Finding 1240565 (2022-007)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2022
Accepted
2026-10-15
Audit: 414987
Organization: NUNAKAUYARMIUT TRIBE (AK)

AI Summary

  • Core Issue: The Council lacked proper internal controls to ensure compliance with environmental review requirements for federal funding.
  • Impacted Requirements: Failure to maintain documentation as per 2 CFR § 200.303 and environmental review criteria jeopardizes compliance with federal statutes.
  • Recommended Follow-up: Establish procedures to complete environmental reviews before funding activities and retain necessary documentation for compliance.

Finding Text

Finding 2022-007 Lack of Internal Control Over Special Test and Provisions – Environmental Review Federal Agency: U.S. Department of Housing and Urban Development Federal Program: Indian Community Block Development Grant Assistance Listing Number: 14.682 Award Numbers: 22RPO216400 Award Year: 2022 Type of Finding: Material weaknesses in internal control over compliance and noncompliance. Criteria: Recipients of federal awards are required to comply with applicable environmental review requirements associated with the federal program and maintain sufficient documentation to demonstrate compliance with those requirements. Additionally, 2 CFR § 200.303 requires non-federal entities to establish and maintain effective internal control over the federal award that provides reasonable assurance that the entity is managing the award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. Condition and Context: During our audit, the Council failed to provide adequate supporting documentation demonstrating that the required environmental review was completed or that the funded activities were determined to be exempt or otherwise not subject to environmental review requirements as applicable. As a result, we were unable to verify that the Tribe had complied with Special Testing requirements applicable to the federal award. Cause: The Council did not have adequate procedures in place to ensure that documentation supporting compliance with applicable environmental review requirements was retained and readily available for federally funded activities. Effect: Failure to follow compliance requirements could result in a loss of federal funding. Questioned Costs: None. Repeat Finding: No, this is not a repeat finding. Recommendation: We recommend that the Council establish and implement procedures to ensure that environmental reviews required by the federal program are completed before federally funded activities are undertaken, when applicable. The Council should also maintain documentation demonstrating completion of the environmental review, exemption or exclusion determinations, approvals, and other applicable environmental compliance requirements for the required record-retention period. Management Response: Management concurs with this finding. See Corrective Action Plan.

Corrective Action Plan

Finding 2022-007 Lack of Internal Control Over Special Test and Provisions – Environmental Review Name of Contact Person: Dora Mathew, Tribal executive Director Mary Carl, Tribal Financial Officer Corrective Action Plan: Nunakauyarmiut Tribe concurs with the finding and has strengthened procedures to ensure required environmental reviews are completed and documented before federally funded activities proceed when environmental review requirements apply. For HUD-funded activities, the Tribe will identify the applicable environmental review requirements at the beginning of the project and maintain the Environmental Review Record and related supporting documentation in the grant file. No choice-limiting action, commitment of funds, or project activity requiring environmental clearance will proceed until the required environmental review process and applicable HUD approvals or releases have been completed. Administration, Finance, Housing, and project personnel will coordinate before procurement, contracting, construction, or other project commitments to verify environmental clearance status. Documentation of exemptions, categorical exclusions, environmental reviews, public notices, requests for release of funds, HUD approvals, and related records will be retained as applicable. Staff responsible for HUD projects will seek HUD technical assistance or training when needed to ensure continued compliance. Proposed Completion Date: September 30, 2026.

Categories

Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 1240563 2022-004
    Material Weakness Repeat
  • 1240564 2022-005
    Material Weakness Repeat
  • 1240566 2022-006
    Material Weakness Repeat
  • 1240567 2022-003
    Material Weakness Repeat
  • 1240568 2022-004
    Material Weakness Repeat
  • 1240569 2022-005
    Material Weakness Repeat
  • 1240570 2022-002
    Material Weakness Repeat
  • 1240571 2022-004
    Material Weakness Repeat
  • 1240572 2022-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.09M
14.862 INDIAN COMMUNITY DEVELOPMENT BLOCK GRANT PROGRAM $1.03M
20.933 NATIONAL INFRASTRUCTURE INVESTMENTS $841,315
84.356 ALASKA NATIVE EDUCATIONAL PROGRAMS $343,787
15.030 INDIAN LAW ENFORCEMENT $186,438
15.020 AID TO TRIBAL GOVERNMENTS $115,310
66.926 INDIAN ENVIRONMENTAL GENERAL ASSISTANCE PROGRAM (GAP) $95,310
15.141 INDIAN HOUSING ASSISTANCE $67,313
15.024 INDIAN SELF-DETERMINATION CONTRACT SUPPORT $54,538
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $36,997
20.205 HIGHWAY PLANNING AND CONSTRUCTION $31,149
93.587 PROMOTE THE SURVIVAL AND CONTINUING VITALITY OF NATIVE AMERICAN LANGUAGES $10,400
15.021 CONSOLIDATED TRIBAL GOVERNMENT $7,809
15.130 INDIAN EDUCATION ASSISTANCE TO SCHOOLS $416