Audit 56719

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-009 Repeat Finding: Yes Type of Finding: Significant deficiency in Internal Control and Nonmaterial Noncompliance Description: Late reporting Major Programs: AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Reporting Requirement Criteria: The Organization is required to submit monthly fiscal reports to the federal funding source beginning 60 days after the Notice of Awards are issued. Condition: The Organization did not meet its financial reporting obligations under the grant during the year. Context: During the audit, it was determined the Organization did not submit reports on a timely basis. Cause: The Organization was not aware of the due dates of the reports. Effect: The Organization was not in compliance with federal regulations and guidelines. Recommendation: Management should develop proper controls around federal grant related reporting requirements. We recommend management develop a due date list of all reports required to be filed for each grant and assign responsibility for review, approval and submission of the reports to the funding sources. The Organization should file the monthly reports in a timely manner and ensure amounts reported agree to supporting documentation and comply with federal compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-009 Repeat Finding: Yes Type of Finding: Significant deficiency in Internal Control and Nonmaterial Noncompliance Description: Late reporting Major Programs: AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Reporting Requirement Criteria: The Organization is required to submit monthly fiscal reports to the federal funding source beginning 60 days after the Notice of Awards are issued. Condition: The Organization did not meet its financial reporting obligations under the grant during the year. Context: During the audit, it was determined the Organization did not submit reports on a timely basis. Cause: The Organization was not aware of the due dates of the reports. Effect: The Organization was not in compliance with federal regulations and guidelines. Recommendation: Management should develop proper controls around federal grant related reporting requirements. We recommend management develop a due date list of all reports required to be filed for each grant and assign responsibility for review, approval and submission of the reports to the funding sources. The Organization should file the monthly reports in a timely manner and ensure amounts reported agree to supporting documentation and comply with federal compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-009 Repeat Finding: Yes Type of Finding: Significant deficiency in Internal Control and Nonmaterial Noncompliance Description: Late reporting Major Programs: AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Reporting Requirement Criteria: The Organization is required to submit monthly fiscal reports to the federal funding source beginning 60 days after the Notice of Awards are issued. Condition: The Organization did not meet its financial reporting obligations under the grant during the year. Context: During the audit, it was determined the Organization did not submit reports on a timely basis. Cause: The Organization was not aware of the due dates of the reports. Effect: The Organization was not in compliance with federal regulations and guidelines. Recommendation: Management should develop proper controls around federal grant related reporting requirements. We recommend management develop a due date list of all reports required to be filed for each grant and assign responsibility for review, approval and submission of the reports to the funding sources. The Organization should file the monthly reports in a timely manner and ensure amounts reported agree to supporting documentation and comply with federal compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-009 Repeat Finding: Yes Type of Finding: Significant deficiency in Internal Control and Nonmaterial Noncompliance Description: Late reporting Major Programs: AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Reporting Requirement Criteria: The Organization is required to submit monthly fiscal reports to the federal funding source beginning 60 days after the Notice of Awards are issued. Condition: The Organization did not meet its financial reporting obligations under the grant during the year. Context: During the audit, it was determined the Organization did not submit reports on a timely basis. Cause: The Organization was not aware of the due dates of the reports. Effect: The Organization was not in compliance with federal regulations and guidelines. Recommendation: Management should develop proper controls around federal grant related reporting requirements. We recommend management develop a due date list of all reports required to be filed for each grant and assign responsibility for review, approval and submission of the reports to the funding sources. The Organization should file the monthly reports in a timely manner and ensure amounts reported agree to supporting documentation and comply with federal compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-009 Repeat Finding: Yes Type of Finding: Significant deficiency in Internal Control and Nonmaterial Noncompliance Description: Late reporting Major Programs: AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Reporting Requirement Criteria: The Organization is required to submit monthly fiscal reports to the federal funding source beginning 60 days after the Notice of Awards are issued. Condition: The Organization did not meet its financial reporting obligations under the grant during the year. Context: During the audit, it was determined the Organization did not submit reports on a timely basis. Cause: The Organization was not aware of the due dates of the reports. Effect: The Organization was not in compliance with federal regulations and guidelines. Recommendation: Management should develop proper controls around federal grant related reporting requirements. We recommend management develop a due date list of all reports required to be filed for each grant and assign responsibility for review, approval and submission of the reports to the funding sources. The Organization should file the monthly reports in a timely manner and ensure amounts reported agree to supporting documentation and comply with federal compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-009 Repeat Finding: Yes Type of Finding: Significant deficiency in Internal Control and Nonmaterial Noncompliance Description: Late reporting Major Programs: AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Reporting Requirement Criteria: The Organization is required to submit monthly fiscal reports to the federal funding source beginning 60 days after the Notice of Awards are issued. Condition: The Organization did not meet its financial reporting obligations under the grant during the year. Context: During the audit, it was determined the Organization did not submit reports on a timely basis. Cause: The Organization was not aware of the due dates of the reports. Effect: The Organization was not in compliance with federal regulations and guidelines. Recommendation: Management should develop proper controls around federal grant related reporting requirements. We recommend management develop a due date list of all reports required to be filed for each grant and assign responsibility for review, approval and submission of the reports to the funding sources. The Organization should file the monthly reports in a timely manner and ensure amounts reported agree to supporting documentation and comply with federal compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-009 Repeat Finding: Yes Type of Finding: Significant deficiency in Internal Control and Nonmaterial Noncompliance Description: Late reporting Major Programs: AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Reporting Requirement Criteria: The Organization is required to submit monthly fiscal reports to the federal funding source beginning 60 days after the Notice of Awards are issued. Condition: The Organization did not meet its financial reporting obligations under the grant during the year. Context: During the audit, it was determined the Organization did not submit reports on a timely basis. Cause: The Organization was not aware of the due dates of the reports. Effect: The Organization was not in compliance with federal regulations and guidelines. Recommendation: Management should develop proper controls around federal grant related reporting requirements. We recommend management develop a due date list of all reports required to be filed for each grant and assign responsibility for review, approval and submission of the reports to the funding sources. The Organization should file the monthly reports in a timely manner and ensure amounts reported agree to supporting documentation and comply with federal compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.

Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.

Finding Number: 2022-009 Repeat Finding: Yes Type of Finding: Significant deficiency in Internal Control and Nonmaterial Noncompliance Description: Late reporting Major Programs: AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Reporting Requirement Criteria: The Organization is required to submit monthly fiscal reports to the federal funding source beginning 60 days after the Notice of Awards are issued. Condition: The Organization did not meet its financial reporting obligations under the grant during the year. Context: During the audit, it was determined the Organization did not submit reports on a timely basis. Cause: The Organization was not aware of the due dates of the reports. Effect: The Organization was not in compliance with federal regulations and guidelines. Recommendation: Management should develop proper controls around federal grant related reporting requirements. We recommend management develop a due date list of all reports required to be filed for each grant and assign responsibility for review, approval and submission of the reports to the funding sources. The Organization should file the monthly reports in a timely manner and ensure amounts reported agree to supporting documentation and comply with federal compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.