FAC Explorer

Finding 500328 (2023-004)

Significant Deficiency
Requirement
F
Questioned Costs
-
Year
2023
Accepted
2024-09-30
Audit: 323095
Organization: Lummi Indian Business Council (WA)
Auditor: Stauffer & Associates PLLC

AI Summary

  • Core Issue: Management conducted a physical inventory but lacked documentation for review and approval, raising concerns about accuracy.
  • Impacted Requirements: Internal controls for property records and physical inventory processes were not adequately followed, as per 2 CFR section 200.313.
  • Recommended Follow-Up: Ensure future physical inventories are documented, reconciled with property records every two years, and maintain records for review.

Finding Text

Program Information: Assistance Listing #: 15.022 U.S. Department of the Interior Tribal Self-Governance/Indian Reservation Roads Program Award Numbers: GT-OSGT107-10/A16AP00068 Award Periods: 1/1/2011 – 12/31/2023 Criteria: Internal control is a process, effected by an entity’s…[governing body], management and other personnel, designed to provide reasonable assurance regarding the achievement of objectives relating to operations, reporting, and compliance: (Internal Control – Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission, © May 2013, p.1). Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). A physical inventory of the property must be taken and the results reconciled with the property records at least once every 2 years (2 CFR section 200.313(d)(2)). A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)). Condition/Context: Management completed a physical inventory in 2022-2023, but was not able to provide support showing management review and approval. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: Turnover in key personnel, lack of internal controls, and the inability to provide supporting documentation. Effect: Without review and approval of the physical inventory listing, it is possible the reconciliation to property records may not occur. Questioned Costs: None. Repeat Finding: No. Recommendation: We recommend that physical inventory is taken, that the results are reconciled with the property records at least once every 2 years, and that documentation of this process is stored for review at a later date. View of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Corrective Action Plan

Person responsible for corrective action plan: Anthony Madera, CFO Lummi Indian Business Council 2665 Kwina Road Bellingham, WA 98226 (360) 384-7181 Condition: Management completed a physical inventory in 2022-2023, but was not able to provide support showing management review and approval. Solution: With the guidance and authority outlined in the Department’s internal policies and in accordance with 2 CFR, Part 200, Subpart D, Property Standards, The non-Federal entity must submit annually an inventory listing of federally-owned property in its custody to the Federal awarding agency as defined within existing governing statues, regulations, or terms and conditions of the award. Procedures for the delegated staff administering these regulatory activities will follow the minimum requirements of maintaining property records. Final review of inventory will have final reviewed by Department’s CFO of approval and will be documented annually. Corrective action plan will be in accordance with c CFR, Part 200, Subpart F, §200.511 Audit findings follow-up. The Department entered into a professional agreement with Financial Service Advisors, LLC to assess current policies to update standards of management by identifying credentials and experience of senior finance staff who will oversee these activities. Revisions to the policies will provide the Department’s government an extensive manual that will be developed into a fiscal management training. Training will include but not be limited to reviewing procurement methods, fiscal review of ledger activity, and audit responsibility on a quarterly basis and reporting to tribal council. Responsible: Anthony Madera, Chief Financial Officer, Lummi Indian Business Council Anticipated completion date: 06/30/2025

Categories

Equipment & Real Property Management Material Weakness Reporting Significant Deficiency

Other Findings in this Audit

  • 500324 2023-002
    Material Weakness
  • 500325 2023-002
    Material Weakness
  • 500326 2023-003
    Significant Deficiency
  • 500327 2023-003
    Significant Deficiency
  • 500329 2023-004
    Significant Deficiency
  • 1076766 2023-002
    Material Weakness
  • 1076767 2023-002
    Material Weakness
  • 1076768 2023-003
    Significant Deficiency
  • 1076769 2023-003
    Significant Deficiency
  • 1076770 2023-004
    Significant Deficiency
  • 1076771 2023-004
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.210 Tribal Self-Governance Demonstration Program: Planning and Negotiation Ihs Compacts $18.03M
15.022 Tribal Self-Governance $13.33M
21.027 Covid-19 - Arpa - Slfrf $10.92M
93.600 Head Start Yr 1 $3.90M
15.042 Indian School Equalization Program $2.19M
93.243 Lummi Nation Project Aware Application $1.75M
21.026 Covid-19 - Haf $1.74M
93.210 Covid-19 - Testing Ihs and Tribal Operated Programs $1.30M
84.027 Idea - Special Educ. $1.28M
93.829 Dhhs Samhsa - Expansion Ln Behavioral Health Svc $1.21M
15.022 Indian Reservation Roads Program $1.06M
11.463 South Fork Nooksack River Restoration $937,665
84.425 Covid-19 - Education Stabilization Fund-Arpa $934,464
10.912 Salmon Recovery $747,256
93.563 Child Support Enforcement $715,400
10.567 Fy20 Net $714,795
15.046 Administrative Costs $698,160
93.382 Dhhs - Ln Chap Project $635,242
93.772 Lummi Nation Public Health Accreditation Project $594,941
84.010 Title I $495,588
11.438 Recreation and Conservation (rco) South Fork Upper and Lower Fobes Ph2 Restoration $462,625
93.575 Covid-19 - Child Care and Development Block Grant $348,225
16.841 Doj Ovc Tribal Set-Aside Program $333,066
21.023 Covid-19 - Arpa - Era $297,764
93.933 Demonstration Projects for Indian Health $283,339
16.575 Health and Wellness Center Solar Pv Project $282,671
81.041 Low Income Solar Deployment $282,025
66.039 Diesel Emissions Reduction Act $271,883
93.237 Special Diabetes Program for Indians-Diabetes Prevention and Treatment Programs $268,379
16.608 Lummi Nation Drug Court Program $263,294
16.587 2021 Ovw Fiscal Year 2021 Grants to Indian Tribal Governments Program Solicitation $259,947
84.181 Early Learning Part C (3 to Prek) $257,066
66.121 Lummi Nation Puget Sound Tribal Capacity Building $254,075
97.036 Fema Shellfish Project D17-153 $200,000
93.575 Child Care and Development Fund $199,155
10.567 Fy13 Net $194,113
11.029 Tribal Broadband Connectivity Program $193,251
10.567 2020 Fdpir $185,811
16.575 Fy22 Ocla $166,620
11.438 Lummi Nation's Pacific Coast Salmon Recovery Grant Program 494.2020 $164,707
93.581 Dhhs Admin for Children & Families Improving Capability of Indian Tribal Govt to Regulate Envir. Quality $161,922
16.575 Tribal Government Initiative Year 2 $154,994
11.454 Covid-19 - Psmfc - Cares Act Funding for States $154,763
84.287 Early Learning Part B (birth to 3) $151,652
16.575 Voca by & for Victim Services $148,146
66.121 Health and Wellness Center Solar Pv Project $145,546
66.121 Fy-20 Epa Puget Sound Partnership Implementation $142,939
93.243 Lummi Nation Strategic Prevention Framework (spf) Project Grant $132,557
93.612 Lummi Nation Young People Re-Engagement Program (yrep) $127,171
16.024 Tribal Sexual Assault Services Program $120,447
16.585 Lummi Nation's Family Drug Court Grant Program $118,272
17.277 Wioa - Dislocated Workers $116,161
20.U03 Implement Gps Tracking of Lummi Transit Vehicles and New Bus Shelters $113,172
16.587 Violence Against Women (discretionary Grants for Tribal Governments) $112,856
16.838 Comprehensive Opioid, and Substance Abuse Program $112,404
81.041 Dept. of Energy-Low Income Community Solar Deployment $110,169
11.438 Fy19 Pcsrf $106,928
93.054 Native American Caregiver Support Program $105,991
16.320 Lummi Nation Services for Victims of Human Trafficking $102,987
16.841 Transforming Lummi Nation's Response to Elder Abuse $94,692
11.438 Fy19 Hatchery Genetic Management Plan $93,243
93.778 Hca Funding $91,945
11.307 Lummi Vendor Marketplace $90,570
15.663 National Fish and Wildlife $90,524
93.600 Head Start $88,652
97.036 Fema Lummi Nation Pump Repair $85,771
93.072 Fy21 Kinship Navigator $84,954
84.425 Covid-19 - Cares Act -Doe/geer I $79,811
93.071 Nutrition Services Incentive Program $79,076
93.958 State - Youth Mentoring Program $77,928
15.631 Srfb $76,987
15.044 Transportation $71,490
10.594 Fy22 Fdpir Nutrition Education $63,031
93.072 Fy19 Kinship Navigator $61,360
16.841 Lummi Nation Ctas PA 7- Lvoc Grant Program $58,532
84.250 Vocational Rehabilitation $56,382
93.959 Supported Housing and Employment $55,782
84.060 Indian Education - Grants to Local Educational Agencies $53,608
84.336 Title IV-B $52,238
11.438 Nwifc - Evaluation of Temporal & Spatial Distribution of Returning S. Fork Chinook Adults $49,895
84.424 Education Stabilization Fund-Arpa Geer III $47,838
11.302 Conduct and Implement Economic Development Strategies $47,823
10.557 Special Supplemental Nutrition Program for Women, Infants and Children (wic) $45,486
11.438 Recreation and Conservation (rco) Sf Nooksack Skookum Edfro Ph 3 Design $42,125
11.477 Fishery Disaster Funding $41,390
15.148 Energy Department Capacity Project $40,866
15.639 South Fork Cavanaugh Island Restoration $40,000
15.069 Zoonoic Disease Initiative $38,579
66.605 Performance Partnership Grant $38,091
20.205 St Wa Wsdot Lummi Transit Infrastructure for Bus Shelters $37,973
10.567 Op Council, Emergency Rental Assistance $36,453
10.594 Fy21 Fdpir Nutrition Education $31,874
11.U01 Interagency Agreement $31,668
93.047 Title Vi, Part A & B $29,563
15.531 Wria 1 Lead Entity $29,000
93.568 Dhhs Admin for Children & Families Low Income Home Energy Asst. Prgrm $28,257
10.567 Fy18 Net $24,728
10.567 Covid-19 - Fdpir: Cares Act: Facility Improvements & Equipment Upgrades $24,662
97.036 Fema - Disaster Declaration $23,167
66.121 Epa Puget Sound Partnership Implementation $21,818
15.631 Psar-Lead Entity Contracts $21,122
20.U02 Fy17-19 Public Transportation on Indian Reservations Formula Apportionments $20,424
93.596 Child Care and Development Fund $19,724
20.509 Covid-19 - Cares Act 5311 Ttp Formula Grant $17,307
11.473 National Fish and Wildlife Creating Resilience Plan for Lummi Reservation $16,872
97.036 Fema-Building Resilient Infrastructure/communities $15,299
11.438 Fy20 Pcsrf $14,254
16.710 Tribal Resources Grant Program- Equipment $14,246
15.904 Historic Preservation Fund Grants-in-Aid $14,029
93.959 Indian Child Welfare Services $13,225
10.912 Wetland Restoration Agreement $13,190
11.438 Nwifc-Hatchery Reform Contract $12,711
93.671 Covid-19 - Arp Fvpvs $12,124
20.205 Highway Planning and Construction $11,641
15.032 Indian Economic Development $10,810
93.788 Dhhs Samhsa - Ln Opioid Grant Prevention Treatment & Aftercare $10,615
93.054 Covid-19 - Tcc6 American Resuce Plan (arp) for Oaa Title Vi Part C $9,927
11.429 Lummi Nation Pacific Northwest Bwet $9,085
93.590 Tribal Fatherhood Support Programs $9,060
84.299 Lummi Marine Trades Nycp $8,942
15.130 Jom $8,225
93.569 Community Services Block Grant $7,052
93.047 Covid-19 - Arp for Oaa Title Vi Part A/b $6,906
10.565 Fy22 Csfp $6,770
93.671 Family Violence Prevention & Services $5,764
93.791 Money Follows the Person Tribal Initiative $5,013
10.565 Wa State Department of Agriculture Food Assistance $4,872
93.069 Public Health Emergency Preparedness $4,507
93.053 Nutrition Services Incentive Program $4,417
15.148 Tribal Energy Development Capacity Grants $4,000
11.438 Nooksack River Early Chinook $3,901
20.U01 Covid-19 - Y21 Arp Tribal Transit Program $3,643
93.575 Construction and Renovation of Childcare Facilities $2,949
11.438 Mf Porter Creek Reach Ph2 Restoration $2,836
15.151 Enhancement Funds $2,797
16.710 Ctas Purpose Area #1: Cops Office Tribal Resources Grant Program $2,476
11.438 Engineering Services for Lummi Bay Hatchery Raceways $1,892
15.149 Focus $1,670
10.565 Fy21 Csfp $1,533
93.047 Nutrition Services Incentive Program $1,346
10.567 Fy19 Net $1,192
84.358 Idea - Small, Rural School Achievement Program $1,083
93.594 Native Employment Works Program $1,030
93.788 Lummi Nation's Tribal Opioid Response Program Application $1,014
93.243 Dhhs Samhsa Native Connections Project $861
16.025 Special Domestic Violence Criminal Jurisdiction Program $384
11.438 Wria 1 Salmon Recovery Board Lead Entity $380
93.243 Lummi Nation Medication Assisted Treatment Expansion Project $364
11.454 Covid-19 - Psmfc - Cares Act Funding $250
16.585 Fy16 Family Drug Court Implementation & Enhancement Program $104
84.181 Idea - Special Educ. $19
15.U01 Forestry on Indian Lands $-2
93.421 Nihb Climate Ready Tribes $-123
21.019 Covid-19 - Federal Coronavirus Relief Funds (crf) for Tribal Governments $-2,426
11.438 Fy12 Pcsrf $-3,118
10.567 Covid-19 - Fy21 Fdpir-Cares Act Supplemental Admin Grant $-3,600
11.307 Covid-19 - Cares Eda Economic Adjustment Assistance $-5,463
11.438 Fy15 Pcsrf $-5,775
93.587 Lummi Nation Language Instruction $-6,420
93.047 Covid-19 - Families First Coronavirus Response Act $-11,387
16.588 Fy20 Stop $-11,806
11.438 Fy16 Pcsrf $-12,885
11.438 Lummi Nation's South Fork Nooksack Chinook Rescue Program $-28,501
93.047 Covid-19 - (nac3) Cares Act for Nutrition Services for Native American Programs Under Title Vi of the Oaa $-28,721
93.391 Covid-19 - Supporting Tribal Public Health Capacity in Coronavirus Preparedness and Response $-36,269
93.568 Low-Income Home Energy Assistance $-160,244