Finding 38606 (2022-004)

Material Weakness
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2023-09-29
Audit: 34680
Organization: Narragansett Indian Tribe (RI)
Auditor: Wipfli LLP

AI Summary

  • Core Issue: The Tribe lacks effective internal controls over expenditures, leading to unauthorized payments and inadequate documentation.
  • Impacted Requirements: Missing approvals from the Finance Director and insufficient supporting documentation violate compliance standards for allowable costs and activities.
  • Recommended Follow-Up: Strengthen disbursement controls and ensure all expenditures have proper authorization and documentation to mitigate fraud risk.

Finding Text

Internal Controls and Compliance over Allowable Cost and Allowable Activity - Expenditures Federal Program Information: Funding agency: Department of the Interior Department of Treasury Department of Health and Human Services Title: Aid to Tribal Government Consolidated Tribal Government Programs Coronavirus State and Local Fiscal Recovery Funds Child Care and Development Block Grant & Child Care Mandatory and Matching Funds of the Child Care and Development Fund - Clusters AL number: 15.020; 15,021; 21.027; 93.575 & 93.596 Award year and number: A08AV0089; SLT0380 and 21PARICDC6 & 22PARICCDF Criteria or Specific Requirement: Effective internal controls over the expenditure process should be properly designed to provide assurance of meeting compliance requirements and should operate effectively. All disbursements should have proper written authorization supported with adequate documentation. Disbursement policies and procedures require the signature of the Finance Director and Tribal Administrator or Chief Sachem for authorization. If the Finance Director is unavailable, his signing authority is delegated to Chief Sachem via a delegation of authority form, who is already a required signer. Condition: During our testing of controls over expenditures and capital asset additions, the following exceptions were noted: AL 15.020 The Tribe paid one individual a total of $2,300 for expenditures related to the public health emergency with respect to Covid-19 without adequate approval. They were missing the Finance Director approval. In addition, because of the inadequate support provided we were unable to determine whether the expenditures were allowable costs or allowable activities. On the capital asset additions testing, two samples totaling $19,588 were missing the Finance Director approval and the required three bids with council approval. AL 15.021 On the expenditure testing, out of thirty samples tested, ten samples totaling $10,166 had supporting documentation that was inadequate and we were unable to determine whether the expenditures were an allowable cost or allowable activity. Without any documented delegation support, we were unable to determine the delegation authority of the Finance Director for two samples totaling $3,573 of the thirty samples tested. On the capital asset additions testing, one sample of $1,981 was missing the Finance Director approval and the required three bids with council approval. AL 21.027 On the expenditure testing, out of thirty samples, nine samples totaling $22,000 had inadequate supporting documentation. Therefore, we were unable to determine whether the expenditures were an allowable cost or allowable activity. The Tribe paid one individual a total of $600 for an expenditure related to the public health emergency with respect to Covid-19 without the Finance Director approval. On the capital asset additions testing, out of five samples tested, three samples totaling $14,175 were missing the Finance Director approval and one sample of $5,175 was missing the required three bids with council approval. AL 93.575 & 93.596 On the expenditure testing, out of thirty samples selected we were not provided any supporting documents for four samples totaling $4,857. In addition, four samples totaling $3,454 had inadequate supporting documentation. Therefore, we were unable to determine whether the expenditures were an allowable cost or allowable activity. Two samples totaling $810 were missing the Finance Director approval. On the capital asset additions testing, out of four samples tested, three samples totaling $84,217 were missing the Finance Director approval and one sample of $14,568 was missing the required three bids with council approval. Follow up on 2021 AL 21.019 finding On the expenditure testing, out of the twenty five samples tested, five samples totaling $11,873 were missing supporting documentation. Six samples totaling $10,990 had supporting documentation provided that was inadequate. Therefore, we were unable to determine whether the expenditures were an allowable cost or allowable activity. The Tribe paid one individual a total of $1,500 for expenditures related to the public health emergency with respect to Covid-19 without adequate supporting documentation. Therefore, we were unable to determine whether the expenditures were allowable costs or allowable activities. On the capital asset additions testing, two samples totaling $15,000 had supporting documentation that was inadequate. Therefore, we were unable to determine whether the expenditures were an allowable cost or an allowable activity. Three samples tested totaling $28,400 were missing the Finance Director approval. Context: We inquired with management and tested two hundred and nine expenditure samples. Questioned Costs: AL 15.020 $600 and prior year follow up AL 21.019 $1,500. Effect: The lack of effective and consistent internal controls exposes the Tribe to a greater risk of fraudulent activities. Cause: Internal control procedures are not properly designed to ensure transactions are authorized prior to payments. Repeat: Yes - Years as Repeat Finding: Three 2021-004 Auditor's Recommendation: We recommend the Tribe strengthen its implementation on controls over disbursement. View of Responsible Officials: Management agrees with the audit finding and they have a plan in place to correct the finding.

Categories

Matching / Level of Effort / Earmarking Procurement, Suspension & Debarment Allowable Costs / Cost Principles

Other Findings in this Audit

  • 38601 2022-004
    Material Weakness Repeat
  • 38602 2022-004
    Material Weakness Repeat
  • 38603 2022-005
    Material Weakness
  • 38604 2022-004
    Material Weakness
  • 38605 2022-006
    Significant Deficiency
  • 38607 2022-006
    Significant Deficiency
  • 38608 2022-004
    Significant Deficiency
  • 615043 2022-004
    Material Weakness Repeat
  • 615044 2022-004
    Material Weakness Repeat
  • 615045 2022-005
    Material Weakness
  • 615046 2022-004
    Material Weakness
  • 615047 2022-006
    Significant Deficiency
  • 615048 2022-004
    Material Weakness
  • 615049 2022-006
    Significant Deficiency
  • 615050 2022-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $7.47M
15.020 Aid to Tribal Governments $1.14M
15.021 Consolidated Tribal Government Program $790,393
14.867 Indian Housing Block Grants $499,755
15.030 Indian Law Enforcement $467,144
15.024 Indian Self-Determination Contract Support $462,399
15.033 Road Maintenance_indian Roads $387,747
21.023 Emergency Rental Assistance Program $337,437
93.441 Indian Self-Determination $315,391
15.113 Indian Social Services_welfare Assistance $207,751
21.019 Coronavirus Relief Fund $174,428
20.205 Highway Planning and Construction $149,134
93.054 National Family Caregiver Support, Title Vi, Part C, Grants to Indian Tribes and Native Hawaiians $105,250
15.035 Forestry on Indian Lands $101,076
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $91,933
15.144 Indian Child Welfare Act_title II Grants $89,451
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $78,559
93.568 Low-Income Home Energy Assistance $66,148
15.029 Tribal Courts $54,028
14.862 Indian Community Development Block Grant Program $37,037
30.001 Employment Discrimination_title Vii of the Civil Rights Act of 1964 $33,935
93.569 Community Services Block Grant $31,053
93.047 Special Programs for the Aging_title Vi, Part A, Grants to Indian Tribes_part B, Grants to Native Hawaiians $30,534
15.041 Environmental Management_indian Programs $25,023
93.556 Promoting Safe and Stable Families $23,763
93.201 Indian Health Services Scatter Sites and Sanitation $20,455
66.605 Performance Partnership Grants $19,150
93.575 Child Care and Development Block Grant $17,132
11.029 Tribal Broadband Connectivity Program $17,020
10.760 Water and Waste Disposal Systems for Rural Communities $14,966
93.045 Special Programs for the Aging_title Iii, Part C_nutrition Services $9,810
93.645 Stephanie Tubbs Jones Child Welfare Services Program $7,516
93.236 Grants to States to Support Oral Health Workforce Activities $6,111
93.053 Nutrition Services Incentive Program $2,679
10.U01 Usda Farm Snow Apprvd Tunnel 1 $1,980
16.540 Juvenile Justice and Delinquency Prevention_allocation to States $1,929
15.141 Indian Housing Assistance $1,604
10.U02 Elder's Church Garden $794
10.171 Organic Certification Cost Share Programs $68
93.237 Special Diabetes Program for Indians_diabetes Prevention and Treatment Projects $-1,004