FAC Explorer

Finding 555708 (2022-006)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2025-04-23
Audit: 354339
Organization: Cheyenne and Arapaho Tribes (OK)
Auditor: Forvis Mazars LLP

AI Summary

  • Core Issue: The Tribe failed to verify vendor eligibility against suspension and debarment lists, risking the use of ineligible vendors.
  • Impacted Requirements: Non-compliance with 2 CFR Part 200 regarding procurement and equitable vendor distribution, leading to potential overpayments.
  • Recommended Follow-Up: Ensure all staff understand procurement policies and maintain proper documentation for all purchasing decisions.

Finding Text

Finding: Procurement, Suspension and Debarment (Significant Deficiency; Other Matter) Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Number – B-18-SR-40-0584 & B-19-SR-40-0584; Award Year 2018 & 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Number – 8L-SS-2021-0901-001; Award Year 2021 Suspension and Debarment Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart C, 200.214 - Recipients and subrecipients are subject to the procurement, debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR Part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Procurement Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart D, 200.321 - When possible, the recipient or subrecipient should ensure there is open competition for non-micro purchases and an equitable distribution among suppliers for micro purchases. Condition: The Tribe was unable to provide supporting documentation showing that a verification had been performed to ensure vendors were not suspended or debarred. Several large purchases were sole sourced without adequate documentation. A high volume of micro purchases were made from the same vendor rather than being distributed equitably amount a variety of vendors. Questioned Costs: None. Context: 14.862 - Three procurements were tested noting two in which suspension and debarment checks were not performed. A high volume of micro purchases ($148,908) were made from the same vendor rather than an equitable distribution of vendors. 21.027 - 14 procurements were tested. Ten procurements tested were subject to suspension and debarment of which checks were not performed on nine. All 14 procurements tested were subject to non-micro purchase requirements. Six procurements were sole sourced without adequate supporting documentation to support this method of purchase. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe's inability to furnish supporting documentation showing that a check to ensure vendors were not suspended or debarred on SAM.gov could result in the use of ineligible vendors. The Tribe's failure to provide for open competition or provide for an equitable distribution of vendors on purchases could result in the Tribe paying more for services than is reasonable or necessary. Cause: Tribal policies were not followed surrounding the requirement of suspension and debarment checks and documentation of sole source procurements. Due to the Tribal location, there may be some limitation of available vendors for consideration to ensure an equitable distribution. Identification as a Repeat Finding: 2021-005 (same issue in different program) Recommendation: We recommend the Department ensure existing procurement, suspension and debarment policies are understood throughout the Tribe and supporting documentation is adequate and maintained for all procurement decisions. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.

Corrective Action Plan

Corrective Action: The Department of Treasury will work closely with the Procurement, Grants, and Contracts program to monitor and enforce proper internal controls and reviews for vendors. Procurement and Accounts Payable teams have been notified of the required SAM.gov checks, and these documents will now be uploaded into Sage when a vendor is added or updated. Person(s) Responsible: Acting Treasurer, Controller, AP Manager and PG&C Director Estimated Completion Date: January 1, 2025

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 555696 2022-004
    Material Weakness
  • 555697 2022-004
    Material Weakness
  • 555698 2022-005
    Significant Deficiency
  • 555699 2022-005
    Significant Deficiency
  • 555700 2022-005
    Significant Deficiency
  • 555701 2022-005
    Significant Deficiency
  • 555702 2022-005
    Significant Deficiency
  • 555703 2022-005
    Significant Deficiency
  • 555704 2022-005
    Significant Deficiency
  • 555705 2022-005
    Significant Deficiency
  • 555706 2022-005
    Significant Deficiency
  • 555707 2022-005
    Significant Deficiency
  • 555709 2022-006
    Significant Deficiency Repeat
  • 555710 2022-006
    Significant Deficiency Repeat
  • 555711 2022-007
    -
  • 555712 2022-007
    -
  • 555713 2022-008
    -
  • 555714 2022-008
    -
  • 1132138 2022-004
    Material Weakness
  • 1132139 2022-004
    Material Weakness
  • 1132140 2022-005
    Significant Deficiency
  • 1132141 2022-005
    Significant Deficiency
  • 1132142 2022-005
    Significant Deficiency
  • 1132143 2022-005
    Significant Deficiency
  • 1132144 2022-005
    Significant Deficiency
  • 1132145 2022-005
    Significant Deficiency
  • 1132146 2022-005
    Significant Deficiency
  • 1132147 2022-005
    Significant Deficiency
  • 1132148 2022-005
    Significant Deficiency
  • 1132149 2022-005
    Significant Deficiency
  • 1132150 2022-006
    Significant Deficiency Repeat
  • 1132151 2022-006
    Significant Deficiency Repeat
  • 1132152 2022-006
    Significant Deficiency Repeat
  • 1132153 2022-007
    -
  • 1132154 2022-007
    -
  • 1132155 2022-008
    -
  • 1132156 2022-008
    -

Programs in Audit

ALN Program Name Expenditures
21.027 Coronavirus State and Local Fiscal Recovery Funds $12.24M
93.575 Child Care and Development Block Grant $1.65M
20.205 Highway Planning and Construction $1.14M
15.114 Indian Education Higher Education Grant $1.03M
15.025 Services to Indian Children, Elderly and Families $938,881
84.299 Indian Education - Special Programs for Indian Children $839,504
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $751,720
93.237 Special Diabetes Program for Indians Diabetes Prevention and Treatment Projects $712,405
15.U01 477 Cluster (plan Year 1/1/2020-12/31/2023 $677,024
21.019 Coronavirus Relief Fund $650,424
93.441 Indian Self-Determination $553,439
84.250 American Indian Vocational Rehabilitation Services $538,085
15.130 Indian Education Assistance to Schools $532,440
10.567 Food Distribution Program on Indian Reservations $492,736
93.788 Opioid Str $476,392
14.862 Indian Community Development Block Grant Program $420,952
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $372,080
15.020 Aid to Tribal Governments $310,735
16.587 Violence Against Women Discretionary Grants for Indian Tribal Governments $305,643
93.568 Low-Income Home Energy Assistance $300,039
15.029 Tribal Courts $288,925
16.582 Crime Victim Assistance/discretionary Grants $268,008
15.144 Indian Child Welfare Act Title II Grants $265,523
11.307 Economic Adjustment Assistance $235,042
15.035 Forestry on Indian Lands $228,559
15.228 Blm Fuels Management and Community Fire Assistance Program Activities $224,609
20.509 Formula Grants for Rural Areas and Tribal Transit Program $158,689
16.750 Support for Adam Walsh Act Implementation Grant Program $132,254
93.047 Special Programs for the Aging, Title Vi, Part A, Grants to Indian Tribes, Part B, Grants to Native Hawaiians $116,809
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $115,526
16.608 Tribal Justice Systems $111,102
15.904 Historic Preservation Fund Grants-in-Aid $104,704
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $104,585
93.495 Community Health Workers for Public Health Response and Resilient $93,016
66.926 Indian Environmental General Assistance Program (gap) $88,002
93.612 Native American Programs $83,369
10.594 Food Distribution Program on Indian Reservations Nutrition Education Grants $78,216
93.600 Head Start $72,018
16.024 Tribal Sexual Assault Services Program $67,387
16.841 Voca Tribal Victim Services Set-Aside Program $61,973
66.419 Water Pollution Control State, Interstate, and Tribal Program Support $57,215
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 $54,316
93.556 Marylee Allen Promoting Safe and Stable Families Program $50,533
93.499 Low Income Household Water Assistance Program $41,768
93.645 Stephanie Tubbs Jones Child Welfare Services Program $39,502
93.569 Community Services Block Grant $34,068
15.922 Native American Graves Protection and Repatriation Act $26,450
93.671 Family Violence Prevention and Services/domestic Violence Shelter and Supportive Services $9,079
15.156 Tribal Climate Resilience $6,663
93.054 National Family Caregiver Support, Title Vi, Part C, Grants to Indian Tribes and Native Hawaiians $6,560
66.818 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements $2,182
15.954 National Park Service Conservation, Protection, Outreach, and Education $1,599
84.415 Indian Education National Activities (state Tribal Education Partnership (step) and Native American Language (nal) $1,214
84.060 Indian Education Grants to Local Educational Agencies $433