FAC Explorer

Finding 486132 (2023-002)

Significant Deficiency
Requirement
L
Questioned Costs
-
Year
2023
Accepted
2024-09-09
Audit: 318771
Organization: Sault Ste. Marie Tribe of Chippewa Indians (MI)
Auditor: Dennis Gartland & Niergarth

AI Summary

  • Core Issue: The Tribe mistakenly categorized project vendors as subrecipients in their reports.
  • Impacted Requirements: Compliance with 2 CFR 200.328 and 31 CFR section 35.4(c) for accurate reporting of expenditures.
  • Recommended Follow-Up: Revise reports to classify payments correctly as project vendors, and address ongoing guidance changes from the Treasury.

Finding Text

Finding Number 2023-002 Assistance Listing #21.027 Coronavirus State and Local Fiscal Recovery Funds (SLFRF) Reporting Immaterial Noncompliance Criteria: In accordance with 2 CFR 200.328 and 31 CFR section 35.4(c) Reporting and requests for other information, grantees are required to file quarterly Project and Expenditure Reports listing significant projects, significant payments to subrecipients, subawards, and expenditure awards greater than $50,000. Condition: The Tribe incorrectly listed some project vendors as a subrecipients on the Project and Expenditure reports. Cause: Treasury guidance for reporting subrecipients versus contractors was in transition during the reporting periods for the year. Effect: The Tribe reported subrecipients on the Project and Expenditures Reports, but did not have any subrecipients of Coronavirus State and Local Fiscal Recovery Funds (SLFRF). Recommendation: Update reporting to ensure payments are reported as project vendors rather than subrecipients. Management's Response: Management recognizes that the error exists and has not been able to correct the report due to US Treasury’s portal not accepting prior period revisions. Treasury has changed its guidance on SLFRF multiple times over the past several years which has created an increased risk in filing errors for all reporting for these funds..

Corrective Action Plan

Criteria: In accordance with 2 CFR 200.328 and 31 CFR section 35.4(c) Reporting and requests for other information, grantees are required to file quarterly Project and Expenditure Reports listing significant projects, significant payments to subrecipients, subawards, and expenditure awards greater than $50,000. Condition: The Tribe incorrectly listed some project vendors as a subrecipients on the Project and Expenditure reports. Cause: Treasury guidance for reporting subrecipients versus contractors was in transition during the reporting periods for the year. Effect: The Tribe reported subrecipients on the Project and Expenditures Reports, but did not have any subrecipients of Coronavirus State and Local Fiscal Recovery Funds (SLFRF). Recommendation: Update reporting to ensure payments are reported as project vendors rather than subrecipients. Management's Response: Management recognizes that the error exists and has not been able to correct the report due to US Treasury’s portal not accepting prior period revisions. Treasury has changed its guidance on SLFRF multiple times over the past several years which has created an increased risk in filing errors for all reporting for these funds. Person Responsible: Robert Schulte, CFO Anticipated Completion Date: Ongoing evaluation

Categories

Subrecipient Monitoring Reporting

Other Findings in this Audit

  • 1062574 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $26.58M
15.042 Indian School Equalization Program $720,209
15.047 Indian Education Facilities, Operations, and Maintenance $467,529
93.788 Opioid Str $363,943
84.010 Title I Grants to Local Educational Agencies $317,326
15.046 Administrative Cost Grants for Indian Schools $274,859
93.210 Tribal Self-Governance Program: Ihs Compacts/funding Agreements $229,663
66.605 Performance Partnership Grants $229,252
16.710 Public Safety Partnership and Community Policing Grants $212,147
93.441 Indian Self-Determination $210,589
84.425 Education Stabilization Fund $189,775
15.062 Replacement and Repair of Indian Schools $189,612
93.237 Special Diabetes Program for Indians_diabetes Prevention and Treatment Projects $173,432
21.029 Coronavirus Capital Projects Fund Program $161,686
15.044 Indian Schools_student Transportation $132,351
16.575 Crime Victim Assistance $123,053
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $111,550
10.558 Child and Adult Care Food Program $108,331
93.762 A Comprehensive Approach to Good Health and Wellness in Indian County Ð Financed Solely by Prevention and Public Health $94,084
15.022 Tribal Self-Governance $85,643
16.587 Violence Against Women Discretionary Grants for Indian Tribal Governments $84,710
16.841 Voca Tribal Victim Services Set-Aside Program $82,096
93.594 Tribal Work Grants $81,205
16.608 Tribal Court Assistance Program $76,723
93.575 Child Care and Development Block Grant $75,592
66.038 Training, Investigations, and Special Purpose Activities of Federally-Recognized Indian Tribes Consistent with the Clean Air Act (caa), Tribal Sovereignty and the Protection and Management of Air Quality $68,079
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $66,878
93.558 Temporary Assistance for Needy Families $56,969
84.336 Teacher Quality Partnership Grants $51,669
93.047 Special Programs for the Aging_title Vi, Part A, Grants to Indian Tribes_part B, Grants to Native Hawaiians $48,639
11.307 Economic Adjustment Assistance $46,574
15.151 Education Program Enhancements $44,151
97.067 Homeland Security Grant Program $43,626
93.645 Stephanie Tubbs Jones Child Welfare Services Program $43,611
93.568 Low-Income Home Energy Assistance $40,888
20.509 Formula Grants for Rural Areas and Tribal Transit Program $37,702
84.424 Student Support and Academic Enrichment Program $27,763
93.069 Public Health Emergency Preparedness $27,625
10.567 Food Distribution Program on Indian Reservations $25,315
10.912 Environmental Quality Incentives Program $23,228
15.662 Great Lakes Restoration $22,994
45.308 Native American/native Hawaiian Museum Services Program $22,973
93.600 Head Start $21,702
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $21,017
93.587 Promote the Survival and Continuing Vitality of Native American Languages $20,631
93.053 Nutrition Services Incentive Program $20,524
17.265 Native American Employment and Training $19,899
93.556 Promoting Safe and Stable Families $17,390
14.231 Emergency Solutions Grant Program $17,205
16.750 Support for Adam Walsh Act Implementation Grant Program $17,139
16.583 Children's Justice Act Partnerships for Indian Communities $13,695
84.181 Special Education-Grants for Infants and Families $12,502
84.027 Special Education_grants to States $10,342
66.419 Water Pollution Control State, Interstate, and Tribal Program Support $5,382
45.311 Native American and Native Hawaiian Library Services $4,378
93.044 Special Programs for the Aging_title Iii, Part B_grants for Supportive Services and Senior Centers $3,393
93.569 Community Services Block Grant $3,268
11.804 Mbda Business Center - American Indian and Alaska Native $2,210
93.497 Family Violence Prevention and Services/ Sexual Assault/rape Crisis Services and Supports $2,054
93.581 Improving the Capability of Indian Tribal Governments to Regulate Environmental Quality $1