Audit 401240

2024-007: Bureau of Indian Affairs – 105(l) Leases ALN 15.048, Lack of Approvals (Material Weakness) Condition There were several instances of lack of approvals for disbursements. Criteria Federal grant recipients are required to maintain effective internal controls over federal awards, as outlined in 2 CFR §200.303. Cause Turnover and inadequate staffing. Effect Some disbursements had no approvals. Perspective Information Nine of 27 tested. Recommendation All disbursements should have one approval and ensure the expenditure is eligible under the grant. View of Responsible Officials and Planned Corrective Action The Tribe has taken steps to strengthen internal controls over disbursement approvals and ensure that all expenditures are properly reviewed and documented including:  Establishment of a standardized disbursement approval process requiring documented approval prior to payment for non-routine/recurring expenditures.  Implementation of procedures to ensure all disbursements are reviewed for allowability under applicable grant requirements before payment is issued.  Maintenance of supporting documentation, including approval evidence, within the accounting records.  Ongoing review of disbursement procedures to ensure compliance with internal control requirements under 2 CFR §200.303. These measures are designed to ensure that all disbursements are properly authorized, documented, and compliant with applicable grant requirements. Corrective actions began implementation during throughout 2025. These procedures are currently in place and will continue to be refined as part of ongoing internal control improvements.

2024-006: Bureau of Indian Affairs – 105(l) Leases ALN 15.048 and Pandemic Relief Activities: Local Food Purchase Agreements with States, Tribes, and Local Governments ALN 10.182, Late filing of Data Collection Form Condition The Tribe did not file the data collection form for the years ended December 31, 2022, 2023, or 2024 timely. Criteria Under the requirements of the Uniform Guidance and the Office of Management and Budget (OMB), all entities are required to file the annual data collection form with the Federal Audit Clearinghouse the earlier of 30 days after the issuance of the entity’s annual audit or nine months after the entity’s fiscal year-end. Cause Management did not complete and certify the auditee portion of the form before the deadline. Effect The Tribe’s form was not submitted timely to the Federal Audit Clearinghouse. Recommendation Management should take steps to ensure that the form is filed timely. View of Responsible Officials and Planned Corrective Action The Tribe has taken steps to ensure timely completion and submission of the annual data collection form going forward including:  Assignment of responsibility for preparation, review, and submission of the auditee portion of the data collection form to the Director of Finance.  Establishment of a formal process to complete and certify the annual data collection form immediately upon completion of the annual audit.  Implementation of internal tracking procedures to monitor audit timelines and ensure compliance with Federal Audit Clearinghouse submission requirements.  Coordination with external auditors to ensure timely communication regarding audit completion and reporting deadlines. This corrective action has been implemented and the tribe anticipates compliance in all future audit reporting periods beginning with FY2025.