Audit 346589

Criteria: According to §200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to the Uniform Guidance (2 CFR Part 200), specifically §200.400 - 200.475, costs charged to federal awards must be reasonable, allocable, and allowable under the terms of the award. Condition and Context: Management was unable to provide sufficient documentation for specific COVID-19 expenditures that were initially reported on the Schedule of Expenditures of Federal Awards. As a result, audit adjustments were necessary to revise the total COVID-19 expenditures to include only those amounts that could be adequately substantiated. Cause: The lack of sufficient documentation was primarily due to a lack of adequate internal controls and oversight regarding the classification and allocation of COVID-19 expenditures charged to federal awards. Effect: Management did not have sufficient documentation to support activities met the terms and conditions related to the COVID-19 Indian Self-Determination federal awards. Audit adjustments were necessary to revise the total COVID-19 expenditures to include only those amounts that could be adequately substantiated. Questioned Cost: None. Repeat Finding: No Recommendation: We recommend the Hospital establish and document clear policies and procedures for identifying, classifying, and allocating costs charged to federal awards, ensuring compliance with the Uniform Guidance. Additionally, we recommend the Hospital conduct regular reviews of expenditures charged to federal awards to ensure compliance with federal regulations and the terms of the awards. Views of Responsible Officials: The Finance team of Financial Controller and Senior Accountant are responsible for gathering sufficient documentation specific to COVID-19 expenditures. Proper and accurate classification and allocation of COVID-19 related activities and expenditures will be tracked and monitored before charging to funds. This will be completed by September 30, 2025.

Criteria: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) requires Tribal Organizations that receive funds under the ISDEAA to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Tribal Organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Tribal Organization may employ only individuals in those positions if they meet standards of character that are no less stringent than those prescribed by the regulations, which are outlined in 42 CFR 136.405, and only after an individual has been the subject of a satisfactory background investigation as described in 42 CFR 136.406. Condition and Context: For 25 out of 25 employees tested, the Hospital was not able to provide sufficient documentation to support that a background check was completed prior to the employee's start date or within five years for existing employees per the Hospital’s Human Resources policy. For 12 out of 25 employees tested, the Hospital was not able to provide support that the background check results were reviewed by the appropriate authority prior to the employee being onboarded or within five years for existing employees per the Hospital’s Human Resources policy. Cause: Policies and procedures were not well defined or communicated to staff to ensure documentation was retained to support the required background checks were completed or reviewed and approved prior to an employee’s start date or within the previous five years for existing employees. Effect: The Hospital does not have sufficient documentation to evidence background checks were completed for new hires in the fiscal year or within the previous five years for existing employees. Questioned Cost: None Repeat Finding: No Recommendation: We recommend the Hospital provide additional training to ensure employees are properly documenting the background checks process and retaining evidence to support background checks were completed, reviewed and approved prior to an employee’s start date or within the previous five years for existing employees. Views of Responsible Officials: The Human Resources (HR) team of the Chief Human Resources Officer and the HR Generalists are responsible for completing background checks for existing new employees. The HR team will ensure proper and required background checks are completed, reviewed and approved for all new and existing employees. Proper documentation and results of all background checks will be reviewed and filed accordingly.

Criteria: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) requires Tribal Organizations that receive funds under the ISDEAA to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Tribal Organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Tribal Organization may employ only individuals in those positions if they meet standards of character that are no less stringent than those prescribed by the regulations, which are outlined in 42 CFR 136.405, and only after an individual has been the subject of a satisfactory background investigation as described in 42 CFR 136.406. Condition and Context: For 25 out of 25 employees tested, the Hospital was not able to provide sufficient documentation to support that a background check was completed prior to the employee's start date or within five years for existing employees per the Hospital’s Human Resources policy. For 12 out of 25 employees tested, the Hospital was not able to provide support that the background check results were reviewed by the appropriate authority prior to the employee being onboarded or within five years for existing employees per the Hospital’s Human Resources policy. Cause: Policies and procedures were not well defined or communicated to staff to ensure documentation was retained to support the required background checks were completed or reviewed and approved prior to an employee’s start date or within the previous five years for existing employees. Effect: The Hospital does not have sufficient documentation to evidence background checks were completed for new hires in the fiscal year or within the previous five years for existing employees. Questioned Cost: None Repeat Finding: No Recommendation: We recommend the Hospital provide additional training to ensure employees are properly documenting the background checks process and retaining evidence to support background checks were completed, reviewed and approved prior to an employee’s start date or within the previous five years for existing employees. Views of Responsible Officials: The Human Resources (HR) team of the Chief Human Resources Officer and the HR Generalists are responsible for completing background checks for existing new employees. The HR team will ensure proper and required background checks are completed, reviewed and approved for all new and existing employees. Proper documentation and results of all background checks will be reviewed and filed accordingly.

Criteria: According to §200.303 Internal controls of 2 CFR Part 200, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. According to the Uniform Guidance (2 CFR Part 200), specifically §200.400 - 200.475, costs charged to federal awards must be reasonable, allocable, and allowable under the terms of the award. Condition and Context: Management was unable to provide sufficient documentation for specific COVID-19 expenditures that were initially reported on the Schedule of Expenditures of Federal Awards. As a result, audit adjustments were necessary to revise the total COVID-19 expenditures to include only those amounts that could be adequately substantiated. Cause: The lack of sufficient documentation was primarily due to a lack of adequate internal controls and oversight regarding the classification and allocation of COVID-19 expenditures charged to federal awards. Effect: Management did not have sufficient documentation to support activities met the terms and conditions related to the COVID-19 Indian Self-Determination federal awards. Audit adjustments were necessary to revise the total COVID-19 expenditures to include only those amounts that could be adequately substantiated. Questioned Cost: None. Repeat Finding: No Recommendation: We recommend the Hospital establish and document clear policies and procedures for identifying, classifying, and allocating costs charged to federal awards, ensuring compliance with the Uniform Guidance. Additionally, we recommend the Hospital conduct regular reviews of expenditures charged to federal awards to ensure compliance with federal regulations and the terms of the awards. Views of Responsible Officials: The Finance team of Financial Controller and Senior Accountant are responsible for gathering sufficient documentation specific to COVID-19 expenditures. Proper and accurate classification and allocation of COVID-19 related activities and expenditures will be tracked and monitored before charging to funds. This will be completed by September 30, 2025.

Criteria: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) requires Tribal Organizations that receive funds under the ISDEAA to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Tribal Organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Tribal Organization may employ only individuals in those positions if they meet standards of character that are no less stringent than those prescribed by the regulations, which are outlined in 42 CFR 136.405, and only after an individual has been the subject of a satisfactory background investigation as described in 42 CFR 136.406. Condition and Context: For 25 out of 25 employees tested, the Hospital was not able to provide sufficient documentation to support that a background check was completed prior to the employee's start date or within five years for existing employees per the Hospital’s Human Resources policy. For 12 out of 25 employees tested, the Hospital was not able to provide support that the background check results were reviewed by the appropriate authority prior to the employee being onboarded or within five years for existing employees per the Hospital’s Human Resources policy. Cause: Policies and procedures were not well defined or communicated to staff to ensure documentation was retained to support the required background checks were completed or reviewed and approved prior to an employee’s start date or within the previous five years for existing employees. Effect: The Hospital does not have sufficient documentation to evidence background checks were completed for new hires in the fiscal year or within the previous five years for existing employees. Questioned Cost: None Repeat Finding: No Recommendation: We recommend the Hospital provide additional training to ensure employees are properly documenting the background checks process and retaining evidence to support background checks were completed, reviewed and approved prior to an employee’s start date or within the previous five years for existing employees. Views of Responsible Officials: The Human Resources (HR) team of the Chief Human Resources Officer and the HR Generalists are responsible for completing background checks for existing new employees. The HR team will ensure proper and required background checks are completed, reviewed and approved for all new and existing employees. Proper documentation and results of all background checks will be reviewed and filed accordingly.

Criteria: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) requires Tribal Organizations that receive funds under the ISDEAA to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Tribal Organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Tribal Organization may employ only individuals in those positions if they meet standards of character that are no less stringent than those prescribed by the regulations, which are outlined in 42 CFR 136.405, and only after an individual has been the subject of a satisfactory background investigation as described in 42 CFR 136.406. Condition and Context: For 25 out of 25 employees tested, the Hospital was not able to provide sufficient documentation to support that a background check was completed prior to the employee's start date or within five years for existing employees per the Hospital’s Human Resources policy. For 12 out of 25 employees tested, the Hospital was not able to provide support that the background check results were reviewed by the appropriate authority prior to the employee being onboarded or within five years for existing employees per the Hospital’s Human Resources policy. Cause: Policies and procedures were not well defined or communicated to staff to ensure documentation was retained to support the required background checks were completed or reviewed and approved prior to an employee’s start date or within the previous five years for existing employees. Effect: The Hospital does not have sufficient documentation to evidence background checks were completed for new hires in the fiscal year or within the previous five years for existing employees. Questioned Cost: None Repeat Finding: No Recommendation: We recommend the Hospital provide additional training to ensure employees are properly documenting the background checks process and retaining evidence to support background checks were completed, reviewed and approved prior to an employee’s start date or within the previous five years for existing employees. Views of Responsible Officials: The Human Resources (HR) team of the Chief Human Resources Officer and the HR Generalists are responsible for completing background checks for existing new employees. The HR team will ensure proper and required background checks are completed, reviewed and approved for all new and existing employees. Proper documentation and results of all background checks will be reviewed and filed accordingly.