Finding 1158080 (2023-007)

Finding 2023-007 Lack of Internal Control over Activities Allowed or Unallowed and Allowable Costs/Cost Principles Type of Finding: Material weakness in internal control over compliance and material Noncompliance. Name of Contact: Adela Lane, Executive Director Corrective Action Plan: 1. Update and Disseminate Financial Management Policies: • Action: Formally update and reissue Chapter III (Financial Management) of the Administrative Manual to specifically include the following requirements for all payroll-related actions. o Mandatory use of the payment authorization form for all employee pays rate changes, bonuses, or other non-standard payments. o Verification of all signatories against a current, board-approved signatory list. o A documented review step during each payroll run where the personnel action recommendation form is compared against the actual pay rate being processed. • Responsible Party: Executive Director and Financial Specialist. 2. Implement a Structured Payroll Review Process: • Action: Establish a mandatory, documented two-step review process for every payroll cycle. o Step 1: The Financial Specialist will review all payment authorization forms and verify signatories. o Step 2: The Financial Specialist will compare the pay rates in the payroll system to the approved rates on the personnel action recommendation forms and initial the review for the record. • Responsible Party: Financial Specialist. 3. Conduct Mandatory Training for Staff: • Action: Provide comprehensive and mandatory training for all relevant staff (e.g., payroll clerks, program managers) on the updated financial management policies and payroll review protocols. This training will cover: o Proper use and routing of payment authorization forms. o Verification procedures for pay rates. o The importance of maintaining proper documentation. • Responsible Party: Executive Director, in coordination with the Financial Specialist 4. Transition to New Permanent Administration: • Action: As part of the onboarding process for the new permanent Administration, the following will occur: o The Executive Director will hold a comprehensive "sit-down" session to review and reinforce all financial management and payroll protocols. o The new team will be provided with the updated Administrative Manual and all relevant training materials. o A transition checklist will be used to ensure all key financial controls are properly handed over and understood. • Responsible Party: Executive Director. 5. Verification of Effectiveness: • Action: After the new procedures are implemented, the Executive Director and Tribal Council will perform a periodic review of a sample of payroll records to ensure compliance with the new internal controls. • Responsible Party: Tribal Council and Executive Director. Proposed Completion Date: Ongoing, starting in early 2026.