Finding Text
Program Information: Assistance Listing #: 93.445 U.S. Department of Health and Human Services I.H.S. Water Tank Replacement Award Numbers: PH12-U35, RN0222 Award Periods: 7/29/2021-7/29/2025 Assistance Listing #: 21.027 U.S. Department of the Treasury COVID-19 American Rescue Plan Act - 2021 Award Numbers: SLFRP3186, SLFRP4785 Award Periods: 8/13/2021 - 12/31/2026, 6/4/2021 - 12/31/2026 Assistance Listing #: 11.029 U.S. Department of Commerce National Telecommunication & Information Adm. Award Number: NT23TBC0290003 Award Period: 12/1/2022-11/30/2026 Criteria: 2 CFR § 200.303 - Internal controls states, the non-Federal entity must: (a) Establish and maintain effective internal control over the federal award that provides reasonable assurance that the non-federal entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: During testing, we noted the following: 21.027 • 1 of 11 Non-IDC Individually Important Items (IIIs) did not have an indication of review/approval of a journal entry (JE) reallocating funds from the program. • 2 of 2 IDC IIIs did not have indication of review/approval on the indirect cost allocation JE. 93.445 • 5 of 7 Non-IDC IIIs had no purchase requisition documentation provided. • 1 of 1 IDC IIIs did not have indication of review/approval on the indirect cost allocation JE. 11.029 • 7 of 11 IIIs had no purchase requisition documentation provided. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Tribe has limited fiscal staffing and experienced personnel changes during 2025 and 2026. As a result, procedures for documenting and retaining and locating evidence of review and approval were not consistently followed for journal entries and purchase requisitions. Effect: The lack of documented review and approval increases the risk that errors, misstatements, or unauthorized transactions may not be prevented or detected and corrected in a timely manner. Additionally, without documentation of the review and approval, the Tribe is unable to demonstrate that established internal control procedures were consistently performed. Questioned Costs: None noted, testing did not identify any unallowable, unsupported, or otherwise questioned expenditures related to the items tested. Repeat Finding: No. Recommendation: We recommend the Tribe strengthen its internal controls over federal expenditures by ensuring that purchase requisitions, journal entries, and indirect cost allocation entries are reviewed and approved by appropriate personnel prior to processing. Evidence of the review and approval should be consistently documented and retained in accordance with Tribal policies. 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.