Audit 384645

CFDA 17.277 Program Title: EKCEP CFDA No. 15.252 Program Title: Abandon Mine Lands Pilot Project CFDA No. 23.001 Program Title: EKAMI Workforce Development Program Failure to have audit completed timely. The Uniform Guidance requires non-Federal entities that expend $750,000 or more a year in Federal awards to have an audit conducted in accordance with the Uniform Guidance. And the contract requires an annual audit be performed. Personnel were not aware of the requirement that an audit was to be performed. Policies and procedures; and internal controls were lacking that would have resulted in having audit completed timely. Failure to meet federal audit requirements. Written policies and procedures should be put in place to negate repeating finding. Policies should be put in place that meet the requirement for compliance with procurement standards (24 CFR Part 85) The Organization agrees with the finding and the recommended procedures have been implemented.

CFDA 17.277 Program Title: EKCEP CFDA No.: 15.252 Program Title: Abandon Mine Lands Pilot Project CFDA No. 23.001 Program Title: EKAMI Workforce Development Program Failure to complete required filings with the Federal Single Audit Clearing House The Office of Management and Budget (OMB) Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) 2 CFR 200.512 requires auditees to submit a completed Form SFSAC, along with one complete reporting package, to the Federal Audit Clearinghouse. Personnel were not aware of the requirement. Policies and procedures; and internal controls were lacking that would have resulted in having audit completed timely. Failure to meet federal audit requirements. Written policies and procedures should be put in place to negate repeating of finding. The Organization agrees with the finding and the recommended procedures have been implemented.

CFDA 17.277 Program Title: EKCEP CFDA No. 23.001 Program Title: EKAMI Workforce Development Program Written policies and procedures do not conform to Uniform Guidance General Procurement Standards. Written policies conforming to the Uniform Guidance procurement standards are required. Lack of written conforming policies and procedures. Failure to meet federal and state procurement requirements. Policies should be put in place that meet the requirement for compliance with procurement standards (24 CFR Part 85) . The organization is currently researching & in the process of forming policies that will put the organization in compliance with the procurement standards.

CFDA 17.277 Program Title: EKCEP CFDA No. 23.001 Program Title: EKAMI Workforce Development Program Approval of purchases not documented. All purchases should be approved by appropriate personnel and all approvals should be documented Lack of written policies and procedures. Failure to meet federal and state procurement requirements. Accounting policies and procedures should be established detailing how approvals should be documents. The organization is currently researching & is in the process of forming policies that would specify how approvals are documented. The organization already has a policy stating that there must be board approval for disbursements of over $10,000.

CFDA 17.277 Program Title: EKCEP CFDA No. 23.001 Program Title: EKAMI Workforce Development Program The Board of Directors did not meet between September 20, 2018 and September 23, 2020. The Board of Directors should meet regularly as stipulated in the articles of incorporation/by-laws. Unknown. Proper oversite of operations not maintained. Thus, failure to meet federal and state procurement requirements. The Corrective action plan (2017 audit) should have been reviewed and addressed by the board; and actions taken and policies to correct findings should have been addressed and approved by the board. Without minutes there is no documentation that this occurred. The Minutes of the Board of Directors meetings did not document the review and approval of Corrective Action Plan (2017) nor any actions taken and/or policies put in place to comply with the Corrective Action Plan. The board of directors have not met since September 20, 2018. The board of directors should meet regularly, with minutes containing all discussions and actions should be maintained. Meetings are being held annually starting September 23, 2020.