Finding 1218801 (2025-002)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2025
Accepted
2026-06-25
Audit: 404885
Organization: Ponca Tribe of Nebraska (NE)

AI Summary

  • Core Issue: Lack of documentation for review and approval of eligibility files for Assistance Listings #93.441 and #93.912.
  • Impacted Requirements: Compliance with federal eligibility criteria and internal controls as per 2 CFR § 200.303.
  • Recommended Follow-Up: Implement procedures to ensure all eligibility determinations are reviewed, approved, and documented properly.

Finding Text

Program Information: U.S. Department of Health and Human Services Tribal Self-Governance and Determination Cluster Assistance Listing #93.441 Award Numbers: HHS-I-241-2022-00004 and HHS-I-241-2019-00003 Award Period: 10/1/2024-9/30/2027 and 10/1/2020-9/30/2021 Rural Health Outreach and Rural Network Development Program Assistance Listing #93.912 Award Numbers: 6 G28RH46294-03-00 and 6 HB1RH47073-03-02 Award Period: 9/30/2022-9/29/2025 and 9/1/2022-8/31/2026 Criteria: Assistance Listing #93.441 Per the compliance supplement and 42 CFR 136.12, eligible individuals include those of Indian descent belonging to the local Indian community, as evidenced by tribal membership or similar factors. Additional eligibility covers non-Indian women pregnant with an eligible Indian’s child, certain non-Indian household members for public health reasons, and specific children and spouses per 25 USC 1680c(a)-(b) and Section 813 of the Indian Health Care Improvement Act. For Purchased/Referred Care (PRC), individuals must reside in the U.S. within a PRC Delivery Area, be a member of or have close ties to the relevant tribe(s), and meet requirements for students, transients, and foster children as specified in the supplement. Assistance Listing #93.912 Per discussion with the program’s Chief Behavioral Health Officer, individuals must provide documentation of membership in a federally recognized Tribe (e.g., Tribal enrollment card, Certificate of Indian Blood, or proof of lineal descent) and a signed consent to receive services. Registration staff are responsible for screening and securely filing these documents in the practice management system. Per 2 CFR § 200.303, recipients must establish and maintain effective internal controls over federal awards to ensure compliance with applicable regulations. Condition/Context: Assistance Listing #93.441 Of the 60 samples selected for testing, documentation to evidence review and approval was not provided. Assistance Listing #93.912 Of the 5 samples selected for testing, documentation to evidence review and approval was not provided. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: The program did not have adequate internal controls to ensure that all eligibility files included documentation of review and approval. This appears to be due to a lack of oversight and monitoring procedures to track compliance with this documentation requirement. Effect: Without adequate documentation of review and approval, there is an increased risk that ineligible individuals may receive services, and the entity may not be able to demonstrate compliance with federal eligibility requirements. This could result in questioned costs or findings in future audits. Questioned Cost: N/A – none of the samples selected for testing were determined to be ineligible to receive services. Prior Year Finding: Yes, 2024-004. Recommendation: We recommend that management implement and enforce procedures to ensure that all eligibility determinations are reviewed and approved, and that supporting documentation of such review and approval is consistently maintained in the appropriate system or file. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Corrective Action Plan

Persons responsible for corrective action: Keith Morrow, Health Services Chief Executive Officer Corrective action planned: Developed and implemented process by which Business Services staff in Health Services review documents provided by non-Ponca Native Americans upon initial request for services and on an annual basis to follow to confirm and verify their capacity to receive health services from the Ponca Tribe. Steps have been taken to see the staff verifying are independent from those who initially collect such documents. Additionally, confirmed such process is consistent with existing verification review of Ponca members requesting services. Implementation date: December 1, 2025.

Categories

Eligibility Internal Control / Segregation of Duties Procurement, Suspension & Debarment Subrecipient Monitoring HUD Housing Programs Material Weakness Significant Deficiency

Other Findings in this Audit

  • 1218797 2025-002
    Material Weakness Repeat
  • 1218798 2025-002
    Material Weakness Repeat
  • 1218799 2025-002
    Material Weakness Repeat
  • 1218800 2025-002
    Material Weakness Repeat
  • 1218802 2025-003
    Material Weakness Repeat
  • 1218803 2025-003
    Material Weakness Repeat
  • 1218804 2025-003
    Material Weakness Repeat
  • 1218805 2025-003
    Material Weakness Repeat
  • 1218806 2025-003
    Material Weakness Repeat
  • 1218807 2025-003
    Material Weakness Repeat
  • 1218808 2025-003
    Material Weakness Repeat
  • 1218809 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
93.441 Indian Self Determination $7.30M
20.205 Tribal Transportation Program $2.06M
21.027 COVID 19 - State and Local Fiscal Recovery Funds $1.42M
20.205 Tribal Transit $1.14M
10.182 Local Food Purchase Assistance Cooperative $860,335
21.032 COVID-19 Local Assistance and Tribal Consistency Fund $828,500
93.441 COVID-19-Indian Self Determination (ARPA) $825,940
20.509 Rural Transit Program $767,084
15.021 Consolidated Tribal Government Program $764,738
93.647 Ponca Tribe of Nebraska Diaper Distribution Program $692,271
93.872 Tribal Maternal, Infant, and Early Childhood Home Visiting $673,595
93.912 Rural Health Outreach and Rural Network Development Program $565,665
20.205 TTP Roads Maintenance $558,289
93.243 Ponca Health Services Medication- Assisted Treatment Project $543,603
93.654 Indian Health Services Behavioral Health Programs $520,580
93.237 Special Diabetes Program for Indians $453,835
93.575 Childcare and Development Block Grants - Discretionary $398,621
66.605 Performance Partnership Grants $379,952
20.509 Tribal Transit Program $362,723
93.231 Native Public Health Resilience $331,733
16.587 Grants for Indian Tribal Governments $303,805
93.441 COVID-19-Indian Self Determination (CARES) $288,614
17.265 Native American Employment and Training $285,134
15.029 Tribal Courts $284,044
20.205 Tribal Transportation Planning $280,038
93.479 Good Health and Wellness in Indian Country $217,503
21.029 COVID-19 Coronavirus Capital Projects Fund $185,647
66.034 Surveys-Studies-Investigations-Demonstrations and Special Purpose Activities relating to the Clean Air Act $168,488
93.243 Substance Abuse and Mental Health Services_Projects of Regional and National Significance $167,352
93.653 Domestic Violence Prevention Program $153,927
16.841 Tribal Victim Services Set-Aside Formula Grant Program $133,842
10.384 Indigenous Animals Harvesting & Meat Processing Grant $128,926
16.021 Justice Systems Response to Families $128,087
15.519 Indian Tribal Water Resources Development, Mgmt & Protection $117,115
16.841 Tribal Victim Services Program $114,731
93.586 State & Tribal Court Improvement Program $74,323
15.141 COVID 19 - Housing Improvement Program - (ARPA) $68,066
20.509 COVID-19-Tribal Transit Program $65,361
20.205 TTP NPHA Elders Complex $61,691
93.047 Special Program for the Aging, Title VI, Part A, Grants to Indian Tribes $45,291
15.025 Services to Indian Children, Elderly and Families $44,622
15.051 Endangered Species on Indian Land $36,975
93.671 Domestic Violence (Family Violence) $28,603
66.817 State and Tribal Response Program Grants $24,064
93.069 Bioterrorism $23,265
15.025 COVID-19 Services to Indian Children, Elderly and Families (ARPA) $22,170
97.137 Tribal Cybersecurity Grant Program $21,769
93.596 Childcare and Development Block Grants - Mandatory $20,338
16.731 Ponca Project Venture $18,734
15.025 Services to Indian Children, Elderly and Families (Tribal Youth Initiative Program) $17,891
93.556 Promoting Safe & Stable Families $17,162
93.612 Native American Programs $16,487
93.054 (OATC) Older Americans Act Title VI, Part C - Grants for Native American Caregiver Support $12,368
93.898 Great Plains Cancer Control Program $9,986
45.311 American Library Services Grant $9,809
93.898 Great Plains Breast &Cervical Cancer Early Detection Program(GP-BCCEDP) $9,742
93.982 Family Violence Prevention and Services/ Sexual Assault/Rape Crisis Services and Supports $7,923
93.569 Community Services Block Grant $7,573
93.645 Child Welfare Services $7,541
15.904 Historic Preservation $7,379
93.674 Chafee Foster Care Independent Living $5,922
93.318 Protecting and Improving Health Globally: Building and Strengthening Public Health Impact, Systems, Capacity and Security $5,384
16.582 OVC Pet Shelter Grant $5,065
93.671 Family Violence Prevention and Services/Domestic Violence Shelter and Supportive Services $4,982
15.130 Johnson O'Malley Program $4,567
45.024 Promotion of the Arts Grants to Organizations and Individuals $4,500
15.020 Aid to Tribal Government $4,412
93.071 (MITR) MIPPA Grants to Title VI Native Americans $4,078
16.841 VOCA Tribal Victim Services Set-Aside Program $3,632
15.029 Appellate Court $2,890
15.935 National Trail System Projects $2,033
93.054 COVID 19 - (TCC6) American Rescue Plan (ARP) for OAA Title VI Part C Native American Caregivers (ARPA) $367
93.994 Maternal and Child Health Services Block Grant to States $364
20.205 TTP HIP Supplemental Funding $99