Finding 1153391 (2024-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-09-18
Audit: 366602
Organization: Duckwater Shoshone Tribe (NV)
Auditor: Sjt Group LLC

AI Summary

  • Core Issue: A vendor was paid over $10,000 without proper procurement documentation, violating the Department's own policies.
  • Impacted Requirements: Non-compliance with Uniform Guidance regulations and the Department's procurement policy, which mandates documentation for purchases exceeding the micro-purchase threshold.
  • Recommended Follow-up: Ensure strict enforcement of procurement policies and procedures to maintain compliance and fair pricing in future transactions.

Finding Text

2024-002 – Procurement Federal program information: Funding Agency: U.S. Departments of the Interior Title: Bureau of Indian Affairs Self-Governance Assistance Listing Number: 15.022 Award Periods: January 1, 2024 – December 31, 2024 Criteria: Uniform Guidance regulations section CFR 200.317 and CFR 200.320(a) state, the non-Federal entity must use its own documented procurement procedures which reflect applicable state, local, and tribal laws and regulations, provided that the procurement conform to applicable federal law and the standards identified. Procurement by micro-purchase is the acquisition of supplies or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold. During 2024, the Department’s procurement policy has a micro purchase threshold of $10,000. The Department’s policy states “Duckwater will conduct procurement in a manner that prohibits the use of statutorily or administratively imposed data, local, or tribal geographical preferences in the evaluation of bids or proposals”. Condition: We reviewed one vendor that was paid in excess of $10,000; however, we were not provided with procurement documentation for this purchase. Context: One of thirty-five expenditures tested. Questioned Costs: None. Cause: The Department’s procurement policies and procedures were not enforced during the year. Effect: The Department is not always ensuring that all goods and services are obtained at a fair price and the Department is not in compliance with their procurement policy. Auditors’ Recommendation: Enforce procurement policies and procedures at all times. Management Response: Management believes that the procurement process has improved considerably. Managers are following the procurement policy by making price comparisons and submitting quotes when required. Approvals for larger purchases are obtained by Resolution from Council. The Finance Manager and the Accounts Payable Clerk monitor the documents submitted with purchase requests to ensure that the required documents have been submitted. Management believes that it is an isolated instance where a transaction lacked procurement documents.

Corrective Action Plan

Corrective action plan: Management believes that the procurement process has improved considerably. Managers are following the procurement policy by making price comparisons and submitting quotes when required. Approvals for larger purchases are obtained by Resolution from Council. The Finance Manager and the Accounts Payable Clerk monitor the documents submitted with purchase requests to ensure that the required documents have been submitted. Management believes that it is an isolated instance where a transaction lacked procurement documentation. Personnel responsible for corrective action: Lisa Donham (Finance Manager), Deidre Moyle (Accounts Payable), and Program Managers. Estimated corrective action completion date: December 31, 2025

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1153392 2024-003
    Material Weakness Repeat
  • 1153393 2024-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.210 Tribal Self-Governance Program: Ihs Compacts/funding Agreements $2.98M
15.022 Tribal Self-Governance $2.94M
14.867 Indian Housing Block Grants $696,652
21.027 Coronavirus State and Local Fiscal Recovery Funds $545,144
15.042 Indian School Equalization $284,975
15.046 Administrative Cost Grants for Indian Schools $223,754
93.237 Special Diabetes Program for Indians Diabetes Prevention and Treatment Projects $208,922
14.862 Indian Community Development Block Grant Program $162,491
66.926 Indian Environmental General Assistance Program (gap) $157,318
15.904 Historic Preservation Fund Grants-in-Aid $144,476
84.027 Special Education Grants to States $117,667
66.605 Performance Partnership Grants $112,677
97.042 Emergency Management Performance Grants $82,849
21.029 Coronavirus Capital Projects Fund $65,466
93.575 Child Care and Development Block Grant $55,146
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $39,632
84.424 Student Support and Academic Enrichment Program $30,330
84.010 Title I Grants to Local Educational Agencies $29,078
10.555 National School Lunch Program $19,057
15.044 Indian Schools Student Transportation $18,584
84.336 Teacher Quality Partnership Grants $15,458
15.149 Focus on Student Achievement $8,313
16.575 Crime Victim Assistance $5,927