Audit 410465

Material Weakness in Internal Control Over Compliance and Material Noncompliance - Reporting Identification of the federal program ALN 15.022 Tribal Self Governance Agencies Department of Interior Award Numbers GT-OSGT812- Year 2017 GT-OSGT812- Year 2018 GT-OSGT812- Year 2019 GT-OSGT812- Year 2020 GT-OSGT812- Year 2021 GT-OSGT812- Year 2022 GT-OSGT812- Year 2023 GT-OSGT812- Year 2024 GT-OSGT812- Year 2025 GT-OSGT812- Year 2026 Criteria In accordance with Uniform Guidance, AVCP must comply with the Federal Funding Accountability and Transparency Act reporting requirements. Recipients of grants or cooperative agreements who make first tier subawards of $30,000 or more are required to register in the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS) and report subaward data through FSRS. AVCP is required to file a FFATA subaward report by the end of the month following the month of the subaward. Condition The Association did not report the current year subaward data to the FSRS within the required time. Additionally, the Association did not retroactively submit the report information for the subawards that were executed in the prior years but had active funding in the current year. Cause Proper controls were not in place to ensure compliance with the Federal Funding Accountability and Transparency Act reporting requirements. Effect or potential effect Noncompliance with the Federal Funding Accountability and Transparency Act reporting requirements. Questioned Costs None Identified. Context We noted that the subaward data for the Tribal Self Governance subrecipients for awards executed in 2025 were reported but not within the required time. Additionally, the subawards executed in previous years with active funding were not reported per the requirements of the Federal Funding Accountability and Transparency Act. Identification as a Repeat Finding Yes, 2024-002. Recommendation We recommend AVCP, design and implement internal control procedures to ensure compliance with the Federal Funding Accountability and Transparency Act reporting requirements. Views of Responsible Official and Planned Corrective Action Management concurs with the finding. The Association has retroactively filed reports in fiscal year 2026 on Tribal Self Governance funding for passthrough funding to Federally recognized Tribes for subrecipient awards including Aid to Tribal Government, Tribal Courts, and emergency funding for the prior years. The Association has implemented controls to ensure that reports are filed within the given timeline.