Finding 2023-004 Late Reporting and Noncompliance with Reporting Requirements 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 formalize policies and procedures: • Action: Conduct a comprehensive review and update of the Administrative Manual Systems, Chapter III: Financial Management, focusing specifically on all sections related to Uniform Guidance (UG) reporting. This includes procurement, reporting, and subrecipient monitoring requirements. • Details: o Develop and document detailed, step-by-step procedures for each UG reporting requirement. o Ensure all policies reflect the most current version of the UG, including the 2024 revisions. o Secure formal approval of the revised manual from tribal leadership. 2. Standardize and conduct mandatory staff training: • Action: Develop and implement a structured, mandatory training program for all staff involved in federal grant management, including finance, administrative, and program personnel. • Details: o Content: The training will cover the revised UG policies, focusing on reporting deadlines, documentation requirements, and proper internal controls. o Onboarding: The Executive Director will meet with all new permanent staff within their first two weeks of employment to review these protocols and emphasize the importance of compliance. o Ongoing Training: Conduct annual refresher training for all relevant staff to address any new changes or best practices. 3. Enhance monitoring and oversight: • Action: Establish a robust system of internal oversight to ensure continuous compliance with UG reporting requirements. • Details: o Regular Reviews: The Executive Director will implement a schedule of regular reviews of financial records to confirm that all supporting documentation for federal awards is correctly attached and reports are filed accurately and on time. o Reporting Checklist: Create and use a standardized checklist for each federal award to ensure all specific reporting requirements are met prior to submission. o Audit Readiness: Perform periodic internal compliance checks or "mock audits" to identify and correct potential issues before an external audit. 4. Strengthen documentation and audit trail: • Action: Improve the organization and accessibility of all documentation required for UG reporting to facilitate a clear and defensible audit trail. • Details: o Centralized Record-keeping: Establish a centralized, secure digital location for all federal award documents, including grant agreements, financial reports, and supporting records. o Documentation Protocol: Implement a protocol requiring all relevant personnel to upload and correctly label all necessary documentation immediately after a transaction is completed. 5. Designate responsibility and accountability: • Action: Clearly assign responsibility for each UG compliance task to specific individuals to eliminate confusion and ensure accountability. • Details: For each grant, a lead financial staff member will be designated as the primary point of contact responsible for ensuring all UG reporting and documentation requirements are met. The Executive Director will oversee this process. Proposed Completion Date: Ongoing, starting in early 2026.