Audit 364856

Reporting Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.594 Program Name: Tribal Work Grants Criteria A good system of internal accounting control contemplates an adequate system for ensuring that all reports are completed and submitted accurately. Condition During the course of our engagement, we noted that the controls surrounding the reporting function of these programs were not being properly segregated. There was no review being performed to ensure that all required reports were submitted accurately. We also noted two SF- 425 reports were not submitted prior to the deadline. Cause The Tribe does not have an internal control system designed to ensure all reports are submitted timely and are reviewed by an individual separate from the person preparing the reports. Effect The control deficiency could result in the Tribe’s reports within these programs not being completed accurately or filed on time. Questioned Costs None reported. Context There were four (4) quarterly reports required to be filed during the year. All four (4) of these were tested and were found to have segregation of duties issues. In addition, two (2) of these were found to have been submitted after the deadline. Recommendation Management should put procedures in place to ensure that all reports are reviewed and documented as well as filed timely. Repeat Finding This is a repeat finding of 2019-008. Management's Response The Tribe will work on procedures to ensure that all reports are reviewed by an individual separate from the person preparing the report and filed timely.

Reporting Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.594 Program Name: Tribal Work Grants Criteria A good system of internal accounting control contemplates an adequate system for ensuring that all reports are completed and submitted accurately. Condition During the course of our engagement, we noted that the controls surrounding the reporting function of these programs were not being properly segregated. There was no review being performed to ensure that all required reports were submitted accurately. We also noted two SF- 425 reports were not submitted prior to the deadline. Cause The Tribe does not have an internal control system designed to ensure all reports are submitted timely and are reviewed by an individual separate from the person preparing the reports. Effect The control deficiency could result in the Tribe’s reports within these programs not being completed accurately or filed on time. Questioned Costs None reported. Context There were four (4) quarterly reports required to be filed during the year. All four (4) of these were tested and were found to have segregation of duties issues. In addition, two (2) of these were found to have been submitted after the deadline. Recommendation Management should put procedures in place to ensure that all reports are reviewed and documented as well as filed timely. Repeat Finding This is a repeat finding of 2019-008. Management's Response The Tribe will work on procedures to ensure that all reports are reviewed by an individual separate from the person preparing the report and filed timely.

Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.044; 93.045; 93.053 Program Name: Aging Cluster Criteria The Aging Cluster compliance supplement requires monitoring to be performed on all subrecipients. The Tribe did not perform monitoring on subrecipients including: review of subrecipient program; review of subrecipient expenditures incurred; or review of subrecipient audited financial statements. Condition The Tribe did not properly perform subrecipient monitoring. Cause The Tribe does not have sufficient procedures in place to ensure proper subrecipient monitoring is being conducted. Effect The Tribe was not in compliance with subrecipient compliance requirements. Questioned Costs Undeterminable. Context During our testing of the program, it was noted the Tribe had not performed any subrecipient monitoring over the course of the fiscal year. Recommendation Management should implement procedures and policies regarding the monitoring of subrecipient activities. Repeat Finding This is a repeat finding of 2019-009. Management’s Response The Tribe will work on developing and implementing procedures and policies regarding the monitoring of subrecipient activities.

Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.044; 93.045; 93.053 Program Name: Aging Cluster Criteria The Aging Cluster compliance supplement requires monitoring to be performed on all subrecipients. The Tribe did not perform monitoring on subrecipients including: review of subrecipient program; review of subrecipient expenditures incurred; or review of subrecipient audited financial statements. Condition The Tribe did not properly perform subrecipient monitoring. Cause The Tribe does not have sufficient procedures in place to ensure proper subrecipient monitoring is being conducted. Effect The Tribe was not in compliance with subrecipient compliance requirements. Questioned Costs Undeterminable. Context During our testing of the program, it was noted the Tribe had not performed any subrecipient monitoring over the course of the fiscal year. Recommendation Management should implement procedures and policies regarding the monitoring of subrecipient activities. Repeat Finding This is a repeat finding of 2019-009. Management’s Response The Tribe will work on developing and implementing procedures and policies regarding the monitoring of subrecipient activities.

Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.044; 93.045; 93.053 Program Name: Aging Cluster Criteria The Aging Cluster compliance supplement requires monitoring to be performed on all subrecipients. The Tribe did not perform monitoring on subrecipients including: review of subrecipient program; review of subrecipient expenditures incurred; or review of subrecipient audited financial statements. Condition The Tribe did not properly perform subrecipient monitoring. Cause The Tribe does not have sufficient procedures in place to ensure proper subrecipient monitoring is being conducted. Effect The Tribe was not in compliance with subrecipient compliance requirements. Questioned Costs Undeterminable. Context During our testing of the program, it was noted the Tribe had not performed any subrecipient monitoring over the course of the fiscal year. Recommendation Management should implement procedures and policies regarding the monitoring of subrecipient activities. Repeat Finding This is a repeat finding of 2019-009. Management’s Response The Tribe will work on developing and implementing procedures and policies regarding the monitoring of subrecipient activities.

Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.044; 93.045; 93.053 Program Name: Aging Cluster Criteria The Aging Cluster compliance supplement requires monitoring to be performed on all subrecipients. The Tribe did not perform monitoring on subrecipients including: review of subrecipient program; review of subrecipient expenditures incurred; or review of subrecipient audited financial statements. Condition The Tribe did not properly perform subrecipient monitoring. Cause The Tribe does not have sufficient procedures in place to ensure proper subrecipient monitoring is being conducted. Effect The Tribe was not in compliance with subrecipient compliance requirements. Questioned Costs Undeterminable. Context During our testing of the program, it was noted the Tribe had not performed any subrecipient monitoring over the course of the fiscal year. Recommendation Management should implement procedures and policies regarding the monitoring of subrecipient activities. Repeat Finding This is a repeat finding of 2019-009. Management’s Response The Tribe will work on developing and implementing procedures and policies regarding the monitoring of subrecipient activities.

Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.044; 93.045; 93.053 Program Name: Aging Cluster Criteria The Aging Cluster compliance supplement requires monitoring to be performed on all subrecipients. The Tribe did not perform monitoring on subrecipients including: review of subrecipient program; review of subrecipient expenditures incurred; or review of subrecipient audited financial statements. Condition The Tribe did not properly perform subrecipient monitoring. Cause The Tribe does not have sufficient procedures in place to ensure proper subrecipient monitoring is being conducted. Effect The Tribe was not in compliance with subrecipient compliance requirements. Questioned Costs Undeterminable. Context During our testing of the program, it was noted the Tribe had not performed any subrecipient monitoring over the course of the fiscal year. Recommendation Management should implement procedures and policies regarding the monitoring of subrecipient activities. Repeat Finding This is a repeat finding of 2019-009. Management’s Response The Tribe will work on developing and implementing procedures and policies regarding the monitoring of subrecipient activities.

Reporting Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.594 Program Name: Tribal Work Grants Criteria A good system of internal accounting control contemplates an adequate system for ensuring that all reports are completed and submitted accurately. Condition During the course of our engagement, we noted that the controls surrounding the reporting function of these programs were not being properly segregated. There was no review being performed to ensure that all required reports were submitted accurately. We also noted two SF- 425 reports were not submitted prior to the deadline. Cause The Tribe does not have an internal control system designed to ensure all reports are submitted timely and are reviewed by an individual separate from the person preparing the reports. Effect The control deficiency could result in the Tribe’s reports within these programs not being completed accurately or filed on time. Questioned Costs None reported. Context There were four (4) quarterly reports required to be filed during the year. All four (4) of these were tested and were found to have segregation of duties issues. In addition, two (2) of these were found to have been submitted after the deadline. Recommendation Management should put procedures in place to ensure that all reports are reviewed and documented as well as filed timely. Repeat Finding This is a repeat finding of 2019-008. Management's Response The Tribe will work on procedures to ensure that all reports are reviewed by an individual separate from the person preparing the report and filed timely.

Reporting Material Weakness in Internal Control over Compliance and Immaterial Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.594 Program Name: Tribal Work Grants Criteria A good system of internal accounting control contemplates an adequate system for ensuring that all reports are completed and submitted accurately. Condition During the course of our engagement, we noted that the controls surrounding the reporting function of these programs were not being properly segregated. There was no review being performed to ensure that all required reports were submitted accurately. We also noted two SF- 425 reports were not submitted prior to the deadline. Cause The Tribe does not have an internal control system designed to ensure all reports are submitted timely and are reviewed by an individual separate from the person preparing the reports. Effect The control deficiency could result in the Tribe’s reports within these programs not being completed accurately or filed on time. Questioned Costs None reported. Context There were four (4) quarterly reports required to be filed during the year. All four (4) of these were tested and were found to have segregation of duties issues. In addition, two (2) of these were found to have been submitted after the deadline. Recommendation Management should put procedures in place to ensure that all reports are reviewed and documented as well as filed timely. Repeat Finding This is a repeat finding of 2019-008. Management's Response The Tribe will work on procedures to ensure that all reports are reviewed by an individual separate from the person preparing the report and filed timely.

Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.044; 93.045; 93.053 Program Name: Aging Cluster Criteria The Aging Cluster compliance supplement requires monitoring to be performed on all subrecipients. The Tribe did not perform monitoring on subrecipients including: review of subrecipient program; review of subrecipient expenditures incurred; or review of subrecipient audited financial statements. Condition The Tribe did not properly perform subrecipient monitoring. Cause The Tribe does not have sufficient procedures in place to ensure proper subrecipient monitoring is being conducted. Effect The Tribe was not in compliance with subrecipient compliance requirements. Questioned Costs Undeterminable. Context During our testing of the program, it was noted the Tribe had not performed any subrecipient monitoring over the course of the fiscal year. Recommendation Management should implement procedures and policies regarding the monitoring of subrecipient activities. Repeat Finding This is a repeat finding of 2019-009. Management’s Response The Tribe will work on developing and implementing procedures and policies regarding the monitoring of subrecipient activities.

Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.044; 93.045; 93.053 Program Name: Aging Cluster Criteria The Aging Cluster compliance supplement requires monitoring to be performed on all subrecipients. The Tribe did not perform monitoring on subrecipients including: review of subrecipient program; review of subrecipient expenditures incurred; or review of subrecipient audited financial statements. Condition The Tribe did not properly perform subrecipient monitoring. Cause The Tribe does not have sufficient procedures in place to ensure proper subrecipient monitoring is being conducted. Effect The Tribe was not in compliance with subrecipient compliance requirements. Questioned Costs Undeterminable. Context During our testing of the program, it was noted the Tribe had not performed any subrecipient monitoring over the course of the fiscal year. Recommendation Management should implement procedures and policies regarding the monitoring of subrecipient activities. Repeat Finding This is a repeat finding of 2019-009. Management’s Response The Tribe will work on developing and implementing procedures and policies regarding the monitoring of subrecipient activities.

Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.044; 93.045; 93.053 Program Name: Aging Cluster Criteria The Aging Cluster compliance supplement requires monitoring to be performed on all subrecipients. The Tribe did not perform monitoring on subrecipients including: review of subrecipient program; review of subrecipient expenditures incurred; or review of subrecipient audited financial statements. Condition The Tribe did not properly perform subrecipient monitoring. Cause The Tribe does not have sufficient procedures in place to ensure proper subrecipient monitoring is being conducted. Effect The Tribe was not in compliance with subrecipient compliance requirements. Questioned Costs Undeterminable. Context During our testing of the program, it was noted the Tribe had not performed any subrecipient monitoring over the course of the fiscal year. Recommendation Management should implement procedures and policies regarding the monitoring of subrecipient activities. Repeat Finding This is a repeat finding of 2019-009. Management’s Response The Tribe will work on developing and implementing procedures and policies regarding the monitoring of subrecipient activities.

Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.044; 93.045; 93.053 Program Name: Aging Cluster Criteria The Aging Cluster compliance supplement requires monitoring to be performed on all subrecipients. The Tribe did not perform monitoring on subrecipients including: review of subrecipient program; review of subrecipient expenditures incurred; or review of subrecipient audited financial statements. Condition The Tribe did not properly perform subrecipient monitoring. Cause The Tribe does not have sufficient procedures in place to ensure proper subrecipient monitoring is being conducted. Effect The Tribe was not in compliance with subrecipient compliance requirements. Questioned Costs Undeterminable. Context During our testing of the program, it was noted the Tribe had not performed any subrecipient monitoring over the course of the fiscal year. Recommendation Management should implement procedures and policies regarding the monitoring of subrecipient activities. Repeat Finding This is a repeat finding of 2019-009. Management’s Response The Tribe will work on developing and implementing procedures and policies regarding the monitoring of subrecipient activities.

Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Instance of Noncompliance Federal Agency: U.S. Department of Health and Human Services CFDA Number: 93.044; 93.045; 93.053 Program Name: Aging Cluster Criteria The Aging Cluster compliance supplement requires monitoring to be performed on all subrecipients. The Tribe did not perform monitoring on subrecipients including: review of subrecipient program; review of subrecipient expenditures incurred; or review of subrecipient audited financial statements. Condition The Tribe did not properly perform subrecipient monitoring. Cause The Tribe does not have sufficient procedures in place to ensure proper subrecipient monitoring is being conducted. Effect The Tribe was not in compliance with subrecipient compliance requirements. Questioned Costs Undeterminable. Context During our testing of the program, it was noted the Tribe had not performed any subrecipient monitoring over the course of the fiscal year. Recommendation Management should implement procedures and policies regarding the monitoring of subrecipient activities. Repeat Finding This is a repeat finding of 2019-009. Management’s Response The Tribe will work on developing and implementing procedures and policies regarding the monitoring of subrecipient activities.