FAC Explorer

Audit 354339

FY End
2022-12-31
Total Expended
$36.39M
Findings
38
Programs
54
Organization: Cheyenne and Arapaho Tribes (OK)
Year: 2022 Accepted: 2025-04-23
Auditor: Forvis Mazars LLP

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
555696 2022-004 Material Weakness - A
555697 2022-004 Material Weakness - A
555698 2022-005 Significant Deficiency - L
555699 2022-005 Significant Deficiency - L
555700 2022-005 Significant Deficiency - L
555701 2022-005 Significant Deficiency - L
555702 2022-005 Significant Deficiency - L
555703 2022-005 Significant Deficiency - L
555704 2022-005 Significant Deficiency - L
555705 2022-005 Significant Deficiency - L
555706 2022-005 Significant Deficiency - L
555707 2022-005 Significant Deficiency - L
555708 2022-006 Significant Deficiency Yes I
555709 2022-006 Significant Deficiency Yes I
555710 2022-006 Significant Deficiency Yes I
555711 2022-007 - - F
555712 2022-007 - - F
555713 2022-008 - - L
555714 2022-008 - - L
1132138 2022-004 Material Weakness - A
1132139 2022-004 Material Weakness - A
1132140 2022-005 Significant Deficiency - L
1132141 2022-005 Significant Deficiency - L
1132142 2022-005 Significant Deficiency - L
1132143 2022-005 Significant Deficiency - L
1132144 2022-005 Significant Deficiency - L
1132145 2022-005 Significant Deficiency - L
1132146 2022-005 Significant Deficiency - L
1132147 2022-005 Significant Deficiency - L
1132148 2022-005 Significant Deficiency - L
1132149 2022-005 Significant Deficiency - L
1132150 2022-006 Significant Deficiency Yes I
1132151 2022-006 Significant Deficiency Yes I
1132152 2022-006 Significant Deficiency Yes I
1132153 2022-007 - - F
1132154 2022-007 - - F
1132155 2022-008 - - L
1132156 2022-008 - - L

Programs

ALN Program Spent Major Findings
21.027 Coronavirus State and Local Fiscal Recovery Funds $12.24M Yes 2
93.575 Child Care and Development Block Grant $1.65M Yes 1
20.205 Highway Planning and Construction $1.14M - 0
15.114 Indian Education Higher Education Grant $1.03M - 0
15.025 Services to Indian Children, Elderly and Families $938,881 - 0
84.299 Indian Education - Special Programs for Indian Children $839,504 - 0
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $751,720 Yes 1
93.237 Special Diabetes Program for Indians Diabetes Prevention and Treatment Projects $712,405 - 0
15.U01 477 Cluster (plan Year 1/1/2020-12/31/2023 $677,024 - 0
21.019 Coronavirus Relief Fund $650,424 - 0
93.441 Indian Self-Determination $553,439 - 0
84.250 American Indian Vocational Rehabilitation Services $538,085 - 0
15.130 Indian Education Assistance to Schools $532,440 - 0
10.567 Food Distribution Program on Indian Reservations $492,736 Yes 3
93.788 Opioid Str $476,392 - 0
14.862 Indian Community Development Block Grant Program $420,952 Yes 2
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $372,080 - 0
15.020 Aid to Tribal Governments $310,735 - 0
16.587 Violence Against Women Discretionary Grants for Indian Tribal Governments $305,643 - 0
93.568 Low-Income Home Energy Assistance $300,039 - 0
15.029 Tribal Courts $288,925 - 0
16.582 Crime Victim Assistance/discretionary Grants $268,008 - 0
15.144 Indian Child Welfare Act Title II Grants $265,523 - 0
11.307 Economic Adjustment Assistance $235,042 - 0
15.035 Forestry on Indian Lands $228,559 - 0
15.228 Blm Fuels Management and Community Fire Assistance Program Activities $224,609 - 0
20.509 Formula Grants for Rural Areas and Tribal Transit Program $158,689 - 0
16.750 Support for Adam Walsh Act Implementation Grant Program $132,254 - 0
93.047 Special Programs for the Aging, Title Vi, Part A, Grants to Indian Tribes, Part B, Grants to Native Hawaiians $116,809 - 0
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $115,526 - 0
16.608 Tribal Justice Systems $111,102 - 0
15.904 Historic Preservation Fund Grants-in-Aid $104,704 - 0
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $104,585 - 0
93.495 Community Health Workers for Public Health Response and Resilient $93,016 - 0
66.926 Indian Environmental General Assistance Program (gap) $88,002 - 0
93.612 Native American Programs $83,369 - 0
10.594 Food Distribution Program on Indian Reservations Nutrition Education Grants $78,216 - 0
93.600 Head Start $72,018 Yes 2
16.024 Tribal Sexual Assault Services Program $67,387 - 0
16.841 Voca Tribal Victim Services Set-Aside Program $61,973 - 0
66.419 Water Pollution Control State, Interstate, and Tribal Program Support $57,215 - 0
66.038 Training, Investigations, and Special Purpose Activities of Federally-Recognized Indian Tribes Consistent with the Clean Air Act (caa), Tribal Sovereignty and the Protection and Management of Air Quality $54,316 - 0
93.556 Marylee Allen Promoting Safe and Stable Families Program $50,533 - 0
93.499 Low Income Household Water Assistance Program $41,768 - 0
93.645 Stephanie Tubbs Jones Child Welfare Services Program $39,502 - 0
93.569 Community Services Block Grant $34,068 - 0
15.922 Native American Graves Protection and Repatriation Act $26,450 - 0
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $9,079 - 0
15.156 Tribal Climate Resilience $6,663 - 0
93.054 National Family Caregiver Support, Title Vi, Part C, Grants to Indian Tribes and Native Hawaiians $6,560 - 0
66.818 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements $2,182 - 0
15.954 National Park Service Conservation, Protection, Outreach, and Education $1,599 - 0
84.415 Indian Education National Activities (state Tribal Education Partnership (step) and Native American Language (nal) $1,214 - 0
84.060 Indian Education Grants to Local Educational Agencies $433 - 0

Contacts

Name Title Type
K26TL2SG17E7 Kayla Tallbear Auditee
4054227614 Jodie Cates Auditor
No contacts on file

Notes to SEFA

Title: Note 1: General Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts, if any, shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Department has elected not to use the 10 percent de minimus indirect cost rate and instead utilizes an indirect cost rate as allowed under the Uniform Guidance. The accompanying Schedule of Expenditures of Federal Awards (Schedule) presents the federal financial assistance programs of the Cheyenne and Arapaho Tribes of Oklahoma Governmental Programs Department (the Department) which is a department of the Cheyenne and Arapaho Tribes of Oklahoma (the Tribe). The Department administers all federal and state grants and contracts received by the Tribe. The reporting entity is defined in Note 1 to the Department's financial statements.
Title: Note 2: Basis of Accounting Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts, if any, shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Department has elected not to use the 10 percent de minimus indirect cost rate and instead utilizes an indirect cost rate as allowed under the Uniform Guidance. This schedule includes the federal awards activity of the tribe under programs of the federal government for the year ended December 31, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the tribe, it is not intended to and does not present the financial position, changes in fund balance/net position or cash flows of the tribe.
Title: Note 3: Summary of Significant Accounting Policies Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts, if any, shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Department has elected not to use the 10 percent de minimus indirect cost rate and instead utilizes an indirect cost rate as allowed under the Uniform Guidance. Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts, if any, shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. The Department has elected not to use the 10 percent de minimus indirect cost rate and instead utilizes an indirect cost rate as allowed under the Uniform Guidance.
Title: Note 4: Subrecipients and Outstanding Federal Loans Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts, if any, shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Department has elected not to use the 10 percent de minimus indirect cost rate and instead utilizes an indirect cost rate as allowed under the Uniform Guidance. Of the expenditures presented in the Schedule, the Department provided no awards to subrecipients. There were no outstanding federal loans on December 31, 2022.
Title: Note 5: 477 Cluster Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts, if any, shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Department has elected not to use the 10 percent de minimus indirect cost rate and instead utilizes an indirect cost rate as allowed under the Uniform Guidance. The Department has entered into a four-year 477 agreement. The four-year agreement began on January 1, 2020 and ends December 31, 2023. The Schedule presents the 477 cluster under the Bureau of Indian Affairs as a single line and includes the following programs: See the Notes to SEFA for chart/table.
Title: Note 6: Reconciliation of Schedule of Expenditures of Federal Awards to Financial Statements Accounting Policies: Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. Negative amounts, if any, shown on the Schedule represent adjustments or credits made in the normal course of business to amounts reported as expenditures in prior years. De Minimis Rate Used: N Rate Explanation: The Department has elected not to use the 10 percent de minimus indirect cost rate and instead utilizes an indirect cost rate as allowed under the Uniform Guidance. The following is a reconciliation of the expenditures reported on the Schedule to the expenditures reported in the financial statements: See the Notes to SEFA for chart/table.

Finding Details

Finding 2022-004
Finding: Allowable Costs/Cost Principles (Material Noncompliance; Material Weakness) Federal Assistance Listing Number 93.600 – Head Start Cluster Award Number – 90CI01001401C3, 90CI010014-02-02, 90HA0008601C6, 90HA00008601C5, 90C101001403, & 90C101001404; Award Year 2020, 2021, & 2022 Criteria: According to 45 CFR sections 75.403, 75.404, and 75.405 costs must meet general allowability criteria, including being necessary and reasonable for the performance of the federal award, allocable thereto and adequately documented. Condition: The Department did not have adequate documentation to support the recoding of certain expenditures from a nonfederal fund to the Headstart program. Questioned Costs: None Context: The Department was unable to provide supporting documentation for $25,467 for one of 25 items sampled. Further review by the Department identified similar unsupported expenditures for a total of $169,339. While these expenditures were included in the original schedule of expenditure of federal awards and expenditure population for the program, they had not been drawn down or reported to the federal agency. Therefore, no questioned costs are being reported. A non-statistical sampling methodology was used to select the sample. Effect: Without the appropriate supporting documentation, the Department is unable to ensure the expenditure is coded to the proper Federal award or fund and the Department was not in compliance with the Uniform Guidance. Further, adjustments to the program's financial records and the schedule of expenditures of federal awards were required. Cause: The Department attempted to reallocate expenditures based on allowable and available funding sources but failed to maintain an adequate audit trail. Identification as a Repeat Finding: N/A Recommendation: We recommend the Department implement a control to ensure adequate supporting documentation exists for any reallocation of expenditures impacting federal funding. Viewed of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-004
Finding: Allowable Costs/Cost Principles (Material Noncompliance; Material Weakness) Federal Assistance Listing Number 93.600 – Head Start Cluster Award Number – 90CI01001401C3, 90CI010014-02-02, 90HA0008601C6, 90HA00008601C5, 90C101001403, & 90C101001404; Award Year 2020, 2021, & 2022 Criteria: According to 45 CFR sections 75.403, 75.404, and 75.405 costs must meet general allowability criteria, including being necessary and reasonable for the performance of the federal award, allocable thereto and adequately documented. Condition: The Department did not have adequate documentation to support the recoding of certain expenditures from a nonfederal fund to the Headstart program. Questioned Costs: None Context: The Department was unable to provide supporting documentation for $25,467 for one of 25 items sampled. Further review by the Department identified similar unsupported expenditures for a total of $169,339. While these expenditures were included in the original schedule of expenditure of federal awards and expenditure population for the program, they had not been drawn down or reported to the federal agency. Therefore, no questioned costs are being reported. A non-statistical sampling methodology was used to select the sample. Effect: Without the appropriate supporting documentation, the Department is unable to ensure the expenditure is coded to the proper Federal award or fund and the Department was not in compliance with the Uniform Guidance. Further, adjustments to the program's financial records and the schedule of expenditures of federal awards were required. Cause: The Department attempted to reallocate expenditures based on allowable and available funding sources but failed to maintain an adequate audit trail. Identification as a Repeat Finding: N/A Recommendation: We recommend the Department implement a control to ensure adequate supporting documentation exists for any reallocation of expenditures impacting federal funding. Viewed of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-006
Finding: Procurement, Suspension and Debarment (Significant Deficiency; Other Matter) Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Number – B-18-SR-40-0584 & B-19-SR-40-0584; Award Year 2018 & 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Number – 8L-SS-2021-0901-001; Award Year 2021 Suspension and Debarment Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart C, 200.214 - Recipients and subrecipients are subject to the procurement, debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR Part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Procurement Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart D, 200.321 - When possible, the recipient or subrecipient should ensure there is open competition for non-micro purchases and an equitable distribution among suppliers for micro purchases. Condition: The Tribe was unable to provide supporting documentation showing that a verification had been performed to ensure vendors were not suspended or debarred. Several large purchases were sole sourced without adequate documentation. A high volume of micro purchases were made from the same vendor rather than being distributed equitably amount a variety of vendors. Questioned Costs: None. Context: 14.862 - Three procurements were tested noting two in which suspension and debarment checks were not performed. A high volume of micro purchases ($148,908) were made from the same vendor rather than an equitable distribution of vendors. 21.027 - 14 procurements were tested. Ten procurements tested were subject to suspension and debarment of which checks were not performed on nine. All 14 procurements tested were subject to non-micro purchase requirements. Six procurements were sole sourced without adequate supporting documentation to support this method of purchase. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe's inability to furnish supporting documentation showing that a check to ensure vendors were not suspended or debarred on SAM.gov could result in the use of ineligible vendors. The Tribe's failure to provide for open competition or provide for an equitable distribution of vendors on purchases could result in the Tribe paying more for services than is reasonable or necessary. Cause: Tribal policies were not followed surrounding the requirement of suspension and debarment checks and documentation of sole source procurements. Due to the Tribal location, there may be some limitation of available vendors for consideration to ensure an equitable distribution. Identification as a Repeat Finding: 2021-005 (same issue in different program) Recommendation: We recommend the Department ensure existing procurement, suspension and debarment policies are understood throughout the Tribe and supporting documentation is adequate and maintained for all procurement decisions. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-006
Finding: Procurement, Suspension and Debarment (Significant Deficiency; Other Matter) Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Number – B-18-SR-40-0584 & B-19-SR-40-0584; Award Year 2018 & 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Number – 8L-SS-2021-0901-001; Award Year 2021 Suspension and Debarment Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart C, 200.214 - Recipients and subrecipients are subject to the procurement, debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR Part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Procurement Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart D, 200.321 - When possible, the recipient or subrecipient should ensure there is open competition for non-micro purchases and an equitable distribution among suppliers for micro purchases. Condition: The Tribe was unable to provide supporting documentation showing that a verification had been performed to ensure vendors were not suspended or debarred. Several large purchases were sole sourced without adequate documentation. A high volume of micro purchases were made from the same vendor rather than being distributed equitably amount a variety of vendors. Questioned Costs: None. Context: 14.862 - Three procurements were tested noting two in which suspension and debarment checks were not performed. A high volume of micro purchases ($148,908) were made from the same vendor rather than an equitable distribution of vendors. 21.027 - 14 procurements were tested. Ten procurements tested were subject to suspension and debarment of which checks were not performed on nine. All 14 procurements tested were subject to non-micro purchase requirements. Six procurements were sole sourced without adequate supporting documentation to support this method of purchase. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe's inability to furnish supporting documentation showing that a check to ensure vendors were not suspended or debarred on SAM.gov could result in the use of ineligible vendors. The Tribe's failure to provide for open competition or provide for an equitable distribution of vendors on purchases could result in the Tribe paying more for services than is reasonable or necessary. Cause: Tribal policies were not followed surrounding the requirement of suspension and debarment checks and documentation of sole source procurements. Due to the Tribal location, there may be some limitation of available vendors for consideration to ensure an equitable distribution. Identification as a Repeat Finding: 2021-005 (same issue in different program) Recommendation: We recommend the Department ensure existing procurement, suspension and debarment policies are understood throughout the Tribe and supporting documentation is adequate and maintained for all procurement decisions. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-006
Finding: Procurement, Suspension and Debarment (Significant Deficiency; Other Matter) Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Number – B-18-SR-40-0584 & B-19-SR-40-0584; Award Year 2018 & 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Number – 8L-SS-2021-0901-001; Award Year 2021 Suspension and Debarment Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart C, 200.214 - Recipients and subrecipients are subject to the procurement, debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR Part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Procurement Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart D, 200.321 - When possible, the recipient or subrecipient should ensure there is open competition for non-micro purchases and an equitable distribution among suppliers for micro purchases. Condition: The Tribe was unable to provide supporting documentation showing that a verification had been performed to ensure vendors were not suspended or debarred. Several large purchases were sole sourced without adequate documentation. A high volume of micro purchases were made from the same vendor rather than being distributed equitably amount a variety of vendors. Questioned Costs: None. Context: 14.862 - Three procurements were tested noting two in which suspension and debarment checks were not performed. A high volume of micro purchases ($148,908) were made from the same vendor rather than an equitable distribution of vendors. 21.027 - 14 procurements were tested. Ten procurements tested were subject to suspension and debarment of which checks were not performed on nine. All 14 procurements tested were subject to non-micro purchase requirements. Six procurements were sole sourced without adequate supporting documentation to support this method of purchase. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe's inability to furnish supporting documentation showing that a check to ensure vendors were not suspended or debarred on SAM.gov could result in the use of ineligible vendors. The Tribe's failure to provide for open competition or provide for an equitable distribution of vendors on purchases could result in the Tribe paying more for services than is reasonable or necessary. Cause: Tribal policies were not followed surrounding the requirement of suspension and debarment checks and documentation of sole source procurements. Due to the Tribal location, there may be some limitation of available vendors for consideration to ensure an equitable distribution. Identification as a Repeat Finding: 2021-005 (same issue in different program) Recommendation: We recommend the Department ensure existing procurement, suspension and debarment policies are understood throughout the Tribe and supporting documentation is adequate and maintained for all procurement decisions. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-007
Finding: Equipment and Real Property Management (Other Matter) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Criteria: According to 48 CFR 52.245-1, a system of internal controls to manage federal property and a process to enable the prompt recognition, investigation, disclosure and reporting of loss of federal government property should be in place. Condition: An item paid for with federal funding was not identified as federal in the inventory listing. Questioned Costs: None. Context: One of five equipment items tested was not properly identified as federal in the inventory listing. A non-statistical sampling methodology was used to select the sample. Effect: Failure to properly identify federally funded equipment in the inventory listings could result in failure to disclose loss of property to the federal government if such should occur or in the inappropriate handling of proceeds should the property be sold. Cause: The funding source for the equipment in question was changed from nonfederal to federal and the inventory listing was inadvertently not updated. Identification as a Repeat Finding: N/A Recommendation: We recommend the Department ensure procedures are in place to ensure that all equipment funded with federal funds is properly identified in the inventory listings and that any changes in funding after the initial purchase are also properly reflected. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-007
Finding: Equipment and Real Property Management (Other Matter) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Criteria: According to 48 CFR 52.245-1, a system of internal controls to manage federal property and a process to enable the prompt recognition, investigation, disclosure and reporting of loss of federal government property should be in place. Condition: An item paid for with federal funding was not identified as federal in the inventory listing. Questioned Costs: None. Context: One of five equipment items tested was not properly identified as federal in the inventory listing. A non-statistical sampling methodology was used to select the sample. Effect: Failure to properly identify federally funded equipment in the inventory listings could result in failure to disclose loss of property to the federal government if such should occur or in the inappropriate handling of proceeds should the property be sold. Cause: The funding source for the equipment in question was changed from nonfederal to federal and the inventory listing was inadvertently not updated. Identification as a Repeat Finding: N/A Recommendation: We recommend the Department ensure procedures are in place to ensure that all equipment funded with federal funds is properly identified in the inventory listings and that any changes in funding after the initial purchase are also properly reflected. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-008
Finding: Reporting (Other Matter) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Criteria or Specific Requirement: According to Chapter I Section 5 - Records and Reporting of the FNS Handbook 501, the Tribe is required to mail, fax, or electronically transmit a completed copy of form FNS-101, Participation in Food Programs - By Race, to be received by the appropriate FNS Regional Office by September 15 of each year. Further, the FNS-152, Monthly Distribution of Donated Foods to Family Units, must be received in the appropriate FNS Regional Office by the 15th date of the month following the month in which the USDA foods were distributed. Condition: Both the FNS-101 form and the FMS-152 form were submitted subsequent to the required deadlines. Questioned Costs: None. Context: The FNS-101 form required to be received by September 15, 2022 was not submitted until September 21, 2022. The FNS-152 required to be submitted by February 15, 2022 was not submitted until March 24, 2022. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe is out of compliance with federal requirements and the awarding agency does not have timely information for evaluating programmatic results. Identification as a Repeat Finding: N/A Cause: Additional responsibilities absorbed by program director resulted in shifting priorities away from reporting deadline. Recommendation: We recommend that program personnel continue to implement policies and procedures that prioritize the federal reporting functions as needed in order to submit reports within the required timelines. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-008
Finding: Reporting (Other Matter) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Criteria or Specific Requirement: According to Chapter I Section 5 - Records and Reporting of the FNS Handbook 501, the Tribe is required to mail, fax, or electronically transmit a completed copy of form FNS-101, Participation in Food Programs - By Race, to be received by the appropriate FNS Regional Office by September 15 of each year. Further, the FNS-152, Monthly Distribution of Donated Foods to Family Units, must be received in the appropriate FNS Regional Office by the 15th date of the month following the month in which the USDA foods were distributed. Condition: Both the FNS-101 form and the FMS-152 form were submitted subsequent to the required deadlines. Questioned Costs: None. Context: The FNS-101 form required to be received by September 15, 2022 was not submitted until September 21, 2022. The FNS-152 required to be submitted by February 15, 2022 was not submitted until March 24, 2022. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe is out of compliance with federal requirements and the awarding agency does not have timely information for evaluating programmatic results. Identification as a Repeat Finding: N/A Cause: Additional responsibilities absorbed by program director resulted in shifting priorities away from reporting deadline. Recommendation: We recommend that program personnel continue to implement policies and procedures that prioritize the federal reporting functions as needed in order to submit reports within the required timelines. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-004
Finding: Allowable Costs/Cost Principles (Material Noncompliance; Material Weakness) Federal Assistance Listing Number 93.600 – Head Start Cluster Award Number – 90CI01001401C3, 90CI010014-02-02, 90HA0008601C6, 90HA00008601C5, 90C101001403, & 90C101001404; Award Year 2020, 2021, & 2022 Criteria: According to 45 CFR sections 75.403, 75.404, and 75.405 costs must meet general allowability criteria, including being necessary and reasonable for the performance of the federal award, allocable thereto and adequately documented. Condition: The Department did not have adequate documentation to support the recoding of certain expenditures from a nonfederal fund to the Headstart program. Questioned Costs: None Context: The Department was unable to provide supporting documentation for $25,467 for one of 25 items sampled. Further review by the Department identified similar unsupported expenditures for a total of $169,339. While these expenditures were included in the original schedule of expenditure of federal awards and expenditure population for the program, they had not been drawn down or reported to the federal agency. Therefore, no questioned costs are being reported. A non-statistical sampling methodology was used to select the sample. Effect: Without the appropriate supporting documentation, the Department is unable to ensure the expenditure is coded to the proper Federal award or fund and the Department was not in compliance with the Uniform Guidance. Further, adjustments to the program's financial records and the schedule of expenditures of federal awards were required. Cause: The Department attempted to reallocate expenditures based on allowable and available funding sources but failed to maintain an adequate audit trail. Identification as a Repeat Finding: N/A Recommendation: We recommend the Department implement a control to ensure adequate supporting documentation exists for any reallocation of expenditures impacting federal funding. Viewed of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-004
Finding: Allowable Costs/Cost Principles (Material Noncompliance; Material Weakness) Federal Assistance Listing Number 93.600 – Head Start Cluster Award Number – 90CI01001401C3, 90CI010014-02-02, 90HA0008601C6, 90HA00008601C5, 90C101001403, & 90C101001404; Award Year 2020, 2021, & 2022 Criteria: According to 45 CFR sections 75.403, 75.404, and 75.405 costs must meet general allowability criteria, including being necessary and reasonable for the performance of the federal award, allocable thereto and adequately documented. Condition: The Department did not have adequate documentation to support the recoding of certain expenditures from a nonfederal fund to the Headstart program. Questioned Costs: None Context: The Department was unable to provide supporting documentation for $25,467 for one of 25 items sampled. Further review by the Department identified similar unsupported expenditures for a total of $169,339. While these expenditures were included in the original schedule of expenditure of federal awards and expenditure population for the program, they had not been drawn down or reported to the federal agency. Therefore, no questioned costs are being reported. A non-statistical sampling methodology was used to select the sample. Effect: Without the appropriate supporting documentation, the Department is unable to ensure the expenditure is coded to the proper Federal award or fund and the Department was not in compliance with the Uniform Guidance. Further, adjustments to the program's financial records and the schedule of expenditures of federal awards were required. Cause: The Department attempted to reallocate expenditures based on allowable and available funding sources but failed to maintain an adequate audit trail. Identification as a Repeat Finding: N/A Recommendation: We recommend the Department implement a control to ensure adequate supporting documentation exists for any reallocation of expenditures impacting federal funding. Viewed of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-005
Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-006
Finding: Procurement, Suspension and Debarment (Significant Deficiency; Other Matter) Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Number – B-18-SR-40-0584 & B-19-SR-40-0584; Award Year 2018 & 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Number – 8L-SS-2021-0901-001; Award Year 2021 Suspension and Debarment Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart C, 200.214 - Recipients and subrecipients are subject to the procurement, debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR Part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Procurement Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart D, 200.321 - When possible, the recipient or subrecipient should ensure there is open competition for non-micro purchases and an equitable distribution among suppliers for micro purchases. Condition: The Tribe was unable to provide supporting documentation showing that a verification had been performed to ensure vendors were not suspended or debarred. Several large purchases were sole sourced without adequate documentation. A high volume of micro purchases were made from the same vendor rather than being distributed equitably amount a variety of vendors. Questioned Costs: None. Context: 14.862 - Three procurements were tested noting two in which suspension and debarment checks were not performed. A high volume of micro purchases ($148,908) were made from the same vendor rather than an equitable distribution of vendors. 21.027 - 14 procurements were tested. Ten procurements tested were subject to suspension and debarment of which checks were not performed on nine. All 14 procurements tested were subject to non-micro purchase requirements. Six procurements were sole sourced without adequate supporting documentation to support this method of purchase. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe's inability to furnish supporting documentation showing that a check to ensure vendors were not suspended or debarred on SAM.gov could result in the use of ineligible vendors. The Tribe's failure to provide for open competition or provide for an equitable distribution of vendors on purchases could result in the Tribe paying more for services than is reasonable or necessary. Cause: Tribal policies were not followed surrounding the requirement of suspension and debarment checks and documentation of sole source procurements. Due to the Tribal location, there may be some limitation of available vendors for consideration to ensure an equitable distribution. Identification as a Repeat Finding: 2021-005 (same issue in different program) Recommendation: We recommend the Department ensure existing procurement, suspension and debarment policies are understood throughout the Tribe and supporting documentation is adequate and maintained for all procurement decisions. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-006
Finding: Procurement, Suspension and Debarment (Significant Deficiency; Other Matter) Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Number – B-18-SR-40-0584 & B-19-SR-40-0584; Award Year 2018 & 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Number – 8L-SS-2021-0901-001; Award Year 2021 Suspension and Debarment Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart C, 200.214 - Recipients and subrecipients are subject to the procurement, debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR Part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Procurement Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart D, 200.321 - When possible, the recipient or subrecipient should ensure there is open competition for non-micro purchases and an equitable distribution among suppliers for micro purchases. Condition: The Tribe was unable to provide supporting documentation showing that a verification had been performed to ensure vendors were not suspended or debarred. Several large purchases were sole sourced without adequate documentation. A high volume of micro purchases were made from the same vendor rather than being distributed equitably amount a variety of vendors. Questioned Costs: None. Context: 14.862 - Three procurements were tested noting two in which suspension and debarment checks were not performed. A high volume of micro purchases ($148,908) were made from the same vendor rather than an equitable distribution of vendors. 21.027 - 14 procurements were tested. Ten procurements tested were subject to suspension and debarment of which checks were not performed on nine. All 14 procurements tested were subject to non-micro purchase requirements. Six procurements were sole sourced without adequate supporting documentation to support this method of purchase. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe's inability to furnish supporting documentation showing that a check to ensure vendors were not suspended or debarred on SAM.gov could result in the use of ineligible vendors. The Tribe's failure to provide for open competition or provide for an equitable distribution of vendors on purchases could result in the Tribe paying more for services than is reasonable or necessary. Cause: Tribal policies were not followed surrounding the requirement of suspension and debarment checks and documentation of sole source procurements. Due to the Tribal location, there may be some limitation of available vendors for consideration to ensure an equitable distribution. Identification as a Repeat Finding: 2021-005 (same issue in different program) Recommendation: We recommend the Department ensure existing procurement, suspension and debarment policies are understood throughout the Tribe and supporting documentation is adequate and maintained for all procurement decisions. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-006
Finding: Procurement, Suspension and Debarment (Significant Deficiency; Other Matter) Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Number – B-18-SR-40-0584 & B-19-SR-40-0584; Award Year 2018 & 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Number – 8L-SS-2021-0901-001; Award Year 2021 Suspension and Debarment Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart C, 200.214 - Recipients and subrecipients are subject to the procurement, debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR Part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Procurement Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart D, 200.321 - When possible, the recipient or subrecipient should ensure there is open competition for non-micro purchases and an equitable distribution among suppliers for micro purchases. Condition: The Tribe was unable to provide supporting documentation showing that a verification had been performed to ensure vendors were not suspended or debarred. Several large purchases were sole sourced without adequate documentation. A high volume of micro purchases were made from the same vendor rather than being distributed equitably amount a variety of vendors. Questioned Costs: None. Context: 14.862 - Three procurements were tested noting two in which suspension and debarment checks were not performed. A high volume of micro purchases ($148,908) were made from the same vendor rather than an equitable distribution of vendors. 21.027 - 14 procurements were tested. Ten procurements tested were subject to suspension and debarment of which checks were not performed on nine. All 14 procurements tested were subject to non-micro purchase requirements. Six procurements were sole sourced without adequate supporting documentation to support this method of purchase. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe's inability to furnish supporting documentation showing that a check to ensure vendors were not suspended or debarred on SAM.gov could result in the use of ineligible vendors. The Tribe's failure to provide for open competition or provide for an equitable distribution of vendors on purchases could result in the Tribe paying more for services than is reasonable or necessary. Cause: Tribal policies were not followed surrounding the requirement of suspension and debarment checks and documentation of sole source procurements. Due to the Tribal location, there may be some limitation of available vendors for consideration to ensure an equitable distribution. Identification as a Repeat Finding: 2021-005 (same issue in different program) Recommendation: We recommend the Department ensure existing procurement, suspension and debarment policies are understood throughout the Tribe and supporting documentation is adequate and maintained for all procurement decisions. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-007
Finding: Equipment and Real Property Management (Other Matter) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Criteria: According to 48 CFR 52.245-1, a system of internal controls to manage federal property and a process to enable the prompt recognition, investigation, disclosure and reporting of loss of federal government property should be in place. Condition: An item paid for with federal funding was not identified as federal in the inventory listing. Questioned Costs: None. Context: One of five equipment items tested was not properly identified as federal in the inventory listing. A non-statistical sampling methodology was used to select the sample. Effect: Failure to properly identify federally funded equipment in the inventory listings could result in failure to disclose loss of property to the federal government if such should occur or in the inappropriate handling of proceeds should the property be sold. Cause: The funding source for the equipment in question was changed from nonfederal to federal and the inventory listing was inadvertently not updated. Identification as a Repeat Finding: N/A Recommendation: We recommend the Department ensure procedures are in place to ensure that all equipment funded with federal funds is properly identified in the inventory listings and that any changes in funding after the initial purchase are also properly reflected. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-007
Finding: Equipment and Real Property Management (Other Matter) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Criteria: According to 48 CFR 52.245-1, a system of internal controls to manage federal property and a process to enable the prompt recognition, investigation, disclosure and reporting of loss of federal government property should be in place. Condition: An item paid for with federal funding was not identified as federal in the inventory listing. Questioned Costs: None. Context: One of five equipment items tested was not properly identified as federal in the inventory listing. A non-statistical sampling methodology was used to select the sample. Effect: Failure to properly identify federally funded equipment in the inventory listings could result in failure to disclose loss of property to the federal government if such should occur or in the inappropriate handling of proceeds should the property be sold. Cause: The funding source for the equipment in question was changed from nonfederal to federal and the inventory listing was inadvertently not updated. Identification as a Repeat Finding: N/A Recommendation: We recommend the Department ensure procedures are in place to ensure that all equipment funded with federal funds is properly identified in the inventory listings and that any changes in funding after the initial purchase are also properly reflected. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-008
Finding: Reporting (Other Matter) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Criteria or Specific Requirement: According to Chapter I Section 5 - Records and Reporting of the FNS Handbook 501, the Tribe is required to mail, fax, or electronically transmit a completed copy of form FNS-101, Participation in Food Programs - By Race, to be received by the appropriate FNS Regional Office by September 15 of each year. Further, the FNS-152, Monthly Distribution of Donated Foods to Family Units, must be received in the appropriate FNS Regional Office by the 15th date of the month following the month in which the USDA foods were distributed. Condition: Both the FNS-101 form and the FMS-152 form were submitted subsequent to the required deadlines. Questioned Costs: None. Context: The FNS-101 form required to be received by September 15, 2022 was not submitted until September 21, 2022. The FNS-152 required to be submitted by February 15, 2022 was not submitted until March 24, 2022. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe is out of compliance with federal requirements and the awarding agency does not have timely information for evaluating programmatic results. Identification as a Repeat Finding: N/A Cause: Additional responsibilities absorbed by program director resulted in shifting priorities away from reporting deadline. Recommendation: We recommend that program personnel continue to implement policies and procedures that prioritize the federal reporting functions as needed in order to submit reports within the required timelines. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.
Finding 2022-008
Finding: Reporting (Other Matter) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Criteria or Specific Requirement: According to Chapter I Section 5 - Records and Reporting of the FNS Handbook 501, the Tribe is required to mail, fax, or electronically transmit a completed copy of form FNS-101, Participation in Food Programs - By Race, to be received by the appropriate FNS Regional Office by September 15 of each year. Further, the FNS-152, Monthly Distribution of Donated Foods to Family Units, must be received in the appropriate FNS Regional Office by the 15th date of the month following the month in which the USDA foods were distributed. Condition: Both the FNS-101 form and the FMS-152 form were submitted subsequent to the required deadlines. Questioned Costs: None. Context: The FNS-101 form required to be received by September 15, 2022 was not submitted until September 21, 2022. The FNS-152 required to be submitted by February 15, 2022 was not submitted until March 24, 2022. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe is out of compliance with federal requirements and the awarding agency does not have timely information for evaluating programmatic results. Identification as a Repeat Finding: N/A Cause: Additional responsibilities absorbed by program director resulted in shifting priorities away from reporting deadline. Recommendation: We recommend that program personnel continue to implement policies and procedures that prioritize the federal reporting functions as needed in order to submit reports within the required timelines. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.