Audit 323235

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Program: AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023- 01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: 1. Federal award identification; 2. All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; 3. Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. 4. (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the passthrough entity must determine the appropriate rate in collaboration with the subrecipient, which is either: 1. The negotiated indirect cost rate between the pass-through entity and the subrecipient; 2. The de minimis indirect cost rate (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. (iii) 5. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and 6. Appropriate terms and conditions concerning closeout of the subaward. b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. c. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. d. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. 4. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. e. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: 1. Providing subrecipients with training and technical assistance on program-related matters; and 2. Performing on-site reviews of the subrecipient's program operations; 3. Arranging for agreed-upon-procedures engagements as described in § 200.425. f. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. g. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. h. Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations. Cause: The Organization’s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-009 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Supporting Documentation for Expenses Incurred During the Year Major Programs: AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: AL#93.788 – $1,000 AL#93.859 - $364, based on the error the questioned costs could exceed $25,000 How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: During testing of cash disbursements there were expenditures for which supporting documentation could not be located. Criteria: Under 2 CFR Part 200.403 (a) costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and (g) costs must be adequately documented in order to be allowable under Federal awards. Cause: The Organization misplaced the invoices. Effect: The Organization was unable to provide the auditors with proper supporting documentation for testing and therefore it could not be determined whether the expenses were reasonable and necessary to be charged to the programs. Recommendation: We recommend the Organization create processes and procedures whereby all invoices and other pertinent supporting documentation is saved and filed either in paper or electronic form to support the expense charged to the federal award and ensure the expense is allowable. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-009 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Supporting Documentation for Expenses Incurred During the Year Major Programs: AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: AL#93.788 – $1,000 AL#93.859 - $364, based on the error the questioned costs could exceed $25,000 How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: During testing of cash disbursements there were expenditures for which supporting documentation could not be located. Criteria: Under 2 CFR Part 200.403 (a) costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and (g) costs must be adequately documented in order to be allowable under Federal awards. Cause: The Organization misplaced the invoices. Effect: The Organization was unable to provide the auditors with proper supporting documentation for testing and therefore it could not be determined whether the expenses were reasonable and necessary to be charged to the programs. Recommendation: We recommend the Organization create processes and procedures whereby all invoices and other pertinent supporting documentation is saved and filed either in paper or electronic form to support the expense charged to the federal award and ensure the expense is allowable. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-010 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Inaccurate Reporting Major Programs: AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: During testing of reporting, we noted the Annual Form SF-425 included revenue for months beyond the reporting period end date. Criteria: Amounts included on the Annual SF-425 report filed were to include amounts through July 31, 2023, the reporting period end date. Cause: The Organization did not review the report prior to filing to ensure the correct data was used to prepare the report. Effect: The Organization filed a report with incorrect data. Recommendation: We recommend the Organization create processes and procedures whereby all someone independent of the report preparation process reviews the reports with supporting documentation prior to filing to ensure the reports were prepared accurately. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-006 Repeat Finding: No Type of Finding: Significant Deficiency Description: Recording Expenses in Proper Period Condition: During our testing of cash disbursements, we noted that an expense that was charged to a major program in 2023 was for a service that was performed in 2022. Criteria: The organization should be following GAAP, when the expense was incurred but not paid for in 2022, it should have been recognized as an expense and accrued as a liability. Cause: The finance department staff did not record the transaction properly. Effect: Grant revenue and expenses were understated in 2022 and overstated in 2023. Recommendation: Finance department staff should review and enter invoices in the accounting system as they come in, so as to ensure the transactions are being properly recorded. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Program: AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023- 01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: 1. Federal award identification; 2. All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; 3. Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. 4. (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the passthrough entity must determine the appropriate rate in collaboration with the subrecipient, which is either: 1. The negotiated indirect cost rate between the pass-through entity and the subrecipient; 2. The de minimis indirect cost rate (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. (iii) 5. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and 6. Appropriate terms and conditions concerning closeout of the subaward. b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. c. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. d. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. 4. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. e. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: 1. Providing subrecipients with training and technical assistance on program-related matters; and 2. Performing on-site reviews of the subrecipient's program operations; 3. Arranging for agreed-upon-procedures engagements as described in § 200.425. f. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. g. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. h. Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations. Cause: The Organization’s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-009 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Supporting Documentation for Expenses Incurred During the Year Major Programs: AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: AL#93.788 – $1,000 AL#93.859 - $364, based on the error the questioned costs could exceed $25,000 How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: During testing of cash disbursements there were expenditures for which supporting documentation could not be located. Criteria: Under 2 CFR Part 200.403 (a) costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and (g) costs must be adequately documented in order to be allowable under Federal awards. Cause: The Organization misplaced the invoices. Effect: The Organization was unable to provide the auditors with proper supporting documentation for testing and therefore it could not be determined whether the expenses were reasonable and necessary to be charged to the programs. Recommendation: We recommend the Organization create processes and procedures whereby all invoices and other pertinent supporting documentation is saved and filed either in paper or electronic form to support the expense charged to the federal award and ensure the expense is allowable. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Program: AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023- 01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: 1. Federal award identification; 2. All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; 3. Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. 4. (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the passthrough entity must determine the appropriate rate in collaboration with the subrecipient, which is either: 1. The negotiated indirect cost rate between the pass-through entity and the subrecipient; 2. The de minimis indirect cost rate (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. (iii) 5. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and 6. Appropriate terms and conditions concerning closeout of the subaward. b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. c. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. d. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. 4. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. e. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: 1. Providing subrecipients with training and technical assistance on program-related matters; and 2. Performing on-site reviews of the subrecipient's program operations; 3. Arranging for agreed-upon-procedures engagements as described in § 200.425. f. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. g. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. h. Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations. Cause: The Organization’s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-009 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Supporting Documentation for Expenses Incurred During the Year Major Programs: AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: AL#93.788 – $1,000 AL#93.859 - $364, based on the error the questioned costs could exceed $25,000 How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: During testing of cash disbursements there were expenditures for which supporting documentation could not be located. Criteria: Under 2 CFR Part 200.403 (a) costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and (g) costs must be adequately documented in order to be allowable under Federal awards. Cause: The Organization misplaced the invoices. Effect: The Organization was unable to provide the auditors with proper supporting documentation for testing and therefore it could not be determined whether the expenses were reasonable and necessary to be charged to the programs. Recommendation: We recommend the Organization create processes and procedures whereby all invoices and other pertinent supporting documentation is saved and filed either in paper or electronic form to support the expense charged to the federal award and ensure the expense is allowable. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-009 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Supporting Documentation for Expenses Incurred During the Year Major Programs: AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: AL#93.788 – $1,000 AL#93.859 - $364, based on the error the questioned costs could exceed $25,000 How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: During testing of cash disbursements there were expenditures for which supporting documentation could not be located. Criteria: Under 2 CFR Part 200.403 (a) costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and (g) costs must be adequately documented in order to be allowable under Federal awards. Cause: The Organization misplaced the invoices. Effect: The Organization was unable to provide the auditors with proper supporting documentation for testing and therefore it could not be determined whether the expenses were reasonable and necessary to be charged to the programs. Recommendation: We recommend the Organization create processes and procedures whereby all invoices and other pertinent supporting documentation is saved and filed either in paper or electronic form to support the expense charged to the federal award and ensure the expense is allowable. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-010 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Inaccurate Reporting Major Programs: AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: During testing of reporting, we noted the Annual Form SF-425 included revenue for months beyond the reporting period end date. Criteria: Amounts included on the Annual SF-425 report filed were to include amounts through July 31, 2023, the reporting period end date. Cause: The Organization did not review the report prior to filing to ensure the correct data was used to prepare the report. Effect: The Organization filed a report with incorrect data. Recommendation: We recommend the Organization create processes and procedures whereby all someone independent of the report preparation process reviews the reports with supporting documentation prior to filing to ensure the reports were prepared accurately. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-006 Repeat Finding: No Type of Finding: Significant Deficiency Description: Recording Expenses in Proper Period Condition: During our testing of cash disbursements, we noted that an expense that was charged to a major program in 2023 was for a service that was performed in 2022. Criteria: The organization should be following GAAP, when the expense was incurred but not paid for in 2022, it should have been recognized as an expense and accrued as a liability. Cause: The finance department staff did not record the transaction properly. Effect: Grant revenue and expenses were understated in 2022 and overstated in 2023. Recommendation: Finance department staff should review and enter invoices in the accounting system as they come in, so as to ensure the transactions are being properly recorded. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Program: AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023- 01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: 1. Federal award identification; 2. All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; 3. Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. 4. (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the passthrough entity must determine the appropriate rate in collaboration with the subrecipient, which is either: 1. The negotiated indirect cost rate between the pass-through entity and the subrecipient; 2. The de minimis indirect cost rate (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. (iii) 5. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and 6. Appropriate terms and conditions concerning closeout of the subaward. b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. c. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. d. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. 4. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. e. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: 1. Providing subrecipients with training and technical assistance on program-related matters; and 2. Performing on-site reviews of the subrecipient's program operations; 3. Arranging for agreed-upon-procedures engagements as described in § 200.425. f. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. g. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. h. Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations. Cause: The Organization’s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03

Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2023-009 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Supporting Documentation for Expenses Incurred During the Year Major Programs: AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: AL#93.788 – $1,000 AL#93.859 - $364, based on the error the questioned costs could exceed $25,000 How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: During testing of cash disbursements there were expenditures for which supporting documentation could not be located. Criteria: Under 2 CFR Part 200.403 (a) costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and (g) costs must be adequately documented in order to be allowable under Federal awards. Cause: The Organization misplaced the invoices. Effect: The Organization was unable to provide the auditors with proper supporting documentation for testing and therefore it could not be determined whether the expenses were reasonable and necessary to be charged to the programs. Recommendation: We recommend the Organization create processes and procedures whereby all invoices and other pertinent supporting documentation is saved and filed either in paper or electronic form to support the expense charged to the federal award and ensure the expense is allowable. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.