Audit 370119

Information on the Federal Program: Assistance Listing Number 81.086— Upper Midwest Inter‐Tribal EV Charging Community Network. Compliance Requirement: Allowable Costs and Cost Principles, Activities Allowed or Unallowed Type of Finding: Significant deficiency in internal control over compliance. Criteria: 2 CFR 200.303 of Subpart D, "Post Federal Award Requirements Standards for Financial and Program Management," of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award, including Activities Allowed or Unallowed, Allowable Costs and Cost Principles. Condition: Controls were not operating as designed to ensure that all expenditures charged to the federal program were reviewed and approved. Causes: For two out of ten tested, expenses charged to the federal grant had no documentation of a review and approval prior to the Organization submitting for reimbursement. The Organization relied on a control activity where the Program Director sent an email to the Executive Director for each expense to obtain approval prior to submitting reimbursements. No documented review and approval for this process being performed was available for two expenses upon request by the audit team. Effect or Potential Effect: Unallowable costs or activities could be charged to the grant. Questioned Costs: None Context: There was not sufficient documentation available upon request to support a review and approval process of reimbursement expenses allocated to the grant. The Organization implemented a payment software that includes review and approval features in July of the fiscal year under audit and no errors were found after the implementation. Repeat Finding: No Recommendation: We recommend the organization continue using their payment software for all transactions relating to federal grants and ensure that all expenses are being reviewed and approved through that software. Views of Responsible Officials: Agree.

Information on the Federal Program: Assistance Listing Number 81.086— Upper Midwest Inter‐Tribal EV Charging Community Network. Compliance Requirement: Matching Type of Finding: Significant deficiency in internal control over compliance. Criteria: 2 CFR 200.303 of Subpart D, "Post Federal Award Requirements Standards for Financial and Program Management," of the Uniform Guidance requires a nonfederal entity to establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award, including Cost Match principles. Condition: Controls were not implemented to monitor cost match partners’ activities to ensure their expenditures comply with allowable cost activities. Causes: For one of three cost matching amounts recorded in 2024, detail of amounts reported as cost match was not available upon request by auditors. It was obtained from the cost match partner, but the detail had not been obtained, reviewed, and approved by the Organization prior to being requested by auditors. Effect or Potential Effect: Unallowable costs or activities could be counted for cost match by match partners causing Native Sun to fall short of cost match requirements. Questioned Costs: None Context: The Organization did not initially have documentation with sufficient detail for expenses reported by cost match partners during 2024. Repeat Finding: Yes Recommendation: We recommend a control be implemented to monitor cost match partners including obtaining, reviewing and retaining support for reported cost match amounts. Views of Responsible Officials: Agree.

Information on the Federal Program: Assistance Listing Number 81.086— Upper Midwest Inter‐Tribal EV Charging Community Network. Compliance Requirement: Procurement Type of Finding: Noncompliance and significant deficiency in internal control over compliance. Criteria: 2 CFR Part 200, Subpart D item i: Procurement Records. The recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Condition: The Organization was not following its own procurement policy as sufficient records of quotes provided during large procurements were not available upon request. Causes: The Organization was not retaining adequate records of bids in accordance with their procurement policy. Effect or Potential Effect: The records for a formal bidding process for a fleet of electric vehicles and electric fitted garage which were expenses of $514,052 and $182,000 respectively. The Organization elected to single source, which is allowed in their procurement policy. However, adequate documentation of other bids or quotes solicited were not available upon request. The procurement policy was therefore not being followed for these instances. Questioned Costs: None Context: Certain purchases made by the Organization did not have adequate documentation that the procurement policy was followed. Repeat Finding: No Recommendation: We recommend the Organization document and retain records of all bids or quotes solicited in keeping with their procurement policy to ensure compliance. Views of Responsible Officials: Agree.

Information on the Federal Program: Assistance Listing Number 81.086— Upper Midwest Inter‐Tribal EV Charging Community Network. Compliance Requirement: Equipment and Real Property Type of Finding: Noncompliance and material weakness in internal control over compliance. Criteria: 2 CFR 200.313 item (d): Property Standards. Property records must include a description of the property, a serial number or another identification number, the source of funding for the property (including the FAIN), the title holder, the acquisition date, the cost of the property, the percentage of the Federal agency contribution towards the original purchase, the location, use and condition of the property, and any disposition data including the date of disposal and sale price of the property. The recipient and subrecipient are responsible for maintaining and updating property records when there is a change in the status of the property. Condition: For real property and equipment purchased with federal funding by Native Sun, adequate records and agreements were not kept. This included a lack of a listing as referenced above and a lack of agreement with beneficiaries of real property and equipment to ensure they remained in compliance with federal standards. Causes: The Organization was not retaining adequate records of equipment transferred to beneficiaries. Effect or Potential Effect: There could be equipment or real property purchased with federal funding that is not adequately accounted for or used outside of the bounds of the designated project use. There could also be equipment or real property unaccounted for or disposed of in a way that is not in compliance with federal standards. Large purchases of equipment including an electric bus and a bus garage lacked agreements that ensured that these items were accounted for in compliance with federal standards. Questioned Costs: None Context: The Organization did not have adequate controls in place to ensure that two of eight equipment and real property purchases tested were in compliance with federal guidelines. In addition, the organization was not able to provide an equipment list which included all required information at the beginning of the single audit process. Repeat Finding: No Recommendation: We recommend the Organization maintain a detailed listing of all real property and equipment purchased with federal funding that adheres to the criteria noted in 2 CFR Part 200. We also recommend the Organization have signed agreements dictating the treatment of real property and equipment with beneficiaries of all items that ownership is transferred from the Organization to ensure compliance. Views of Responsible Officials: Agree.