FAC Explorer

Finding 1172718 (2022-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2026-02-06
Audit: 385956
Organization: Northwest Indian College (WA)
Auditor: CLIFTONLARSONALLEN LLP

AI Summary

  • Core Issue: The College lacks a system to verify that vendors are not suspended or debarred before transactions, leading to potential compliance risks.
  • Impacted Requirements: This finding violates 2 CFR 200.303, which mandates effective internal controls over federal awards and prohibits contracting with suspended or debarred parties.
  • Recommended Follow-Up: Implement a formal suspension and debarment policy and procedures to ensure compliance and prevent future issues.

Finding Text

Federal Agency: Department of the Interior, National Science Foundation, Department of Health and Human Services, and Department of Education Federal Programs: Assistance to Tribally Controlled Community Colleges and Universities, Research and Development Cluster and COVID-19 – Education Stabilization Fund Assistance Listing Numbers: 15.027, 47.076 and 93.859, and 84.425K and 84.425F Federal Award Identification Number and Year: Various Award Period: July 1, 2021 to June 30, 2022 Type of Finding: Material Weakness in Internal Control over Compliance and Other Matters Criteria: In accordance with 2 CFR 200.303, the College must establish and maintain effective internal controls over federal awards that provide reasonable assurance that the College is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. "Covered transactions" include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a passthrough entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition: 10 out of the 11 vendors tested had no documentation to ensure the vendor was not suspended or debarred at the time of purchase. At least one vendor was tested from each program. Upon Inquiry, we noted the College does not have a suspension and debarment policy or process. Questioned Costs: None. Context: The College entered into transactions with vendors before verifying they were not suspended or debarred. Cause: There is no control system in place to ensure there are no transactions entered into with suspended or debarred vendors. Effect: The College could have entered into transactions with suspended or debarred vendors. Repeat Finding: Yes, see Finding 2021-003. Recommendation: We recommend the College implement a suspension and debarment policy and corresponding procedures. Views of Responsible Officials: Management agrees with the finding and has prepared a plan to correct the finding.

Corrective Action Plan

Recommendation: We recommend the College implement a suspension and debarment policy and corresponding procedures. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College currently follows its internal control policies to document verification of vendors who may be listed in SAM for suspension and debarment. The College approved an updated procurement policy effective November 7, 2020, to adhere to Uniform Guidance. The College will strengthen (include) the suspension and debarment section to include a policy specific to Debarment and Suspension. Name of the contact person responsible for corrective action: Reatha Tom, Accounts Payable Specialist, and Clarissa Salhus, Finance Manager Planned completion date for corrective action plan: December 31, 2024

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1172688 2022-003
    Material Weakness Repeat
  • 1172689 2022-003
    Material Weakness Repeat
  • 1172690 2022-003
    Material Weakness Repeat
  • 1172691 2022-004
    Material Weakness Repeat
  • 1172692 2022-004
    Material Weakness Repeat
  • 1172693 2022-004
    Material Weakness Repeat
  • 1172694 2022-005
    Material Weakness Repeat
  • 1172695 2022-005
    Material Weakness Repeat
  • 1172696 2022-005
    Material Weakness Repeat
  • 1172697 2022-006
    Material Weakness Repeat
  • 1172698 2022-006
    Material Weakness Repeat
  • 1172699 2022-006
    Material Weakness Repeat
  • 1172700 2022-007
    Material Weakness Repeat
  • 1172701 2022-008
    Material Weakness Repeat
  • 1172702 2022-003
    Material Weakness Repeat
  • 1172703 2022-008
    Material Weakness Repeat
  • 1172704 2022-003
    Material Weakness Repeat
  • 1172705 2022-005
    Material Weakness Repeat
  • 1172706 2022-008
    Material Weakness Repeat
  • 1172707 2022-003
    Material Weakness Repeat
  • 1172708 2022-003
    Material Weakness Repeat
  • 1172709 2022-003
    Material Weakness Repeat
  • 1172710 2022-003
    Material Weakness Repeat
  • 1172711 2022-003
    Material Weakness Repeat
  • 1172712 2022-003
    Material Weakness Repeat
  • 1172713 2022-003
    Material Weakness Repeat
  • 1172714 2022-003
    Material Weakness Repeat
  • 1172715 2022-009
    Material Weakness Repeat
  • 1172716 2022-003
    Material Weakness Repeat
  • 1172717 2022-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 EDUCATION STABILIZATION FUND $3.93M
15.027 ASSISTANCE TO TRIBALLY CONTROLLED COMMUNITY COLLEGES AND UNIVERSITIES $1.78M
84.063 FEDERAL PELL GRANT PROGRAM $1.50M
84.031 Higher Education Institutional Aid - Title III - 2021-2022 Part A $921,111
84.031 Higher Education Institutional Aid - Title III - Formula Funds 2021-2022 Part F $589,587
93.859 Native American Research Centers for Health - AIWIRE $412,988
47.076 STEM Education - Instructional Capacity Excellence in Tribal Colleges and Universities Programs $382,398
84.031 Higher Education Institutional Aid - Title III - Formula Funds 2020-2021 Part F $350,877
84.101 CAREER AND TECHNICAL EDUCATION - GRANTS TO NATIVE AMERICANS AND ALASKA NATIVES $284,963
47.076 STEM Education - Targeted STEM Infusion Projects - Salish Sea Research Center Summer Science $227,135
10.221 TRIBAL COLLEGES EDUCATION EQUITY GRANTS $215,362
15.027 ASSISTANCE TO TRIBALLY CONTROLLED COMMUNITY COLLEGES AND UNIVERSITIES - FI&R $191,121
47.076 STEM Education - Scholarships in Science, Technology, Engineering, and Mathematics Program (S-STEM) $184,009
84.250 TVR Institute - NAU Subaward $168,115
93.243 SAMHSA - Native Connections $159,755
10.500 Cooperative Extension Service - Indigenous Community Engagement $120,499
10.222 TRIBAL COLLEGES ENDOWMENT PROGRAM $120,319
93.243 SAMHSA - Native Connections Project $119,974
84.315 Traditionally Underserved Populations - Tribal Vocational Rehabilitation $96,441
43.001 SCIENCE - Water Quality Algorithms $91,956
84.031 Higher Education Institutional Aid - Title III - 2017-2018 $91,518
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) - Esteem $91,007
10.227 1994 INSTITUTIONS RESEARCH GRANTS - eDNA Longfin Smelt $86,569
93.859 Native American Research Centers for Health - 11 $84,355
93.243 SAMHSA - Northwest Washington Indian Health Board $83,828
93.243 SAMHSA -Northwest Indian College - Native Connections $71,142
93.243 SAMHSA - Northwest Washington Indian Health Board Native Connections Project $68,404
47.076 STEM Education - Digital Divide $68,298
10.500 Cooperative Extension Service - Traditional Foods and Plants $66,673
11.478 CENTER FOR SPONSORED COASTAL OCEAN RESEARCH COASTAL OCEAN PROGRAM - University of California, Santa Cruz - National Oceanic and Atmospheric Administration/Algal Toxins $61,210
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) - National Aeronautics and Space Administration - STEM $46,635
84.031 Higher Education Institutional Aid - Title III - 2016-2017 $41,769
10.227 1994 INSTITUTIONS RESEARCH GRANTS - Paralytic Shellfish Toxins $33,652
84.033 FEDERAL WORK-STUDY PROGRAM $33,409
10.766 COMMUNITY FACILITIES LOANS AND GRANTS - Community Funds 2021 $30,870
10.500 Cooperative Extension Service - Financial Literacy Development $30,475
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $27,118
10.227 1994 INSTITUTIONS RESEARCH GRANTS - Mentor Students $23,393
84.031 Higher Education Institutional Aid - Title III - 2018-2019 $21,827
15.156 TRIBAL CLIMATE RESILIENCE - Youth Engagement $20,363
10.224 FUND FOR RURAL AMERICA_RESEARCH, EDUCATION, AND EXTENSION ACTIVITIES - Buoy $18,611
47.076 STEM Education - Tribal Colleges and Universities Programs Enterprise Advancement Centers Center $17,852
47.075 STEM Education - Ethical STEM $14,238
10.766 COMMUNITY FACILITIES LOANS AND GRANTS - Health & Wellness Equipment $10,268
15.156 TRIBAL CLIMATE RESILIENCE - Microgrid Feasibility Study $9,798
47.076 STEM Education - SEA PHAGES II $9,702
93.243 SAMHSA - Lummi Indian Business Council - Native Connections $9,301
93.732 NPAIHB $7,177
10.227 1994 INSTITUTIONS RESEARCH GRANTS - SWAT Model $7,047
11.417 Washington Sea Grant (WSG) Omnibus 2022 $6,676
45.311 NATIVE AMERICAN AND NATIVE HAWAIIAN LIBRARY SERVICES $6,525
10.224 FUND FOR RURAL AMERICA_RESEARCH, EDUCATION, AND EXTENSION ACTIVITIES - National Disaster Resilience - Diets $5,253
10.766 COMMUNITY FACILITIES LOANS AND GRANTS - Parking Lot 2020 $5,008
10.500 Cooperative Extension Service - Food Sovereignty $4,980
93.U01 Ethical Genomics $3,321
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) - CHARM $2,742
47.076 STEM Education - Connections to Water $1,792
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) - Space Grant $1,525
84.002 Adult Education - State Basic Skills $-190
84.002 Adult Education - Train the Trainer $-411
10.500 Cooperative Extension Service - Distance Learning and Telemedicine $-2,255
84.002 Adult Education - BEDA CBO State Grant $-2,843
84.031 Higher Education Institutional Aid - Title III - Formula Funds $-100,350