Finding 1240035 (2022-009)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2026-10-06
Audit: 414656
Organization: Akiachak Native Community (AK)

AI Summary

  • Core Issue: There are significant gaps in internal controls and compliance with procurement requirements for federal funding.
  • Impacted Requirements: Failure to adhere to procurement policies as outlined in 2 CFR sections 200.318 to 200.325, risking federal funding loss.
  • Recommended Follow-Up: Develop and implement a robust procurement policy to ensure compliance and proper documentation for all projects.

Finding Text

Finding 2022-009 Lack of Internal Controls and Noncompliance with Procurement Requirements Federal Agencies: U.S. Department of Health and Human Services and U.S. Department of the Treasury, respectively Federal Programs: Tribal Self-Governance and Determination Cluster (TSGDC) and Coronavirus State and Local Fiscal Recovery Funds (CSLFRF), respectively CFDA Numbers: 93.441 (TSGDC) and 21.027 (CSLFRF), respectively Award Number: 0243-12-0006 (TSGDC) and SLFRP2520/4754 (CSLFRF), respectively Award Year: 2020, 2021, 2022 (TSGDC) and 2021 (CSLFRF), respectively Type of Finding: Material weakness in internal control over compliance and material noncompliance. Criteria: In accordance with 2 CFR sections 200.318 to 200.325, procurement policies must be in place to ensure the Tribe is promoting full and open competition consistent with the standards of these sections. In order to ensure objective contractor performance and eliminate unfair competitive advantage, contractors that develop or draft specifications, requirements, statements of work, or invitations for bids or requests for proposals must be excluded from competing for such procurements. Condition and Context: During our testing of allowable costs charged to the TSGDC program, management could not provide adequate procurement documentation related to the clinic construction project. During our testing of allowable costs charged to the CSLFRF program, management could not provide adequate procurement documentation related to a construction project and supplies related to the water treatment system. Cause: Lack of internal controls over procurement requirements. Effect: Failure to follow compliance requirements could result in loss of federal funding or questioned costs being incurred. Questioned costs: Undetermined. Due to the lack of procurement documentation, we were unable to determine if the Community received the lowest price possible. Repeat finding: No. Recommendation: We recommend that management establish a procurement policy and ensure that the policy is followed. Management Response: Management agrees with this finding, see Corrective Action Plan.

Corrective Action Plan

Finding 2022-009 Lack of Internal Controls and Noncompliance with Procurement Requirements Name of Contact Person: Noelle George, Tribal Administrator Corrective Action Plan: Internal controls over procurement will be developed and implemented in accordance with 2 CFR 200.318 to 200.325. Micro purchase procedures will be used for expenditures up to $15,000 and small purchase methods will be used for purchases between that level and the simplified acquisition threshold (SAT) of $350,000. Competitive bidding will be implemented for contracts in excess of the SAT. Proposed Completion Date: December 31, 2026.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1240021 2022-005
    Material Weakness Repeat
  • 1240022 2022-006
    Material Weakness Repeat
  • 1240023 2022-007
    Material Weakness Repeat
  • 1240024 2022-008
    Material Weakness Repeat
  • 1240025 2022-009
    Material Weakness Repeat
  • 1240026 2022-005
    Material Weakness Repeat
  • 1240027 2022-006
    Material Weakness Repeat
  • 1240028 2022-007
    Material Weakness Repeat
  • 1240029 2022-008
    Material Weakness Repeat
  • 1240030 2022-009
    Material Weakness Repeat
  • 1240031 2022-005
    Material Weakness Repeat
  • 1240032 2022-006
    Material Weakness Repeat
  • 1240033 2022-007
    Material Weakness Repeat
  • 1240034 2022-008
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $2.66M
15.021 CONSOLIDATED TRIBAL GOVERNMENT $575,212
81.087 RENEWABLE ENERGY RESEARCH AND DEVELOPMENT $499,051
20.205 HIGHWAY PLANNING AND CONSTRUCTION $224,603
66.926 INDIAN ENVIRONMENTAL GENERAL ASSISTANCE PROGRAM (GAP) $208,732
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $143,077
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $70,144
15.029 TRIBAL COURTS $68,286
14.867 INDIAN HOUSING BLOCK GRANTS $65,537
16.841 VOCA TRIBAL VICTIM SERVICES SET-ASIDE PROGRAM $55,251
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $48,302
17.265 NATIVE AMERICAN EMPLOYMENT AND TRAINING $10,000
93.441 INDIAN SELF-DETERMINATION $2,121