Audit 403879

Finding 2025-004 – Single Audit Report Submission – Significant Deficiency in Internal Control Over Compliance and Noncompliance (Repeat Finding – Prior Year 2023-002) Criteria or Specific Requirement: The Uniform Guidance, 2 CFR 200.512(a), requires the auditee to submit the single audit reporting package and the data collection form to the Federal Audit Clearinghouse (FAC) within the earlier of 30 days after receipt of the auditor's report or nine months after the end of the fiscal year under audit. For the fiscal year ended June 30, 2024, the submission deadline was March 31, 2025. Condition: The single audit reporting package and data collection form for the fiscal year ended June 30, 2024 were not submitted to the Federal Audit Clearinghouse by the required deadline of March 31, 2025, resulting in a late filing and noncompliance with 2 CFR 200.512(a). This finding was previously identified as Finding 2023-002 for the fiscal year ended June 30, 2023, and was reported as resolved in the prior year audit. The recurrence of this condition indicates that the corrective actions implemented were not sufficient to prevent the issue from recurring. Cause and Effect: The late submission was primarily attributable to staff turnover in key finance positions, which resulted in delays in completing the year-end close, preparing the financial statements, and finalizing the single audit reporting package in a timely manner. Late submission of the single audit reporting package may jeopardize the Organization's standing with federal awarding agencies and could affect the Organization's ability to receive future federal funding. Auditors' Recommendations: Management should establish a formal single audit submission timeline with clearly defined milestones, responsible parties, and target completion dates beginning at the start of each fiscal year. The timeline should work backward from the submission deadline to establish interim deadlines for year-end close, draft financial statement preparation, management review, and auditor fieldwork. Given the recurring nature of this finding, management should also consider engaging its external auditors earlier in the process and ensuring that adequate finance staffing is in place prior to the year-end close. Progress against the submission timeline should be monitored by the CEO and reported to the Board of Directors. Management's Response: Management has created standard operating procedures and instructions in order to adhere to established quarterly and annual deadlines including quarterly board reporting and treasurer review for adherence to deadlines.

Finding 2025-005 – Revenue Recognition Cutoff and Schedule of Expenditures of Federal Awards – Material Weakness in Internal Control Over Compliance and Noncompliance (Repeat Finding – Prior Year 2024-002) Criteria or Specific Requirement: The Uniform Guidance, 2 CFR 200.510(b), requires the auditee to prepare a Schedule of Expenditures of Federal Awards (SEFA) for the period covered by the financial statements, which must include the total federal awards expended as determined in accordance with 2 CFR 200.502. Additionally, 2 CFR 200.403 requires that costs charged to federal awards be allocable, allowable, and properly recorded in the period in which they are incurred. 27 Condition: During the audit of the fiscal year ended June 30, 2025, it was determined that revenue earned under the Indian Health Service Behavioral Health Programs grant (CFDA 93.654, Award No. BH22IHS0008) during the fiscal year ended June 30, 2024 was not recognized until the fiscal year ended June 30, 2025. The misapplication of the revenue recognition cutoff resulted in federal award revenue and expenditures being reported on the SEFA in the incorrect fiscal year, requiring a material post-close adjusting journal entry. This finding is a repeat of prior year Finding 2024-002. Cause and Effect: Controls over the period-end review of federal award revenue recognition and SEFA preparation were not operating effectively. The Organization did not perform a sufficient review of grant expenditure activity and award eligibility requirements relative to the June 30 fiscal year-end cutoff. The recurrence of this condition, despite being identified and reported in the prior year audit, indicates that corrective actions implemented were not sufficient to prevent the issue from recurring. Auditors' Recommendations: Management should implement a formal SEFA preparation and review process to ensure federal award expenditures are accurately reported for each fiscal year. A designated Finance staff member with sufficient knowledge of the Uniform Guidance requirements should be responsible for overseeing SEFA preparation for each fiscal year-end. A grant-by-grant SEFA reconciliation should be completed prior to year-end close. Management should engage its external accountants earlier in the year-end close process to allow sufficient time to identify and correct any SEFA discrepancies prior to fieldwork. Management's Response: Management has implemented a series of 3 checks and balance procedures for monthly review for SEFA procedures. A finance staff member with Uniform Guidance requirements will prepare the annual statement preparation at year end with review from Director of Finance and Board Treasurer before submission.