Finding 43988 (2022-002)

- Repeat Finding
Requirement
L
Questioned Costs
-
Year
2022
Accepted
2023-09-30
Audit: 45054
Organization: Wiyot Tribe (CA)
Auditor: Blue Arrow INC

AI Summary

  • Core Issue: The Tribe failed to submit required reports on time for key grant programs, indicating significant deficiencies in internal controls over compliance.
  • Impacted Requirements: Timely submission of SF-425 reports and semi-annual progress reports as mandated by grant agreements.
  • Recommended Follow-Up: Enhance monitoring processes to ensure timely report submissions and maintain proper documentation for compliance.

Finding Text

Finding 2022-002 ? Reporting (Significant Deficiencies in Internal Controls over Compliance) Criteria Information on the Major Programs Affected Major Program #15.021 Consolidated Tribal Government Program Award Number Period Report Type Due Date Submission Date A20AV00488 04/01/2022 - 06/30/2022 SF-425 07/15/2022 07/25/2022 A20AV00488 10/01/2022 - 12/31/2022 SF-425 01/15/2023 01/20/2023 Major Program #16.587 Violence Against Women Discretionary Grants for Indian Tribal Governments Award Number Period Report Type Due Date Submission Date 2017-TW-AX-0032 01/01/2022 - 03/31/2022 SF-425 04/30/2022 05/13/2022 2017-TW-AX-0032 10/01/2022 - 12/31/2022 SF-425 01/30/2023 02/01/2023 2017-TW-AX-0032 01/01/2022 - 06/30/2022 Semi annual progress report 07/30/2022 08/29/2022 Criteria As per the Consolidated Tribal Government Program, and Violence Against Women Discretionary Grants for Indian Tribal Governments compliance and reporting guidance, the Tribe must file SF-425 and a semi annual progress report by the due dates, as mentioned in the above tables. Condition/Context We noted that for fiscal year 2022, the Tribe did not submit the SF-425 report on time for ALN #15.021 Consolidated Tribal Government Program, and ALN #16.587 Violence Against Women Discretionary Grants for Indian Tribal Governments, and the semi annual progress report for ALN #16.587 Violence Against Women Discretionary Grants for Indian Tribal Governments. Cause The Tribe did not have adequate monitoring over the completion and submission of the required reports. Effect The Tribe is not in compliance with the reporting requirements, per the grant contract. Recommendation We recommend the Tribe continue to review its internal control processes, to ensure that controls are properly implemented for the reporting requirement and that adequate documentation is maintained.

Corrective Action Plan

2022-001 ? Financial Close and Reporting (Material Weakness in Internal Control Over Financial Reporting) - Repeated (Prior Year Finding 2021-001) Management Response: The Tribe has continued to develop the fiscal department by hiring three employees (two full-time and one part-time for the fiscal department. The new employees completed accounting courses conducted by professional entities in the field of governmental and tribal fund accounting such as the GFOA, NAFOA, Moss Adams, and Oklahoma State University. The Tribe has continued to retain the services of a CPA consultant to train and assist them as needed. The Tribe has budgeted for an increase in indirect funding in discussion with the BIA's indirect cost services and implemented a process for budgeting. The Tribe has implemented an online grant management system (CGMS) to document and monitor all the approved grants more accurately. The Tribe conducted a quarterly review for the stale checks in compliance with the Tribe fiscal policy to void outstanding checks over 90 days regularly. The fiscal department created a new GL account as "Unclaimed Property" to record the voided outstanding checks. The fiscal department created new procedures and updated the existing ones such as the Accounts Payable and Cash Handling procedures. The fiscal department created new forms for check requests, drawdowns, invoice requests, and transfer requests which created more control and supervision over the expenditures and grant management by adding and requesting more information such as award number, effective date, indirect calculation, budgets, balance for grants, etc. Another activity conducted by the fiscal department to ensure the accuracy of transactions is to reconcile accounts on a monthly basis. The fiscal department created a monthly binder for the Wiyot Tribe's monthly Council Meeting that consists of 16 different sections including but not limited to financial statements, Bank Reconciliations for all accounts, Journal Vouchers, AP reports, AR reports, drawdowns, and invoice requests. This cumulative monthly report is accompanied by a Month-end Closing form in which all the fiscal activities are listed according to the performer, date of performance, and status of the activities. This form is signed by the Fiscal staff, fiscal manager, and Tribal administrator and presented to the Council members and the Tribal Treasurer for review and approval. This form helps to indicate the accuracy of the attached fiscal reports and assure the Council that the required activities were performed by the fiscal department. The month-end closing report will assist the fiscal department in performing account reconciliation in a timely manner throughout the year rather than the year-end closeout. Another activity conducted by the fiscal department to address this finding was reviving the accounts receivable of the Tribe. The new form for invoice requests was created and applied for all departments to use. This form helps to accumulate all the payments for different services conducted by the Tribal departments for outside customers, which increases internal control and diminishes the risk of fraud. The drawdown process is also moved to the AR rather than journal vouchers which helps the Departments to trace their awards' financial activities with more accuracy and enables the fiscal to perform its financial activities regarding grant management including indirect cost calculation and expenditure/revenue recording precisely and correctly. To fix the issue with the 941 reports, the Tribe will provide a procedure regarding the production and submission of 941 reports for each quarter that specifies assigned duties for each involved employee. These reports will be included in the month-end closing form submitted to the Council and the Treasurer in each quarter which will help to oversee the procedure and ensure its completion for each quarter. Anticipated Completion Date: 12/31/2023 Responsible Party: Michelle Vassel, Tribal Administrator Farzad Forouhar, Fiscal Manager

Categories

Reporting Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
15.021 Consolidated Tribal Government Program $521,711
66.605 Performance Partnership Grants $259,408
16.587 Violence Against Women Discretionary Grants for Indian Tribal Governments $243,072
15.024 Indian Self-Determination Contract Support $177,466
93.047 Special Programs for the Aging_title Vi, Part A, Grants to Indian Tribes_part B, Grants to Native Hawaiians $134,902
11.438 Pacific Coast Salmon Recovery_pacific Salmon Treaty Program $120,564
93.587 Promote the Survival and Continuing Vitality of Native American Languages $106,227
93.575 Child Care and Development Block Grant $81,052
15.904 Historic Preservation Fund Grants-in-Aid $79,219
15.141 Indian Housing Assistance $76,013
14.867 Indian Housing Block Grants $68,700
16.581 Tribal Victim Services Program $65,872
21.027 Coronavirus State and Local Fiscal Recovery Funds $56,588
93.002 Ihs - Moa (pt) $45,951
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $42,934
93.054 National Family Caregiver Support, Title Vi, Part C, Grants to Indian Tribes and Native Hawaiians $31,293
21.023 Emergency Rental Assistance Program $30,379
93.101 Ihs - Moa $26,221
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $20,192
93.524 Building Capacity of the Public Health System to Improve Population Health Through National, Non-Profit Organizations- Financed in Part by Prevention and Public Health Funds (pphf) $17,762
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $12,842
15.003 Bia Attorney Fees $11,899
93.569 Community Services Block Grant $5,509
15.051 Endangered Species on Indian Lands $5,363
15.032 Indian Economic Development $4,742
15.922 Native American Graves Protection and Repatriation Act $4,189
93.053 Nutrition Services Incentive Program $3,278
84.299 Indian Education -- Special Programs for Indian Children $2,810
45.308 Native American/native Hawaiian Museum Services Program $1,532
15.144 Indian Child Welfare Act_title II Grants $1,199
15.033 Road Maintenance_indian Roads $838