2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-004 Significant Deficiency in Compliance ? Special Tests ? Collateralization, repeat of 2022-002 Identification of federal programs: 21.027 Coronavirus State and Local Fiscal Recover Funds 2022-002 Collateralization ? Significant Deficiency in Compliance and Internal Controls over Compliance ? Special Tests Criteria: 2 CFR part 200 subpart -D section 200.305(b)(7)(ii) states that ?Advance payments of Federal funds must be deposited and maintained in insured accounts whenever possible.? Condition: The accounts at the banking institution were not collateralized. Cause: Klawock Cooperative Association has changed banking institution and has not set up the collateralization at the new bank. Effect or potential effect: The Association was not in compliance with Federal compliance requirements. Additionally, if the bank fails, federal funds would be put at risk. Recommendation: Klawock Cooperative should immediately have the bank provide collateralization. Views of Responsible Officials: Management agrees. See Corrective Action Plan
2022-003 Significant Deficiency in Compliance and Internal Control over Compliance ? Allowable Costs/Cost Principles Identification of federal programs: 21.027 Coronavirus State and Local Fiscal Recover Funds Criteria: Title 2 U.S. Code Part 200.403(g) requires that for costs charged to a federal program to be allowable, they must be adequately documented. Condition: Major federal programs 21.027 Coronavirus State and Local Fiscal Recovery Funds had payroll related costs charged to the program that potentially would be overpayment. One employee had two timesheets that represented two differing federal programs. Both timesheets resulted in a paycheck. Taken together these paychecks resulted in an overpayment of wages. Of the 72 paychecks sampled, 6 related to the one individual and duplicates were noted in each of the 6. The other employee paychecks did not have exceptions. Cause: Due to staffing shortages, the accounting staff was undertrained. Management oversight did not have adequate financial training. Effect or potential effect: Costs were charged to these programs that were unsupported in accordance with allowable cost principles. Questioned Costs: None ? The known and likely questioned costs were below the $25,000 reporting threshold and program materiality for both major federal programs. Context: 21.027 Coronavirus State and Local Fiscal Recovery Funds ? During my sample testing for allowable costs, I identified 6 out of 72 transactions (error rate of 8%) that had conflicting documentation to support the program cost. They were all isolated from payroll charges and specifically to one employee. Total payroll expenditures charged to the program was $295,466 out of $1,557,537 total expenditures. Program materiality was $77,877 (5% of total expenditures). The likely error was not material to the program, the internal controls which allowed the errors to occur should be corrected. Identification of Repeat Finding: 2021-002 Recommendations: I recommend the Association use one timesheet that allows time to be allocated between all programs which would eliminate the possibility of double time records and consequently the potential of duplicate payments. Views of Responsible Officials: Management agrees. Also see Corrective Action Plan.
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-004 Significant Deficiency in Compliance ? Special Tests ? Collateralization, repeat of 2022-002 Identification of federal programs: 21.027 Coronavirus State and Local Fiscal Recover Funds 2022-002 Collateralization ? Significant Deficiency in Compliance and Internal Controls over Compliance ? Special Tests Criteria: 2 CFR part 200 subpart -D section 200.305(b)(7)(ii) states that ?Advance payments of Federal funds must be deposited and maintained in insured accounts whenever possible.? Condition: The accounts at the banking institution were not collateralized. Cause: Klawock Cooperative Association has changed banking institution and has not set up the collateralization at the new bank. Effect or potential effect: The Association was not in compliance with Federal compliance requirements. Additionally, if the bank fails, federal funds would be put at risk. Recommendation: Klawock Cooperative should immediately have the bank provide collateralization. Views of Responsible Officials: Management agrees. See Corrective Action Plan
2022-003 Significant Deficiency in Compliance and Internal Control over Compliance ? Allowable Costs/Cost Principles Identification of federal programs: 21.027 Coronavirus State and Local Fiscal Recover Funds Criteria: Title 2 U.S. Code Part 200.403(g) requires that for costs charged to a federal program to be allowable, they must be adequately documented. Condition: Major federal programs 21.027 Coronavirus State and Local Fiscal Recovery Funds had payroll related costs charged to the program that potentially would be overpayment. One employee had two timesheets that represented two differing federal programs. Both timesheets resulted in a paycheck. Taken together these paychecks resulted in an overpayment of wages. Of the 72 paychecks sampled, 6 related to the one individual and duplicates were noted in each of the 6. The other employee paychecks did not have exceptions. Cause: Due to staffing shortages, the accounting staff was undertrained. Management oversight did not have adequate financial training. Effect or potential effect: Costs were charged to these programs that were unsupported in accordance with allowable cost principles. Questioned Costs: None ? The known and likely questioned costs were below the $25,000 reporting threshold and program materiality for both major federal programs. Context: 21.027 Coronavirus State and Local Fiscal Recovery Funds ? During my sample testing for allowable costs, I identified 6 out of 72 transactions (error rate of 8%) that had conflicting documentation to support the program cost. They were all isolated from payroll charges and specifically to one employee. Total payroll expenditures charged to the program was $295,466 out of $1,557,537 total expenditures. Program materiality was $77,877 (5% of total expenditures). The likely error was not material to the program, the internal controls which allowed the errors to occur should be corrected. Identification of Repeat Finding: 2021-002 Recommendations: I recommend the Association use one timesheet that allows time to be allocated between all programs which would eliminate the possibility of double time records and consequently the potential of duplicate payments. Views of Responsible Officials: Management agrees. Also see Corrective Action Plan.
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan
2022-005 Significant Deficiency in Compliance and Internal Control over Compliance ? Subrecipient Monitoring Identification of federal programs: 14.862 Indian Community Development Block Grant 21.027 Coronavirus State and Local Fiscal Recover Funds 93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes, x Part B, Grants to Native Hawaiians 93.054 Special Program for the Aging, Title VI, Part C, Grants to Indian Tribes and x Native Hawaiians Criteria or specific requirements: There are various federal pass-through programs that the Association administers. When the Association receives these grants and passes them through to a subrecipient, the Association is required to complete subrecipient monitoring procedures. Condition: The Association received reports from the subrecipients however the activity was never recorded on the financial reports to the Council or in their annual financial statement. Cause: Management continues to understand the reporting requirements and obligations associated with subrecipient monitoring. Effect or potential effect: By not completing the appropriate subrecipient monitoring procedures, the Association is not complying with federal program requirements. Questioned Costs: None Context: Although these programs are not major federal programs, in reviewing the summary schedule of prior audit findings with management, it did not appear that corrective action for subrecipient monitoring had been implemented. Identification of Repeat Finding: 2021-004 Recommendation: I recommend that the Association institute procedures to properly monitor subrecipients. The procedures performed should be documented and maintained as part of the grant recordkeeping. Views of Responsible Officials: See Corrective Action Plan