Finding 1218982 (2024-005)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2026-06-26
Audit: 404989
Organization: Cheyenne and Arapaho Tribes (OK)
Auditor: REDW LLC

AI Summary

  • Core Issue: The Department failed to verify that vendors were not suspended or debarred for two out of five procurements tested, and sole source justifications did not meet policy requirements.
  • Impacted Requirements: Compliance with procurement standards outlined in the Uniform Guidance and the Department’s internal policies.
  • Recommended Follow-Up: Revise procedures to ensure vendor eligibility checks and strengthen sole source justification processes; management is already working on updated policies pending approval.

Finding Text

2024-005 – Procurement, Suspension, and Debarment – Significant Deficiency Federal program information: Funding agency: U.S. Department of Treasury Title: Coronavirus State and Local Fiscal Recovery Funds Assistance listing number: 21.027 Award year: December 31, 2024 Award number: COVID-19 Funding Criteria: In accordance with the program’s contract provisions, recipients may use award funds to enter into contracts to procure goods and services necessary to implement the eligible purposes outlined by the treasury. Recipients are expected to follow procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance. Condition/Context: For two of five procurements tested, the Department could not provide evidence that procedures were performed to ensure vendors were not suspended or debarred from receiving federal funding for services rendered. In addition, for two of five procurements tested, sole source justifications were identified that did not meet the Department’s policy requirements. Cause and Effect: The Department did not have appropriate internal control policies and procedures in place to ensure selected vendors were not suspended or debarred and that sole source procurements were adequately justified in accordance with the Department’s policy. As a result, federal funding could be awarded to vendors not entitled to receive federal funds. Questioned Costs: None. Identification as a Repeat Finding: This is a repeat finding from the prior year. This finding was reported as finding 2023-005 in the 2023 report. Recommendations: We recommend revising the Department’s procedures to ensure vendors with which the Department procures goods and services are not federally suspended or debarred. We also recommend revising the Department strengthen procedures over sole source procurements to ensure justifications are prepared, reviewed, and maintained in accordance with Department policy and the Uniform Guidance.. Views of Responsible Officials: Management concurs with the finding. Procurement, Grants, and Contracts has developed updated policies and procedures intended to strengthen procurement controls and support compliance with applicable federal requirements, including vendor suspension and debarment verification. These policies and procedures have been submitted for approval but have not yet been formally adopted. In the interim, management will continue working with the responsible departments to support implementation efforts and strengthen procurement practices while formal approval is pending.

Corrective Action Plan

The Department of Treasury is working closely with the Procurement, Grants, and Contracts program to monitor and enforce proper internal controls and reviews for vendors. Procurement and Accounts Payable teams have been notified of the required SAM.gov checks and related documentation requirements. Person Responsible: Kayla Tallbear, Acting Treasurer Estimated Completion Date: December 31, 2027

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1218975 2024-003
    Material Weakness Repeat
  • 1218976 2024-003
    Material Weakness Repeat
  • 1218977 2024-003
    Material Weakness Repeat
  • 1218978 2024-003
    Material Weakness Repeat
  • 1218979 2024-003
    Material Weakness Repeat
  • 1218980 2024-004
    Material Weakness Repeat
  • 1218981 2024-004
    Material Weakness Repeat
  • 1218983 2024-006
    Material Weakness Repeat
  • 1218984 2024-006
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 COVID-19 - CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $15.97M
21.032 COVID-19 - LOCAL ASSISTANCE AND TRIBAL CONSISTENCY FUND $3.38M
10.567 FOOD DISTRIBUTION PROGRAM ON INDIAN RESERVATIONS $2.42M
93.441 INDIAN SELF-DETERMINATION $2.09M
93.600 HEAD START $1.60M
20.205 HIGHWAY PLANNING AND CONSTRUCTION $1.24M
16.596 TRIBAL JUSTICE ASSISTANCE $956,090
15.025 SERVICES TO INDIAN CHILDREN, ELDERLY AND FAMILIES $924,842
15.U01 Public Law 102-477 Program (477 Cluster) $894,729
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $892,524
93.237 SPECIAL DIABETES PROGRAM FOR INDIANS DIABETES PREVENTION AND TREATMENT PROJECTS $857,023
10.937 PARTNERSHIPS FOR CLIMATE-SMART COMMODITIES $681,786
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $595,122
15.114 INDIAN EDUCATION HIGHER EDUCATION GRANT $562,886
84.415 INDIAN EDUCATION NATIONAL ACTIVITIES (STATE TRIBAL EDUCATION PARTNERSHIP (STEP) AND NATIVE AMERICAN LANGUAGE (NAL) $535,878
93.495 COVID-19 - COMMUNITY HEALTH WORKERS FOR PUBLIC HEALTH RESPONSE AND RESILIENT $467,978
20.509 FORMULA GRANTS FOR RURAL AREAS AND TRIBAL TRANSIT PROGRAM $427,805
93.596 CHILD CARE MANDATORY AND MATCHING FUNDS OF THE CHILD CARE AND DEVELOPMENT FUND $426,200
93.441 COVID-19 - INDIAN SELF-DETERMINATION $418,005
15.228 BLM FUELS MANAGEMENT AND COMMUNITY FIRE ASSISTANCE PROGRAM ACTIVITIES $370,877
20.509 COVID-19 - FORMULA GRANTS FOR RURAL AREAS AND TRIBAL TRANSIT PROGRAM $350,892
15.130 INDIAN EDUCATION ASSISTANCE TO SCHOOLS $297,536
10.182 COVID-19 - PANDEMIC RELIEF ACTIVITIES: LOCAL FOOD PURCHASE AGREEMENTS WITH STATES, TRIBES, AND LOCAL GOVERNMENTS $248,038
93.568 LOW-INCOME HOME ENERGY ASSISTANCE $217,283
15.029 TRIBAL COURTS $186,401
93.933 DEMONSTRATION PROJECTS FOR INDIAN HEALTH $181,253
93.671 FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $167,562
15.144 INDIAN CHILD WELFARE ACT TITLE II GRANTS $151,264
15.020 COVID-19 - AID TO TRIBAL GOVERNMENTS $146,051
15.035 FORESTRY ON INDIAN LANDS $145,073
93.387 COVID-19 - NATIONAL AND STATE TOBACCO CONTROL PROGRAM $139,277
15.051 ENDANGERED SPECIES ON INDIAN LANDS $136,874
84.250 AMERICAN INDIAN VOCATIONAL REHABILITATION SERVICES $131,649
10.558 COVID-19 - CHILD AND ADULT CARE FOOD PROGRAM $131,095
16.750 SUPPORT FOR ADAM WALSH ACT IMPLEMENTATION GRANT PROGRAM $124,513
16.608 TRIBAL JUSTICE SYSTEMS $122,407
15.024 INDIAN SELF-DETERMINATION CONTRACT SUPPORT $120,662
16.841 VOCA TRIBAL VICTIM SERVICES SET-ASIDE PROGRAM $105,493
93.575 COVID-19 - CHILD CARE AND DEVELOPMENT BLOCK GRANT $101,409
93.047 SPECIAL PROGRAMS FOR THE AGING, TITLE VI, PART A, GRANTS TO INDIAN TRIBES, PART B, GRANTS TO NATIVE HAWAIIANS $98,416
93.556 MARYLEE ALLEN PROMOTING SAFE AND STABLE FAMILIES PROGRAM $96,543
66.926 INDIAN ENVIRONMENTAL GENERAL ASSISTANCE PROGRAM (GAP) $93,204
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $91,027
93.499 LOW INCOME HOUSEHOLD WATER ASSISTANCE PROGRAM $90,947
84.299 INDIAN EDUCATION -- SPECIAL PROGRAMS FOR INDIAN CHILDREN $87,879
93.054 NATIONAL FAMILY CAREGIVER SUPPORT, TITLE VI, PART C, GRANTS TO INDIAN TRIBES AND NATIVE HAWAIIANS $87,601
16.812 SECOND CHANCE ACT REENTRY INITIATIVE $83,187
15.020 AID TO TRIBAL GOVERNMENTS $81,349
66.815 BROWNFIELDS JOB TRAINING COOPERATIVE AGREEMENTS $77,935
81.254 GRID INFRASTRUCTURE DEPLOYMENT AND RESILIENCE $64,374
93.421 STRENGTHENING PUBLIC HEALTH SYSTEMS AND SERVICES THROUGH NATIONAL PARTNERSHIPS TO IMPROVE AND PROTECT THE NATION€™S HEALTH $58,106
93.671 COVID-19 - FAMILY VIOLENCE PREVENTION AND SERVICES/DOMESTIC VIOLENCE SHELTER AND SUPPORTIVE SERVICES $56,785
66.419 WATER POLLUTION CONTROL STATE, INTERSTATE, AND TRIBAL PROGRAM SUPPORT $54,437
66.708 POLLUTION PREVENTION GRANTS PROGRAM $53,771
15.041 ENVIRONMENTAL MANAGEMENT INDIAN $49,196
93.788 OPIOID STR $42,343
93.645 STEPHANIE TUBBS JONES CHILD WELFARE SERVICES PROGRAM $38,528
93.054 COVID-19 - NATIONAL FAMILY CAREGIVER SUPPORT, TITLE VI, PART C, GRANTS TO INDIAN TRIBES AND NATIVE HAWAIIANS $37,745
93.497 FAMILY VIOLENCE PREVENTION AND SERVICES/ SEXUAL ASSAULT/RAPE CRISIS SERVICES AND SUPPORTS $31,291
93.594 TRIBAL WORK GRANTS $30,556
93.569 COMMUNITY SERVICES BLOCK GRANT $26,850
93.047 COVID-19 - SPECIAL PROGRAMS FOR THE AGING, TITLE VI, PART A, GRANTS TO INDIAN TRIBES, PART B, GRANTS TO NATIVE HAWAIIANS $24,649
93.053 NUTRITION SERVICES INCENTIVE PROGRAM $17,908
15.040 REAL ESTATE PROGRAMS INDIAN LANDS $14,761
15.954 NATIONAL PARK SERVICE CONSERVATION, PROTECTION, OUTREACH, AND EDUCATION $14,676
93.479 GOOD HEALTH AND WELLNESS IN INDIAN COUNTRY $12,653
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $9,623
15.034 AGRICULTURE ON INDIAN LANDS $5,756
20.600 STATE AND COMMUNITY HIGHWAY SAFETY $3,790
66.818 BROWNFIELDS MULTIPURPOSE, ASSESSMENT, REVOLVING LOAN FUND, AND CLEANUP COOPERATIVE AGREEMENTS $3,016