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Instead, the Tribe used its approved indirect cost rate. The Tribe has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Instead, the Tribe used its approved indirect cost rate.
Title: Note 4 – Reconciliation of Federal and Nonfederal Awards Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, or other guidelines as applicable, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: The Tribe has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Instead, the Tribe used its approved indirect cost rate. Grant Fund expenditures reported in the statement of revenues, expenditures and changes in fund balances—governmental funds Grants Fund expenditures $19,631,548 Less Expenditures funded by other sources, which are not federal funds (6,786,638) Total federal award expenditures $12,844,910
Title: Note 5 – Outstanding Federal Loans Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, or other guidelines as applicable, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Pass-through entity identifying numbers are presented where available. De Minimis Rate Used: N Rate Explanation: The Tribe has elected not to use the 10-percent de minimis indirect cost rate allowed under the Uniform Guidance. Instead, the Tribe used its approved indirect cost rate. There are no outstanding federal loan balances at December 31, 2023.

Finding Details

Finding 2023-001— Suspension and Debarment (Significant Deficiency) Major Programs Affected – CFDAL Number Program Name Award Number Award Year Questioned Costs 11.438 Department of Commerce (DOC) – Pacific Coast Salmon Recovery Multiple 2023 N/A Criteria – Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition and Context – During our testing of two vendor files, we noted both vendors files had no evidence of review of the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) to ensure that the vendors were not suspended or debarred before the Tribe entered into contracts with those vendors. We noted that one vendor had a self-certify clause that they are not suspended or debarred included in the final contract; no such self-certification was noted for the second vendor. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Tribe’s procurement policy’s documentation requirement to indicate verification of checking the vendors for suspension and debarment. Effect – The Tribe could be at risk for contracting with vendors that have been suspended or debarred from governmental contracts. Recommendation – We understand that the Tribe has already implemented a procedure to enhance current practice and will be including a printed verification from SAM.gov in the vendor’s procurement file. We recommend the Tribe implement a supervisory review of the vendor files to ensure all procurement-related documents are maintained in accordance with the Tribe’s policy. Views of responsible officials – See the Tribe’s Corrective Action Plan.
Finding 2023-001— Suspension and Debarment (Significant Deficiency) Major Programs Affected – CFDAL Number Program Name Award Number Award Year Questioned Costs 11.438 Department of Commerce (DOC) – Pacific Coast Salmon Recovery Multiple 2023 N/A Criteria – Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition and Context – During our testing of two vendor files, we noted both vendors files had no evidence of review of the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) to ensure that the vendors were not suspended or debarred before the Tribe entered into contracts with those vendors. We noted that one vendor had a self-certify clause that they are not suspended or debarred included in the final contract; no such self-certification was noted for the second vendor. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Tribe’s procurement policy’s documentation requirement to indicate verification of checking the vendors for suspension and debarment. Effect – The Tribe could be at risk for contracting with vendors that have been suspended or debarred from governmental contracts. Recommendation – We understand that the Tribe has already implemented a procedure to enhance current practice and will be including a printed verification from SAM.gov in the vendor’s procurement file. We recommend the Tribe implement a supervisory review of the vendor files to ensure all procurement-related documents are maintained in accordance with the Tribe’s policy. Views of responsible officials – See the Tribe’s Corrective Action Plan.
Finding 2023-001— Suspension and Debarment (Significant Deficiency) Major Programs Affected – CFDAL Number Program Name Award Number Award Year Questioned Costs 11.438 Department of Commerce (DOC) – Pacific Coast Salmon Recovery Multiple 2023 N/A Criteria – Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition and Context – During our testing of two vendor files, we noted both vendors files had no evidence of review of the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) to ensure that the vendors were not suspended or debarred before the Tribe entered into contracts with those vendors. We noted that one vendor had a self-certify clause that they are not suspended or debarred included in the final contract; no such self-certification was noted for the second vendor. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Tribe’s procurement policy’s documentation requirement to indicate verification of checking the vendors for suspension and debarment. Effect – The Tribe could be at risk for contracting with vendors that have been suspended or debarred from governmental contracts. Recommendation – We understand that the Tribe has already implemented a procedure to enhance current practice and will be including a printed verification from SAM.gov in the vendor’s procurement file. We recommend the Tribe implement a supervisory review of the vendor files to ensure all procurement-related documents are maintained in accordance with the Tribe’s policy. Views of responsible officials – See the Tribe’s Corrective Action Plan.
Finding 2023-001— Suspension and Debarment (Significant Deficiency) Major Programs Affected – CFDAL Number Program Name Award Number Award Year Questioned Costs 11.438 Department of Commerce (DOC) – Pacific Coast Salmon Recovery Multiple 2023 N/A Criteria – Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition and Context – During our testing of two vendor files, we noted both vendors files had no evidence of review of the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) to ensure that the vendors were not suspended or debarred before the Tribe entered into contracts with those vendors. We noted that one vendor had a self-certify clause that they are not suspended or debarred included in the final contract; no such self-certification was noted for the second vendor. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Tribe’s procurement policy’s documentation requirement to indicate verification of checking the vendors for suspension and debarment. Effect – The Tribe could be at risk for contracting with vendors that have been suspended or debarred from governmental contracts. Recommendation – We understand that the Tribe has already implemented a procedure to enhance current practice and will be including a printed verification from SAM.gov in the vendor’s procurement file. We recommend the Tribe implement a supervisory review of the vendor files to ensure all procurement-related documents are maintained in accordance with the Tribe’s policy. Views of responsible officials – See the Tribe’s Corrective Action Plan.
Finding 2023-001— Suspension and Debarment (Significant Deficiency) Major Programs Affected – CFDAL Number Program Name Award Number Award Year Questioned Costs 11.438 Department of Commerce (DOC) – Pacific Coast Salmon Recovery Multiple 2023 N/A Criteria – Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition and Context – During our testing of two vendor files, we noted both vendors files had no evidence of review of the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) to ensure that the vendors were not suspended or debarred before the Tribe entered into contracts with those vendors. We noted that one vendor had a self-certify clause that they are not suspended or debarred included in the final contract; no such self-certification was noted for the second vendor. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Tribe’s procurement policy’s documentation requirement to indicate verification of checking the vendors for suspension and debarment. Effect – The Tribe could be at risk for contracting with vendors that have been suspended or debarred from governmental contracts. Recommendation – We understand that the Tribe has already implemented a procedure to enhance current practice and will be including a printed verification from SAM.gov in the vendor’s procurement file. We recommend the Tribe implement a supervisory review of the vendor files to ensure all procurement-related documents are maintained in accordance with the Tribe’s policy. Views of responsible officials – See the Tribe’s Corrective Action Plan.
Finding 2023-001— Suspension and Debarment (Significant Deficiency) Major Programs Affected – CFDAL Number Program Name Award Number Award Year Questioned Costs 11.438 Department of Commerce (DOC) – Pacific Coast Salmon Recovery Multiple 2023 N/A Criteria – Non-federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. Condition and Context – During our testing of two vendor files, we noted both vendors files had no evidence of review of the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) to ensure that the vendors were not suspended or debarred before the Tribe entered into contracts with those vendors. We noted that one vendor had a self-certify clause that they are not suspended or debarred included in the final contract; no such self-certification was noted for the second vendor. However, based on our testing, we noted none of the vendors were suspended or debarred. Cause – The programs did not follow the Tribe’s procurement policy’s documentation requirement to indicate verification of checking the vendors for suspension and debarment. Effect – The Tribe could be at risk for contracting with vendors that have been suspended or debarred from governmental contracts. Recommendation – We understand that the Tribe has already implemented a procedure to enhance current practice and will be including a printed verification from SAM.gov in the vendor’s procurement file. We recommend the Tribe implement a supervisory review of the vendor files to ensure all procurement-related documents are maintained in accordance with the Tribe’s policy. Views of responsible officials – See the Tribe’s Corrective Action Plan.