Audit 404885

Program Information: U.S. Department of Health and Human Services Tribal Self-Governance and Determination Cluster Assistance Listing #93.441 Award Numbers: HHS-I-241-2022-00004 and HHS-I-241-2019-00003 Award Period: 10/1/2024-9/30/2027 and 10/1/2020-9/30/2021 Rural Health Outreach and Rural Network Development Program Assistance Listing #93.912 Award Numbers: 6 G28RH46294-03-00 and 6 HB1RH47073-03-02 Award Period: 9/30/2022-9/29/2025 and 9/1/2022-8/31/2026 Criteria: Assistance Listing #93.441 Per the compliance supplement and 42 CFR 136.12, eligible individuals include those of Indian descent belonging to the local Indian community, as evidenced by tribal membership or similar factors. Additional eligibility covers non-Indian women pregnant with an eligible Indian’s child, certain non-Indian household members for public health reasons, and specific children and spouses per 25 USC 1680c(a)-(b) and Section 813 of the Indian Health Care Improvement Act. For Purchased/Referred Care (PRC), individuals must reside in the U.S. within a PRC Delivery Area, be a member of or have close ties to the relevant tribe(s), and meet requirements for students, transients, and foster children as specified in the supplement. Assistance Listing #93.912 Per discussion with the program’s Chief Behavioral Health Officer, individuals must provide documentation of membership in a federally recognized Tribe (e.g., Tribal enrollment card, Certificate of Indian Blood, or proof of lineal descent) and a signed consent to receive services. Registration staff are responsible for screening and securely filing these documents in the practice management system. Per 2 CFR § 200.303, recipients must establish and maintain effective internal controls over federal awards to ensure compliance with applicable regulations. Condition/Context: Assistance Listing #93.441 Of the 60 samples selected for testing, documentation to evidence review and approval was not provided. Assistance Listing #93.912 Of the 5 samples selected for testing, documentation to evidence review and approval was not provided. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: The program did not have adequate internal controls to ensure that all eligibility files included documentation of review and approval. This appears to be due to a lack of oversight and monitoring procedures to track compliance with this documentation requirement. Effect: Without adequate documentation of review and approval, there is an increased risk that ineligible individuals may receive services, and the entity may not be able to demonstrate compliance with federal eligibility requirements. This could result in questioned costs or findings in future audits. Questioned Cost: N/A – none of the samples selected for testing were determined to be ineligible to receive services. Prior Year Finding: Yes, 2024-004. Recommendation: We recommend that management implement and enforce procedures to ensure that all eligibility determinations are reviewed and approved, and that supporting documentation of such review and approval is consistently maintained in the appropriate system or file. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: U.S. Department of the Interior Services to Indian Children, Elderly and Families Assistance Listing #15.025 Award Numbers: A24AV00213, A18AV00060, A23AV00656, A25AV00471, Unknown Award Period: 10/1/2023-9/30/2026 U.S. Department of Health and Human Services Substance Abuse and Mental Health Services Projects of Regional and National Significance Assistance Listing #93.243 Award Numbers: 5H79SM086440-03, 1H79SM089733-01, and 5H79TI086315-02 Award Period: 9/30/2022-9/29/2027, 9/30/2024-9/29/2029, and 9/30/2023-9/29/2028 Criteria: Assistance Listing #15.025 Per discussion with the program’s management the following reports are required to be submitted: • Quarterly SF-425 Federal Financial Reports • Annual Narrative Report • FASSR Report • ICWA Annual Report Assistance Listing #93.243 Per discussion with the program’s management the following reports are required to be submitted: • Annual SF-425 Federal Financial Reports • SF-424 Application for Federal Assistance • Mid-year Programmatic Progress Reports • Annual Programmatic Progress Reports • SPARS Reports Per 2 CFR § 200.303, recipients must establish and maintain effective internal controls over federal awards to ensure compliance with applicable regulations. Assistance Listing #15.025 • 1 of 2 Quarterly SF-425 Federal Financial Reports were submitted after the required due date. • 1 of 1 Annual Narrative Report had no documentation of approval. • 1 of 1 Annual FASSR Report had no documentation of approval and was submitted after the required due date. • 1 of 1 ICWA Annual Report had no documentation of approval and was submitted after the required due date. Assistance Listing #93.243 • 1 of 3 SF-425 Federal Financial Reports was submitted after the required due date. • 1 of 1 Mid-year Programmatic Progress Report had no documentation of approval or date of submission. • 2 of 2 Annual Programmatic Progress Reports had no documentation of approval or date of submission. • 1 of 1 SPARS Report had no documentation of approval. [ X ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: Management did not have adequately designed and implemented controls to ensure required federal reports were prepared, reviewed, approved, and submitted timely. In addition, evidence of supervisory review and approval was not consistently maintained. Effect: Late or inadequately documented reports increase the risk that the Department will not comply with federal award reporting requirements and may be unable to demonstrate compliance during monitoring or audit. In addition, the lack of documented review or approval increases the risk that reporting errors, omissions, or incomplete information may not be detected before submission. Questioned Cost: N/A. No questioned costs were identified as the finding relates to late reporting and lack of documented review/approval. Prior Year Finding: No. Recommendation: We recommend that the Department strengthen internal controls over federal reporting by implementing procedures to ensure all required reports are prepared, reviewed, approved, and submitted timely. Such procedures should include maintaining a reporting calendar of required due dates, assigning responsibility for report preparation and submission, documenting supervisory review and approval, and periodically monitoring compliance with reporting requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.