Audit 405469

Item 2025-003: Material Weakness in Internal Control Over Compliance - Cash Management Federal agency: • U.S. Department of Agriculture • U.S. Department of Commerce Federal program: • Environmental Quality Incentives Program (ALN 10.912) • Habitat Conservation (ALN 11.463) Pass-through Entity: None Federal Award Year: Year ended September 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to review reimbursement requests. Condition: During our testing of cash management requirements, we noted that a review of the reimbursement requests sampled for testing was not performed prior to submission. Cause: The Band does not have a procedure for a review of the reimbursement requests prior to submission for the identified programs. Currently, the same employee prepares and submits the reimbursement requests. Effect: Likelihood of inaccurate reimbursement requests is increased when they are not thoroughly reviewed. Questioned costs: None Context: • ALN 10.912 – The population of reimbursement requests subject to cash management requirements included one request. Our sample included one reimbursement request which did not have documentation showing it was reviewed. • ALN 11.463 – The population of reimbursement requests subject to cash management requirements included eight requests. Our sample included two reimbursement requests which did not have documentation showing they were reviewed. Repeat finding: No Recommendation: We recommend that the Band review their processes to ensure all reimbursement requests have review a process documented indicating that a secondary review was performed prior to submission. Views of responsible officials: The Band agrees with the above finding and its response is included in the corrective action plan.

2025-002 Special Tests and Provisions - Character Investigations Federal agency: U.S. Department of Health and Human Services Federal program: Tribal Self-Governance Program: IHS Compacts/Funding Agreements (ALN 93.210). Pass-through Entity: None Federal Award Year: Year ended September 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance; Adverse Opinion on Compliance Criteria: The Indian Child Protection and Family Violence Protection Act (25 USC 3207) requires that all Indian tribes or tribal organizations receiving funds under the authority of the Indian Self Determination and Education Assistance Act or Tribally Controlled Schools Act of 1988 must conduct a background investigation for individuals whose duties and responsibilities would allow them regular contact with or control over Indian children. The Act further states that the tribe or tribal organization can employ only individuals who meet standards of character that are no less stringent than those prescribed by the regulations, which are outlined in 42 CFR 136.405, and only after an individual has been the subject of a satisfactory background investigation as described in 42 CFR 136.406. Condition: The Band did not have documentation to support that character investigations were performed on employees that have regular contact with, or control over Indian children for all employees subject to character investigations. Cause: Character investigations were not conducted in accordance with 42 CFR 136.406. Effect: The Band is not in compliance with special tests and provisions requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: None Context: The population of employees subject to character investigations included 19 employees. The Band did not have documentation to support that character investigations were performed on employees that have regular contact with, or control over Indian children for all employees subject to character investigations. Repeat finding: Yes Recommendation: We recommend that all individuals with access to vulnerable populations, including contractors and volunteers are subjected to the required background investigations and that documentation that these investigations are performed are retained in the records of the Band. Views of responsible officials: The Band agrees with the above finding and its response is included in the corrective action plan.