FAC Explorer

Finding 575273 (2023-004)

Material Weakness Repeat Finding
Requirement
E
Questioned Costs
-
Year
2023
Accepted
2025-08-29
Audit: 365312
Organization: Standing Rock Sioux Tribe (ND)
Auditor: Baker Tilly US LLP

AI Summary

  • Core Issue: Inadequate internal controls over eligibility documentation for the CCDF and LIHEAP programs led to non-compliance with federal requirements.
  • Impacted Requirements: Missing CPR certifications for providers and insufficient documentation for LIHEAP participants, including income verification and household size.
  • Recommended Follow-Up: Reassess eligibility processes, implement a supervisory review system, and ensure all staff are trained and compliant with documentation standards.

Finding Text

AL Numbers: 93.575, 93.568 Name of Federal Program or Cluster: Child Care and Development Block Grant – CCDF Cluster and COVID-19 CCDF Cluster, Low-Income Home Energy Assistance Program (LIHEAP) and COVID-19 LIHEAP Award Number: 21PANDCCDF, 22PANDCCDD, 23PANDCCDD, 23PANDLIEA, 23PANDLIEE, 23 PANDLIEI Award Year: 2021, 2022, 2023 Criteria – In accordance with the Tribe’s grant award requirements and the Uniform Guidance 2 CFR 200.303, the Tribe must have internal controls in place for documenting and verifying eligibility to ensure compliance with federal requirements. Condition and context – We noted the following for each program: ALN 93.575 – Of the 158 provider payments made by the CCDF Cluster program during fiscal year 2023, we used a random sample selection methodology to select and test 32 files for eligibility. We noted 4 provider files did not contain proof of CPR certification, which is a required certification for all providers. Additionally, the Tribe’s CCDF program distributed American Rescue Plan Act (ARPA) Stabilization assistance payments to eligible providers. Of the 168 provider payments made using ARPA funds during fiscal year 2023, we used a random sample selection methodology to select and test 10 files for eligibility. We noted 2 provider files that were not in compliance with grant requirements. One file contained a background check that did not meet the grant’s criteria, and one file lacked sufficient evidence that childcare services were provided. ALN 93.568 – Of the 1004 LIHEAP participants during fiscal year 2023, we used a random sample selection methodology to select and test 60 files. We noted there was no documentation provided for 1 file. For 58 of the 59 files reviewed, we noted the same individual that made the eligibility determination also reviewed the file for accuracy without evidence of review by another individual. Of the 59 provider files reviewed, 17 were not in compliance with the eligibility requirements of the program, this included 8 files with incomplete documentation on income verification and 9 files with incomplete documentation on verification of household size. Cause – Inadequate internal controls over eligibility requirements may have led to this finding. Questioned costs – For the CCDF Cluster program, the known questioned costs identified were $4,985. For the LIHEAP Program, we were unable to determine questioned costs due to lack of sufficient information. Effect – It is possible that individuals not eligible to receive services may have received services. Repeat finding – This is a repeat finding and was reported in the prior year as findings 2022-002 and 2022-003. Recommendation – These programs should reexamine processes and controls over participant eligibility and implement a supervisory review process to establish strong internal controls over compliance. Views of responsible officials and planned corrective actions – ALN 93.575 (CPR Certifications): Starting in October 2024 the Program has hired a company to provide CPR training to the staff. This training occurred throughout fiscal year 2024. ALN 93.575 (Provider files): In July 2025, the Program hired a Compliance Specialist to review provider files for compliance. In addition, the Program hired an employee to assist with the demanding workload. ALN 93.568 (participant files): the identified items of non-compliance were a direct result of program personnel turnover, including the Director. The Director position was vacant for the entire fiscal year. The Program is now fully staffed and working on ensuring that all intake items are clearly documented/retained in the participant files.

Corrective Action Plan

Corrective Action Plan: ALN 93.575 and 93.596 (CPR Certifications): Starting in October 2024 the Program has hired a company to provide CPR training to the staff. This training occurred throughout fiscal year 2024. ALN 93.575 and 93.596 (Provider files): In July 2025, the Program hired a Compliance Specialist to review provider files for compliance. In addition, the Program hired an employee to assist with the demanding workload. ALN 93.568 (participant files): the identified items of non-compliance was a direct result of program personnel turnover, including the Director. The Director position was vacant for the entire fiscal year. The Program is now fully staffed and working on ensuring that all intake items are clearly documented/retained in the participant files. Person(s) Responsible: Jackie Brownotter, Child Care Assistance Program Director, Deanne Bear Catches, LIHEAP Director Estimated Completion Date: ALN 93.575 and 93.596 (CPR Certifications): October 2024, ALN 93.575 and93.596 (Provider files): Effective immediately ALN 93.568 (participant files): effectively immediately

Categories

Eligibility Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 575270 2023-006
    Material Weakness
  • 575271 2023-009
    Material Weakness
  • 575272 2023-008
    Material Weakness Repeat
  • 575274 2023-006
    Material Weakness Repeat
  • 575275 2023-010
    Material Weakness Repeat
  • 575276 2023-005
    Significant Deficiency
  • 575277 2023-010
    Material Weakness
  • 575278 2023-005
    Significant Deficiency
  • 575279 2023-010
    Material Weakness
  • 575280 2023-008
    Material Weakness Repeat
  • 575281 2023-003
    Material Weakness Repeat
  • 575282 2023-004
    Material Weakness Repeat
  • 575283 2023-007
    Material Weakness Repeat
  • 575284 2023-009
    Material Weakness Repeat
  • 575285 2023-003
    Material Weakness Repeat
  • 575286 2023-004
    Material Weakness Repeat
  • 575287 2023-007
    Material Weakness Repeat
  • 575288 2023-009
    Material Weakness Repeat
  • 1151712 2023-006
    Material Weakness
  • 1151713 2023-009
    Material Weakness
  • 1151714 2023-008
    Material Weakness Repeat
  • 1151715 2023-004
    Material Weakness Repeat
  • 1151716 2023-006
    Material Weakness Repeat
  • 1151717 2023-010
    Material Weakness Repeat
  • 1151718 2023-005
    Significant Deficiency
  • 1151719 2023-010
    Material Weakness
  • 1151720 2023-005
    Significant Deficiency
  • 1151721 2023-010
    Material Weakness
  • 1151722 2023-008
    Material Weakness Repeat
  • 1151723 2023-003
    Material Weakness Repeat
  • 1151724 2023-004
    Material Weakness Repeat
  • 1151725 2023-007
    Material Weakness Repeat
  • 1151726 2023-009
    Material Weakness Repeat
  • 1151727 2023-003
    Material Weakness Repeat
  • 1151728 2023-004
    Material Weakness Repeat
  • 1151729 2023-007
    Material Weakness Repeat
  • 1151730 2023-009
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.518 Garrison Diversion Unit $8.60M
15.021 Consolidated Tribal Government $6.76M
93.445 Indian Health Service Sanitation Facilities Construction Program $5.98M
93.600 Head Start $3.99M
21.027 Coronavirus State and Local Fiscal Recovery Funds - Covid-19 $3.80M
93.575 Child Care and Development Block Grant - Covid-19 $3.01M
93.441 Indian Self-Determination $3.00M
10.760 Water and Waste Disposal Systems for Rural Communities $2.54M
93.568 Low-Income Home Energy Assistance $2.36M
10.557 Wic Special Supplemental Nutrition Program for Women, Infants, and Children - Covid-19 $2.33M
21.019 Coronavirus Relief Fund - Covid-19 $1.83M
93.563 Child Support Services $1.26M
15.033 Road Maintenance Indian Roads $912,313
15.108 Indian Employment Assistance $681,076
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $562,453
10.567 Food Distribution Program on Indian Reservations $478,505
93.237 Special Diabetes Program for Indians Diabetes Prevention and Treatment Projects $392,808
20.205 Highway Planning and Construction $344,685
84.181 Special Education-Grants for Infants and Families $315,338
93.047 Special Programs for the Aging, Title Vi, Part A, Grants to Indian Tribes, Part B, Grants to Native Hawaiians $259,131
84.027 Special Education Grants to States $258,737
15.151 Education Enhancements $257,143
15.040 Real Estate Programs Indian Lands $255,997
15.065 Safety of Dams on Indian Lands $232,414
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $226,022
15.037 Water Resources on Indian Lands $225,442
66.419 Water Pollution Control State, Interstate, and Tribal Program Support $216,377
15.141 Indian Housing Assistance $214,422
93.600 Head Start - Covid-19 $194,547
66.608 Environmental Information Exchange Network Grant Program and Related Assistance $190,578
66.605 Performance Partnership Grants $145,273
84.250 American Indian Vocational Rehabilitation Services $135,989
66.817 State and Tribal Response Program Grants $134,852
15.021 Consolidated Tribal Government - Covid-19 $132,084
16.750 Support for Adam Walsh Act Implementation Grant Program $130,446
93.959 Block Grants for Prevention and Treatment of Substance Abuse $120,682
16.585 Treatment Court Discretionary Grant Program $119,646
93.586 State Court Improvement Program $115,779
15.904 Historic Preservation Fund Grants-in-Aid $97,347
15.051 Endangered Species on Indian Lands $90,830
93.556 Marylee Allen Promoting Safe and Stable Families Program $81,327
16.587 Violence Against Women Discretionary Grants for Indian Tribal Governments $77,693
15.020 Aid to Tribal Governments $76,952
15.U01 Public Law 102-477 Program $73,979
93.053 Nutrition Services Incentive Program $69,137
89.001 National Archives Reference Services Historical Research $65,302
16.841 Voca Tribal Victim Services Set-Aside Program $59,837
11.307 Economic Adjustment Assistance - Covid-19 $56,250
66.296 Clean Air Act $54,924
93.645 Stephanie Tubbs Jones Child Welfare Services Program $47,716
93.441 Indian Self-Determination - Covid-19 $40,595
15.562 Dixie Valley Water Export Study $36,704
93.054 National Family Caregiver Support, Title Vi, Part C, Grants to Indian Tribes and Native Hawaiians $31,703
30.009 Employment Discrimination Project Contracts_indian Tribes $26,955
93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (sed) $26,086
11.300 Investments for Public Works and Economic Development Facilities $21,615
66.805 Leaking Underground Storage Tank Trust Fund Corrective Action Program $16,499
15.113 Indian Social Services Welfare Assistance $14,968
84.299 Indian Education -- Special Programs for Indian Children $14,392
14.862 Indian Community Development Block Grant Program $12,000
66.306 Environmental Justice Collaborative Problem-Solving Cooperative Agreement Program $7,029
93.424 Non-Aca/pphf—building Capacity of the Public Health System to Improve Population Health Through National Nonprofit Organizations $6,600
14.218 Community Development Block Grants/entitlement Grants $3,900
20.106 Airport Improvement Program, Infrastructure Investment and Jobs Act Programs, and Covid-19 Airports Programs - Covid-19 $2,661
66.818 Brownfields Multipurpose, Assessment, Revolving Loan Fund, and Cleanup Cooperative Agreements $1
93.569 Community Services Block Grant - Covid-19 $-1
64.035 Veterans Transportation Program $-6,830
93.568 Low-Income Home Energy Assistance - Covid-19 $-88,609
15.152 Land Buy-Back for Tribal Nations $-90,579