Audit 371211

Finding 2024-002 Material Weakness in Internal Control Over Compliance and Material Noncompliance - Reporting Identification of the federal program Agencies Award Numbers ALN 15.022 Tribal Self Governance Department of Interior GT-OSGT812- Year 2013 GT-OSGT812- Year 2017 GT-OSGT812- Year 2018 GT-OSGT812- Year 2019 GT-OSGT812- Year 2020 GT-OSGT812- Year 2021 GT-OSGT812- Year 2022 GT-OSGT812- Year 2023 GT-OSGT812- Year 2024 GT-OSGT812- Year 2025 Criteria In accordance with Uniform Guidance, AVCP must comply with the Federal Funding Accountability and Transparency Act reporting requirements. Recipients of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. AVCP is required to file a FFATA sub-award report by the end of the month following the month. Condition The Association did not report subaward data through FSRS for the program. Cause Proper controls were not in place to ensure compliance with the Federal Funding Accountability and Transparency Act reporting requirements. Effect or potential effect Noncompliance with the Federal Funding Accountability and Transparency Act reporting requirements. Questioned Costs None Identified. Context We noted that subaward data for all TSG sub-recipients were not reported per the requirements of the Federal Funding Accountability and Transparency Act. Identification as a Repeat Finding Yes, 2023-001. Recommendation We recommend AVCP, design and implement internal control procedures to ensure compliance with the Federal Funding Accountability and Transparency Act reporting requirements. Views of Responsible Official and Planned Corrective Action Management concurs with the finding. Management is reviewing the policy and procedure and updating process of reporting and clearly defining roles and responsibilities of all employees involved in the process. Management is also provided with additional training of the subaward policy for employees involved in the subaward process, with emphasis on the FFATA reporting requirements and roles and responsibilities.

Finding 2024-004 Significant Deficiency in Internal Control over Compliance and Noncompliance – Procurement Identification of the federal program Agencies Award Numbers ALN 15.022 Tribal Self Governance ` Department of Interior GT-OSGT812- Year 2013 GT-OSGT812- Year 2017 GT-OSGT812- Year 2018 GT-OSGT812- Year 2019 GT-OSGT812- Year 2020 GT-OSGT812- Year 2021 GT-OSGT812- Year 2022 GT-OSGT812- Year 2023 GT-OSGT812- Year 2024 GT-OSGT812- Year 2025 Criteria The Uniform Guidance in 2 CFR Section 200.320(b), Procurement Methods – Small Purchase, is required if the aggregate dollar amount of the procurement transaction is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources. Unless specified by the Federal agency, the recipient or subrecipient may exercise judgment in determining what number is adequate. The recipient or subrecipient is responsible for determining an appropriate small purchase threshold based on internal controls, an evaluation of risk, and its documented procurement procedures, which may be lower than, but must not exceed, the threshold established in the Federal Acquisition Regulation. Condition The Association is not consistently following their own internal control policy for purchases that meet their small purchase threshold for procurement to obtain price or rate quotations from an adequate number of qualified sources. Cause AVCP is subject to high turnover in its purchasing department. Due to the frequency of new personal onboarding, the small purchase policy was missed was certain contracts. Effect or possible effect The Association not adhering to its established procedures, can lead to noncompliance, questioned costs, repayment obligations, or loss of funding. Questioned Costs None Identified. Context 2 out of 5 vendors selected for testing were not procured for in accordance with AVCP’s policy. Identification as a Repeat Finding None. Recommendation We recommend AVCP implement additional internal controls to ensure AVCP’s internal procurement policies are being followed. Views of Responsible Official and Planned Corrective Action Management concurs with the finding. Thorough training in AVCP’s procurement policies and procedures will be provided to departmental staff. AVCP will also hold an overall training of AVCP’s key and senior personnel by an outside expert in government procurement rules and regulations.

Finding 2024-003 Significant Deficiency in Internal Control Over Compliance - Eligibility Application Review Identification of the federal program Agencies Award Numbers ALN 84.250 American Indian Vocational Rehabilitation Services Department of Education H250N210051- Year 2023 H250N210051- Year 2024 Criteria In accordance with the Rehabilitation Act of 1973, as amended, Title I, Part C, Section 121, AVCP must comply with the Section 7(9) of the Acts eligibility requirements. Recipients of grants must provide services to American Indians with disabilities residing on or near a Federal or State reservation who meet the definition of an individual with a disability in Section 7 (9) of the Rehabilitation Act. According to the Act the term "disability" means (A) a physical or mental impairment that constitutes or results in a substantial impediment to employment; or (B) a physical or mental impairment that substantially limits one or more major life activities. AVCP is required to check eligibility requirements prior to providing services. Condition The Association is not consistently following their own internal control procedures for keeping evidence of reviewing the eligibility certification form. Cause Due to the remoteness of the villages served by the Association, physical signatures are not always obtainable. Effect or possible effect Individuals who do not met the eligibility requirements may be provided services. Questioned Costs None Identified. Context We tested 16 individuals who were designated as eligible for the American Indian Vocational Rehabilitation Services program. Out of the 16 tested, we found 3 instances where the evidence of the review control was not maintained. Identification as a Repeat Finding None. Recommendation We recommend AVCP update their internal control to include electronic reviews of the eligibility certificate. Views of Responsible Official and Planned Corrective Action Management concurs with the finding. AVCP Vocational Rehabilitation department is adding internal control policies to ensure eligibility documentations are reviewed and maintained.

Finding 2024-005 Significant Deficiency in Internal Control over Compliance and Noncompliance – Reporting Deadline for Federal Single Audit Identification of the federal programs Agencies Award Numbers ALN 15.022 Tribal Self Governance Department of Interior GT-OSGT812- Year 2013 GT-OSGT812- Year 2017 GT-OSGT812- Year 2018 GT-OSGT812- Year 2019 GT-OSGT812- Year 2020 GT-OSGT812- Year 2021 GT-OSGT812- Year 2022 GT-OSGT812- Year 2023 GT-OSGT812- Year 2024 GT-OSGT812- Year 2025 ALN 84.250 American Indian Vocational Rehabilitation Services Department of Education H250N210051- Year 2023 H250N210051- Year 2024 Criteria 2 CFR 200.512, Report Submission, establishes that the audit must be completed and the data collection form and reporting package submitted to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or 9 months after the end of the audit period. Condition The Association did not comply with the required submission date of the data collection form and reporting package to the FAC for the fiscal year ended December 31, 2024. Cause The audit was not completed in time to file the data collection form and reporting package, due to a delay in closing the books and records because of staff turnover. Effect or possible effect The Association is not compliant with 2 CFR 200.512. The Association could be exposed to a reduction or elimination of funds by the Federal awarding agencies. Questioned Costs None Identified. Context The data collection form and reporting package is due nine months after the fiscal year end. The data collection form and reporting package for the fiscal year ended December 30, 2024 was filed late. Identification as a Repeat Finding None. Recommendation We recommend the Association establish controls to ensure the audit is completed timely and the data collection form and reporting package is submitted to the FAC within the required timeframe. Views of Responsible Official and Planned Corrective Action Management concurs with the finding. Positions will be filled and reconciliation and review controls will be added for year end-close to ensure audit is filed before the deadline.