Finding 2023‐001:
Information on the Federal Program: Assistance Listing Number 81.086— Upper Midwest Inter‐Tribal EV Charging
Community Network.
Compliance Requirement: Allowable Costs and Cost Principles, Activities Allowed or Unallowed
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.303 of Subpart D, "Post Federal Award Requirements Standards for Financial and 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, Allowable Costs and Cost Principles.
Condition: Controls were not operating as designed to ensure that all travel reimbursements and payroll
expenditures were reviewed and approved prior to payment.
Causes: SDK notes that for the two reimbursement draw down dates selected for testing, pay for one of the three
workers in each draw down request lacked proper review and approval of hours allocated to the grant. There was
not adequate documentation of hours charged to the grant for the executive director as of the date of audit
requests. For one of seven remaining non‐payroll transactions tested for allowability, approval documentation
did not exist.
Effect or Potential Effect: Unallowable costs or activities could be charged to the grant.
Questioned Costs: None
Context: There was not sufficient documentation available upon request to support a review and approval process
of the Executive Director’s pay allocated to the grant nor for a travel reimbursement.
Repeat Finding: No
Recommendation: We recommend that a process for board review and approval of the executive director’s hours
be implemented and performed on a regular (at least quarterly) basis. We additionally recommend approval be
documented for all expenditures prior to charging to a federal grant.
Views of Responsible Officials: Agree.
Finding 2023‐002:
Information on the Federal Program: Assistance Listing Number 81.086— Upper Midwest Inter‐Tribal EV Charging
Community Network.
Compliance Requirement: Matching
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.303 of Subpart D, "Post Federal Award Requirements Standards for Financial and 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 Cost
Match principles.
Condition: Controls were not implemented to monitor cost match partners’ activities to ensure their expenditures
comply with allowable cost activities.
Causes: For one of three cost matching amounts recorded in 2023, detail of amounts reported as cost match was
not available upon request by auditors, and therefore the detail had not been obtained by the Organization.
Effect or Potential Effect: Unallowable costs or activities could be counted for cost match by match partners
causing Native Sun to fall short of cost match requirements.
Questioned Costs: None
Context: The Organization did not initially have documentation with sufficient detail for $756,108 of expenses
reported by a cost match partner during 2023.
Repeat Finding: No
Recommendation: We recommend a control be implemented to monitor cost match partners including obtaining,
reviewing and retaining support for reported cost match amounts.
Views of Responsible Officials: Agree.
Finding 2023‐003:
Information on the Federal Program: Assistance Listing Number 81.086— Upper Midwest Inter‐Tribal EV Charging
Community Network.
Compliance Requirement: Reporting
Type of Finding: Noncompliance and significant deficiency in internal control over compliance.
Criteria: 2 CFR Part 170, Appendix A item I. a. 1: you must report, in the Federal Funding Accountability and
Transparency Act Subaward Reporting System (FSRS) at fsrs.gov, each action that obligates $25,000 or more in
Federal funds for a subaward to an entity no later than the end of the month following the month in which the
obligation was made. Data elements which must be reported include subawardee name, subawardee DUNS #,
amount of subaward, subaward obligation/action date, subaward number and subaward project description.
Condition: Per client inquiry and review of usaspending.gov, the subaward of DE‐EE0009865 to American Lung
Association had not been reported in FSRS.
Causes: Controls were not in place to ensure reporting of subawards to FSRS.
Effect or Potential Effect: The subaward to American Lung Association, effective March 1, 2022, for the amount of
$5,583,789, crossing three budget periods from March 1, 2022 to May 31, 2025 was not reported in FSRS. Of this
award, $498,051 was passed through to the subrecipient in the year ended December 31, 2023.
Questioned Costs: None
Context: The award to American Lung Association was the only subaward related to the 2023 federal expenditures
and was therefore selected for testing.
Repeat Finding: No
Recommendation: We recommend the organization adopt processes and controls to ensure FSRS reporting is
completed on a timely basis for all subawards.
Views of Responsible Officials: Agree.
Finding 2023‐001:
Information on the Federal Program: Assistance Listing Number 81.086— Upper Midwest Inter‐Tribal EV Charging
Community Network.
Compliance Requirement: Allowable Costs and Cost Principles, Activities Allowed or Unallowed
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.303 of Subpart D, "Post Federal Award Requirements Standards for Financial and 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, Allowable Costs and Cost Principles.
Condition: Controls were not operating as designed to ensure that all travel reimbursements and payroll
expenditures were reviewed and approved prior to payment.
Causes: SDK notes that for the two reimbursement draw down dates selected for testing, pay for one of the three
workers in each draw down request lacked proper review and approval of hours allocated to the grant. There was
not adequate documentation of hours charged to the grant for the executive director as of the date of audit
requests. For one of seven remaining non‐payroll transactions tested for allowability, approval documentation
did not exist.
Effect or Potential Effect: Unallowable costs or activities could be charged to the grant.
Questioned Costs: None
Context: There was not sufficient documentation available upon request to support a review and approval process
of the Executive Director’s pay allocated to the grant nor for a travel reimbursement.
Repeat Finding: No
Recommendation: We recommend that a process for board review and approval of the executive director’s hours
be implemented and performed on a regular (at least quarterly) basis. We additionally recommend approval be
documented for all expenditures prior to charging to a federal grant.
Views of Responsible Officials: Agree.
Finding 2023‐002:
Information on the Federal Program: Assistance Listing Number 81.086— Upper Midwest Inter‐Tribal EV Charging
Community Network.
Compliance Requirement: Matching
Type of Finding: Significant deficiency in internal control over compliance.
Criteria: 2 CFR 200.303 of Subpart D, "Post Federal Award Requirements Standards for Financial and 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 Cost
Match principles.
Condition: Controls were not implemented to monitor cost match partners’ activities to ensure their expenditures
comply with allowable cost activities.
Causes: For one of three cost matching amounts recorded in 2023, detail of amounts reported as cost match was
not available upon request by auditors, and therefore the detail had not been obtained by the Organization.
Effect or Potential Effect: Unallowable costs or activities could be counted for cost match by match partners
causing Native Sun to fall short of cost match requirements.
Questioned Costs: None
Context: The Organization did not initially have documentation with sufficient detail for $756,108 of expenses
reported by a cost match partner during 2023.
Repeat Finding: No
Recommendation: We recommend a control be implemented to monitor cost match partners including obtaining,
reviewing and retaining support for reported cost match amounts.
Views of Responsible Officials: Agree.
Finding 2023‐003:
Information on the Federal Program: Assistance Listing Number 81.086— Upper Midwest Inter‐Tribal EV Charging
Community Network.
Compliance Requirement: Reporting
Type of Finding: Noncompliance and significant deficiency in internal control over compliance.
Criteria: 2 CFR Part 170, Appendix A item I. a. 1: you must report, in the Federal Funding Accountability and
Transparency Act Subaward Reporting System (FSRS) at fsrs.gov, each action that obligates $25,000 or more in
Federal funds for a subaward to an entity no later than the end of the month following the month in which the
obligation was made. Data elements which must be reported include subawardee name, subawardee DUNS #,
amount of subaward, subaward obligation/action date, subaward number and subaward project description.
Condition: Per client inquiry and review of usaspending.gov, the subaward of DE‐EE0009865 to American Lung
Association had not been reported in FSRS.
Causes: Controls were not in place to ensure reporting of subawards to FSRS.
Effect or Potential Effect: The subaward to American Lung Association, effective March 1, 2022, for the amount of
$5,583,789, crossing three budget periods from March 1, 2022 to May 31, 2025 was not reported in FSRS. Of this
award, $498,051 was passed through to the subrecipient in the year ended December 31, 2023.
Questioned Costs: None
Context: The award to American Lung Association was the only subaward related to the 2023 federal expenditures
and was therefore selected for testing.
Repeat Finding: No
Recommendation: We recommend the organization adopt processes and controls to ensure FSRS reporting is
completed on a timely basis for all subawards.
Views of Responsible Officials: Agree.