EIN: 043337456
UEI: T56BV185GKB6
Audited by: WIPFLI LLP
Oversight agency: 93 [Department of Health and Human Services]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 30, 2025. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by March 30, 2026 (158 days ago).
What is a management decision? →During the audit, Wipfli LLP proposed several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, other revenue, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the consolidated financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization’s internal controls over financial reporting and the preparation of the consolidated financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2023 audit, finding number 2023-001, the December 31, 2022 audit, finding number 2022-001 and the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization’s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number 2024-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 5H79SM087536-02, 1H79SM087590-01, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-03, 5H79SP082229-04, 1H79SM088765-01, 1H79SM088765-02, 1H79TI085542-01, 5H79TI085542-02, 5H79T086128-02 and Pass-through awards CD9-23-4425 and CD9-25-4425 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 6 NU38TO000023-01-00, 6 NU38TO000023-02-00 and 6 NU38OT000257-05-03 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 5H79TI083088-02, 5H79TI083088-03, 6H79TI085684-01M003, 1H79T1087860-01 and Pass-through award CD9-24-5124 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-03 and 5S06GM142115-04 Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, other revenue, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the consolidated financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization’s internal controls over financial reporting and the preparation of the consolidated financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2023 audit, finding number 2023-001, the December 31, 2022 audit, finding number 2022-001 and the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization’s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.
2024-001 - Material Weakness - Material Adjusting Journal Entries WPHW understands this finding and has corrected this error, but the correction was not fully completed for FY24 due to the timing of receiving the FY23 audit. In October 2024, we transitioned back to QuickBooks fully, we also made significant staff role changes. Our accounting department now has a Director of Accounting and a new manager, Accounting Manager. With these new positions, we have developed the following procedures for adjusting journal entries: 1) Accounting Director, Accounting Manager or Accountant Specialist identifies need for a journal entry 2) Accounting Specialist pulls the supporting documentation for the required entry, creates journal entry template in Excel or hand writes on supporting document, and prepares journal entry packet with supporting documentation for entry into QB. 3) Accounting Manager/Director of Accounting reviews packet and determines who can enter journal a. If reviewed by Director of Accounting, entry is entered QuickBooks by Accounting Specialist/Accounting Manager b. If reviewed by Accounting Manager, entry is entered into QuickBooks by Accountant Specialist 4) Once journal entry is entered into QuickBooks, entry is printed from QB system and added to packet. The packet is returned to the preparer to ensure all elements were completed corrected and signed off on 5) Completed packet goes to filing and are scanned into our electronic file system All adjustments must go through three different individuals to ensure separation of duties. This process was implemented during Q4 of FY24. The Director of Accounting will go back over all the journals completed before this date to review how each were completed and delegate additional review to the Accounting Manager and Accounting Specialist to ensure each journal entry had appropriate review and support. With this process in place, we anticipate this issue being fully resolved in FY25.
2023-001
The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization’s financial records to the consolidated financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust grants receivable and refundable advances for current year activity, to adjust promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2023 audit, finding number 2023-002, the December 31, 2022 audit, finding number 2022-002, and the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization’s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number 2024-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 5H79SM087536-02, 1H79SM087590-01, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-03, 5H79SP082229-04, 1H79SM088765-01, 1H79SM088765-02, 1H79TI085542-01, 5H79TI085542-02, 5H79T086128-02 and Pass-through awards CD9-23-4425 and CD9-25-4425 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 6 NU38TO000023-01-00, 6 NU38TO000023-02-00 and 6 NU38OT000257-05-03 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 5H79TI083088-02, 5H79TI083088-03, 6H79TI085684-01M003, 1H79T1087860-01 and Pass-through award CD9-24-5124 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-03 and 5S06GM142115-04 Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization’s financial records to the consolidated financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust grants receivable and refundable advances for current year activity, to adjust promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2023 audit, finding number 2023-002, the December 31, 2022 audit, finding number 2022-002, and the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization’s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
2024-002 - Material Weakness - Year End Cutoff WPHW understands this finding and recognizes the corrections were not completed FY24, but have been implemented, as stated in the FY23 Corrective Action Plan. WPWH implemented the following process: 1) Full year-end check list is distributed and review by staff (Accounting Specialists, Accountants, and AR/AP Specialists) prior to year-end for review and training, conducted by the Director of Accounting and Accounting Manager a. Review each step with staff and provide training on the expectation for each step 2) Accounting Specialists and Accountants complete necessary year-end tasks 3) Accounting Manager reviews all completed tasks to ensure accuracy and completeness 4) Director of Accounting conducts a final review and signs off at the end of the year With this clear process in place, we anticipate this issue being fully resolved in FY25.
2023-002
Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated consolidated financial statements. This is a repeat finding from the December 31, 2023 audit, finding number 2023-003, the December 31, 2022 audit, finding number 2022-003 and the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number 2024-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 5H79SM087536-02, 1H79SM087590-01, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-03, 5H79SP082229-04, 1H79SM088765-01, 1H79SM088765-02, 1H79TI085542-01, 5H79TI085542-02, 5H79T086128-02 and Pass-through awards CD9-23-4425 and CD9-25-4425 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 6 NU38TO000023-01-00, 6 NU38TO000023-02-00 and 6 NU38OT000257-05-03 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 5H79TI083088-02, 5H79TI083088-03, 6H79TI085684-01M003, 1H79T1087860-01 and Pass-through award CD9-24-5124 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-03 and 5S06GM142115-04 Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated consolidated financial statements. This is a repeat finding from the December 31, 2023 audit, finding number 2023-003, the December 31, 2022 audit, finding number 2022-003 and the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
2024-003- Significant Deficiency - Segregation of Duties WPHW understands this finding and continues to work to sufficiently segregate duties. In October 2024, we implemented more rigorous segregation of duties procedures that have been fully implemented in FY25. In addition, we have restructured our accounting team to ensure proper segregation of duties. WPHW has implemented the following process to ensure the separation of duties: 1) Accounting Specialists will have access to the accounting software and will not have any access to the bank accounts for entry of information. 2) Accounting Manager and Accounting Specialists will have read-only access to the bank accounts and full access to the accounting software to verify and review day-to-day transactions. 3) The Director of Accounting will have full access to the bank and review only access to the accounting software to do the proper review process. 4) Tasks can be handed off between staff within each level, but to ensure appropriate separation of duties, task cannot cross levels We believe that this issue has been fully resolved in FY25.
2023-003
The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2024-007 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 5H79SM087536-02, 1H79SM087590-01, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-03, 5H79SP082229-04, 1H79SM088765-01, 1H79SM088765-02, 1H79TI085542-01, 5H79TI085542-02, 5H79T086128-02 and Pass-through awards CD9-23-4425 and CD9-25-4425 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 6 NU38TO000023-01-00, 6 NU38TO000023-02-00 and 6 NU38OT000257-05-03 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 5H79TI083088-02, 5H79TI083088-03, 6H79TI085684-01M003, 1H79T1087860-01 and Pass-through award CD9-24-5124 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-03 and 5S06GM142115-04 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
2024-007 - Significant Deficiency in Internal Control and Non-material Noncompliance - Schedule of Expenditures of Federal Award Awareness and Preparation WPHW understands this finding and will be implementing further steps to ensure full compliance with this finding. The follow process has been put in place to ensure compliance: 1) Director of Accounting and Grants Director will ensure they have appropriate training and work collaboratively to develop documentation process a. The Grant Director will update all grants as they are received, to ensure an accurate list of grants b. The Director of Accounting will update all the financial data for each grant 2) The Director of Accounting will be responsible for the review and submitting document to the auditing firm For FY25, the Director of Accounting and Grant Director will jointly build the document and review to ensure completeness and accuracy. Person(s) Responsible: Beth McLean, Director of Accounting Timing for Implementation: FY25-FY26
2023-008
FAC accepted this audit on September 30, 2024 — management decision was due March 30, 2025.
Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03
Show full finding ▾Hide full finding ▴Finding Number 2023-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03
2023-001 - Material Weakness - Material Adjusting Journal Entries WPHW understands this finding and recognizes that corrections that were planned for FY23 did not come to fruition. WPHW was in the process of implementing a new financial management system, NetSuite. It was our plan to implement new processes that would have fully addressed prior concerns. It was our plan to have the FY23 audit completed in both NetSuite and QuickBooks. However, we encountered several issues with the implementation of the new system, which delayed prior year corrected actions. In May 2024, WPHW decide to no longer work with NetSuite, due to the number of issues with the system and the company. Since that time, we have fully committed to QuickBooks and have started engaging in systematic business process redesign of our financial system. At the time of the transition back to QuickBooks fully, we also made significant staff role changes. Our accounting department now has a Director of Accounting and two new managers, AR/AP Manager and Accounting Manager. With these new positions, we have developed the following procedures for adjusting journal entries: 1) Accounting Director, Accounting Manager or AR/AP Manager identifying need for a journal entry 2) Accounting Specialist or AR/AP Specialist pulls the supporting documentation for the required entry, creates journal entry template in Excel, and prepares journal entry packet with supporting documentation for entry into QB. 3) Accountant or Accounting Manager reviews packet and determines who can enter journal a. If reviewed by Accountant, entry is entered QuickBooks by Accounting Specialist b. If reviewed by Accounting Manager, entry is entered into QuickBooks by Accountant 4) Once journal entry is entered into QuickBooks, entry is printed from QB system and added to packet. The packet is returned to the preparer to ensure all elements were completed corrected and signed off on 5) Completed packet goes to filing and are scanned into our electronic file system All adjustments must go through three different individuals to ensure separation of duties. This process will be implemented during Q4 of FY24. The Director of Accounting will go back over all the journals completed before this date to review how each were completed and delegate additional review to the Accounting Manager and Accounting Specialist to ensure each journal entry had appropriate review and support. With this process in place, we anticipate this issue being fully resolved in FY25.
2022-001
Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03
Show full finding ▾Hide full finding ▴Finding Number 2023-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03
2023-002 - Material Weakness - Year End Cutoff WPHW understands this finding and recognizes the corrections that were planned for FY23 did not come to fruition due to the challenges with implementing a new financial management system. Despite these challenges, WPHW has made strides in improving our year-end processes and acknowledges that there is additional improvement needed. For FY23, WPHW created a year-end check list and started the review process. Unfortunately, due to staff absences and NetSuite issues, we were not able to fully implement these changes. Both situations have provided us with lessons learned for how to correctly implement changes in the future. For FY24, WPWH implemented the following process: 1) Full year-end check list is distributed and review by staff (Accounting Specialists, Accountants, and AR/AP Specialists) prior to year-end for review and training, conducted by the Director of Accounting and Accounting Manager a. Review each step with staff and provide training on the expectation for each step 2) Accounting Specialists and Accountants complete necessary year-end tasks 3) Accounting Manager reviews all completed tasks to ensure accuracy and completeness 4) Director of Accounting conducts a final review and signs off at the end of the year With this clear process in place, we anticipate this issue being fully resolved in FY24.
2022-002
Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03
Show full finding ▾Hide full finding ▴Finding Number 2023-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC’s major federal programs. Questioned Costs: None Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03
2023-003- Significant Deficiency - Segregation of Duties WPHW understands this finding and recognizes that corrections that were planned for FY23 were not able to be fully implemented. Our prior year corrective actions and business process were redesigned to work with our new financial management system, NetSuite. It was our plan to have the FY23 audit completed in both NetSuite and QuickBooks, and the NetSuite changes would have demonstrated our corrective action for the segregation of duties, since this was part of the software’s functionality. However, we encountered several issues with the implementation of the new system and WPHW decide to move away from NetSuite in May 2024. Since that time, we have fully committed to QuickBooks and have started engaging in systematic business process redesign of our financial system. WPHW has implemented the following process to ensure the separation of duties: 1) AR/AP Specialists and Accounting Specialists will have access to the accounting software and will not have any access to the bank accounts for entry of information. 2) Accountants, Accounting Manager and AR/AP Manager will have read-only access to the bank accounts and full access to the accounting software to verify and review day-to-day transactions. 3) The Director of Accounting will have full access to the bank and review only access to the accounting software to do the proper review process. 4) Tasks can be handed off between staff within each level, but to ensure appropriate separation of duties, task cannot cross levels With these implemented there will be clear separation of duties this will allow mitigating of procedures to be formed by somebody who has full access to both systems to help ensure that there is no cross between any possible chance of fraud and decrease risk of significant errors and/or misstated financial statements. Access for the Director of Accounting to make adjustments will be cut off by October 1, 2024, at which time the process will be fully implemented. With this process in place, we anticipate this issue being fully resolved in FY25.
2022-003
During our testing of cash disbursements, we noted that an expense that was charged to a major program in 2023 was for a service that was performed in 2022. Criteria: The organization should be following GAAP, when the expense was incurred but not paid for in 2022, it should have been recognized as an expense and accrued as a liability. Cause: The finance department staff did not record the transaction properly. Effect: Grant revenue and expenses were understated in 2022 and overstated in 2023. Recommendation: Finance department staff should review and enter invoices in the accounting system as they come in, so as to ensure the transactions are being properly recorded. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2023-006 Repeat Finding: No Type of Finding: Significant Deficiency Description: Recording Expenses in Proper Period Condition: During our testing of cash disbursements, we noted that an expense that was charged to a major program in 2023 was for a service that was performed in 2022. Criteria: The organization should be following GAAP, when the expense was incurred but not paid for in 2022, it should have been recognized as an expense and accrued as a liability. Cause: The finance department staff did not record the transaction properly. Effect: Grant revenue and expenses were understated in 2022 and overstated in 2023. Recommendation: Finance department staff should review and enter invoices in the accounting system as they come in, so as to ensure the transactions are being properly recorded. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
2023-006 - Significant Deficiency - Recording Expenses in Proper Period WPHW understands this finding and recognizes that correction that were planned for FY23 were not able to be fully implemented. WPHW accounting department went through some staffing position shifts in the Q2 of FY24 to assist with separation of duties, which will help address the expense recording process. The follow process will be implemented to address this finding: 1) Accounting Specialists, AR/AP Manager, Accounting Manager, and Accountants will be trained by the Director of Accounting on the appropriate manner of recording expenses in the proper period. a. Follow up trainings will occur quarterly as part of the Accounting Team Meetings b. Team training will cover accrual process and the process to enter invoices as received vs incurred. This process has been implemented within FY24 and as it continued process in which this WP HW team is continuing to hone and define for the organization to ensure transactions are being properly recorded revenue recognition entry for restricted and non-restricted revenue into QuickBooks, the supporting documentation process, and the review process 2) Accounting Director will look for additional outside training to ensure all staff have development opportunities 3) Accounting Specialists will enter expenses into to system and the Accounting Manager, Accountant, and Accounting Director will all review the entry to ensure the correct categorization of expenses a. WPHW has implemented this step earlier in the review process, and with multiple people, avoid said issues This process will be implemented during Q4 FY24 and all prior entries will be reviewed by the Director of Accounting for accuracy.
The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: 1. Federal award identification; 2. All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; 3. Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. 4. (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the passthrough entity must determine the appropriate rate in collaboration with the subrecipient, which is either: 1. The negotiated indirect cost rate between the pass-through entity and the subrecipient; 2. The de minimis indirect cost rate (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. (iii) 5. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and 6. Appropriate terms and conditions concerning closeout of the subaward. b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. c. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. d. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. 4. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. e. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: 1. Providing subrecipients with training and technical assistance on program-related matters; and 2. Performing on-site reviews of the subrecipient's program operations; 3. Arranging for agreed-upon-procedures engagements as described in § 200.425. f. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. g. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. h. Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations. Cause: The Organization’s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2023-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Program: AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023- 01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: 1. Federal award identification; 2. All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; 3. Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. 4. (i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the passthrough entity must determine the appropriate rate in collaboration with the subrecipient, which is either: 1. The negotiated indirect cost rate between the pass-through entity and the subrecipient; 2. The de minimis indirect cost rate (ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. (iii) 5. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient’s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and 6. Appropriate terms and conditions concerning closeout of the subaward. b. Evaluate each subrecipient’s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. c. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in § 200.208. d. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: 1. Reviewing financial and performance reports required by the pass-through entity. 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. 3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by § 200.521. 4. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section § 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the passthrough entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. e. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: 1. Providing subrecipients with training and technical assistance on program-related matters; and 2. Performing on-site reviews of the subrecipient's program operations; 3. Arranging for agreed-upon-procedures engagements as described in § 200.425. f. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in § 200.501. g. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. h. Consider taking enforcement action against noncompliant subrecipients as described in § 200.339 of this part and in program regulations. Cause: The Organization’s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
2023- 007 - Material Weakness in Internal Control and Material Noncompliance – Sub-recipient Monitoring and Management WPHW understands this finding and recognizes that correction that were planned for FY23 were not able to be fully implemented. One of the significant challenges WPHW had over the past couple of year, in addition to IT system challenges, is staffing. WPHW has hired three individuals to develop our contracting process and had performance issues with all three individuals. In addition to the difficulties with the NetSuite implementation, we have had to re-evaluate our sub-recipient monitoring and management business process. The following process will address this finding: 1) Director of Accounting and the Accounting Manager will review CFR 200.332 and develop a revised business process for the WPHW contract system a. Accounting Team will hire 2 Accounting Specialists who will each have specific sub-recipient monitoring responsibilities 2) Director of Accounting and the Accounting Manager will review all current contract to ensure the following: a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: i. Federal, State or other award identification. ii. Subrecipient name (which must match the name associated with its unique entity identifier); iii. Subrecipient's unique entity identifier; iv. Award Identification Number (FAIN/SAIN); v. Award Date of award to the recipient by the Federal agency; vi. Subaward Period of Performance Start and End Date; vii. Subaward Budget Period Start and End Date; viii. Amount of Federal Funds (if applicable) Obligated by this action by the pass-through entity to the subrecipient; ix. Total Amount of Federal Funds Obligated, if applicable, to the subrecipient by the pass-through entity including the current financial obligation; x. Total Amount of the Federal Award committed to the subrecipient by the pass-through entity; xi. Federal award project description, as required to be responsive to the Federal Funding Accountability and Transparency Act (FFATA); xii. Name of Federal awarding agency, pass-through entity, and contact information for awarding official of the Pass-through entity; xiii. Assistance Listings number and Title; the pass-through entity must identify the dollar amount made available under each Federal award and the Assistance Listings Number at time of disbursement; xiv. Identification of whether the award is R&D; and xv. Indirect cost rate for the Federal, State, or other award (including if the de minimis rate is charged) per § 200.414. b. All requirements imposed by the pass-through entity on the subrecipient are in accordance with Federal, State, Local statutes, regulations and the terms and conditions of the award; c. Determines and ensure completion of required financial and performance reports; d. Has an approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government or utilizes the de minimus. e. States that subrecipient permit the pass-through entity and auditors to have access to the subrecipient's records and financial statements as necessary for the pass-through entity to meet the requirements of this part f. Details appropriate terms and conditions concerning closeout of the subaward. g. Subrecipient risk assessment that accesses: i. prior experience with the same or similar subawards; ii. previous audits iii. personnel or substantially changed systems iv. Prior monitoring results 1. Subaward conditions will be placed if issues arise 3) Implement sub-recipient monitoring process. a. Conduct invoice review monthly i. All invoices must include full back up and support for expenses ii. All invoices will be reviewed as they are received to ensure expenses are allowable iii. Any issues that arise will be addressed prior to invoice payment b. Conduct contract monitoring visit annually i. Hold a meeting with the sub-recipient to review the following: 1. Reviewing financial and performance reports 2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the subaward. 3. Training and technical assistance on program-related matters 4. Determine corrective action for any deficiencies or findings and determine risk 5. Discussion of enforcement action against noncompliant subrecipient This process will be reviewed, and implementation will begin during Q4 FY24. All current FY24 contracts will be reviewed, and monitoring visits scheduled. For FY25, all contracts will be in compliance with requirements.
2022-007
The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2023-008 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Schedule of Expenditures of Federal Awards Awareness and Preparation Major Programs: AL#93.243 - Substance Abuse and Mental Health Services – Direct Award (DHHS) – Award numbers: 1H79SM087536-01, 1H79SM087590-01, 5H79SP081724-04, 5H79SP081724-05, 5H79SM082160-04, 5H79SM082160-05, 5H79SP082229-02, 5H79SP082229-03, 1H79SM088765-01, 1H79TI085542-01, H79TI086128-01 and CD9-23-4425 AL#93.738 – PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds – Direct Award (DHHS) – Award number: 5 NU58DP006960-02-00 and 6 NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement – Direct Award (DHHS) – Award numbers: 1 NU38TO000023-01-00, 6 NU38TO000023-01-01, 6 NU38OT000257-05-03 and 6 NU38OT000257C3 AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: The Organization did not have all federal expenditures recorded in their trial balance and did not have accurate records of all expenditures spent during the audit period. In addition, it did not have all of the necessary information or training to create the Schedule of Expenditures of Federal Awards. Criteria: Under 2 CFR Part 200.502, the auditee must prepare the Schedule of Expenditure of Federal Awards to cover the appropriate audit period and to include all applicable federal expenditures expended during the audit period. Cause: The Organization does not have processes in place to properly track award numbers, award periods, assistance listing numbers and grant spending. Effect: The Organization was unable to provide the auditors with a complete Schedule of Expenditures of Federal Awards (including all grants with federal awards, all assistance listing numbers, total amount of federal awards expended) and could not verify the completeness of expenditures recorded in their financial statements provided for the audit. Recommendation: We recommend the Organization create processes and procedures that capture all federal funding received and track applicable expenditures. This report should be reconciled regularly (at least monthly) when requests for reimbursement are made and should include all applicable information necessary to identify the funding agency, assistance listing number, and any other pertinent passthrough information. With this process in place, the Organization will be better able to track and monitor grant funding, plan future projects or future funding needs, and prepare for the annual audit. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
2023-008 - Significant Deficiency in Internal Control and Non-material Noncompliance - Schedule of Expenditures of Federal Award Awareness and Preparation WPHW understands this finding and has already taken steps to ensure this issue does not come back up for FY24. The follow process has been put in place to ensure compliance: 1) Director of Accounting and Grants Director will ensure they have appropriate training and work collaboratively to develop documentation process a. The Grant Director will update all grants as they are received, to ensure an accurate list of grants b. The Director of Accounting will update all of the financial data for each grant 2) The Director of Accounting will be responsible for the review and submitting document to the auditing firm For FY24, the Director of Accounting and Grant Director will jointly build the document and review to ensure completeness and accuracy. In FY25, the schedule of expenditures of federal award will be prepared as the year progresses.
During testing of cash disbursements there were expenditures for which supporting documentation could not be located. Criteria: Under 2 CFR Part 200.403 (a) costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and (g) costs must be adequately documented in order to be allowable under Federal awards. Cause: The Organization misplaced the invoices. Effect: The Organization was unable to provide the auditors with proper supporting documentation for testing and therefore it could not be determined whether the expenses were reasonable and necessary to be charged to the programs. Recommendation: We recommend the Organization create processes and procedures whereby all invoices and other pertinent supporting documentation is saved and filed either in paper or electronic form to support the expense charged to the federal award and ensure the expense is allowable. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2023-009 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Supporting Documentation for Expenses Incurred During the Year Major Programs: AL#93.788 – Opioid STR – Direct Award (DHHS) – Award numbers: 1H79TI083088-01, 5H79TI083088-02, 6H79TI085684-01M003 and CD9-23-4425 AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: AL#93.788 – $1,000 AL#93.859 - $364, based on the error the questioned costs could exceed $25,000 How the questioned costs were computed: N/A Compliance Requirement: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: During testing of cash disbursements there were expenditures for which supporting documentation could not be located. Criteria: Under 2 CFR Part 200.403 (a) costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles and (g) costs must be adequately documented in order to be allowable under Federal awards. Cause: The Organization misplaced the invoices. Effect: The Organization was unable to provide the auditors with proper supporting documentation for testing and therefore it could not be determined whether the expenses were reasonable and necessary to be charged to the programs. Recommendation: We recommend the Organization create processes and procedures whereby all invoices and other pertinent supporting documentation is saved and filed either in paper or electronic form to support the expense charged to the federal award and ensure the expense is allowable. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
2023-009- Significant Deficiency in Internal Control and Non-material Noncompliance - Supporting Documentation for Expenses Incurred during the Year WPHW understands this finding and has already taken steps to ensure this issue does not come back up for FY24. WPHW keeps an extensive filing system which is mostly paper and not electronic. Our initial plan was utilized in NetSuite program as part of the electronic filing keeping system. After the transition away from NetSuite, we recognized the need for electronic filing keeping. In FY24 we did transition utilizing our share file to keep electronic copies of everything that we have paper copy. This includes AP items, AR items along with journal entries, bank reconciliations anything else deemed necessary. We understand the importance of having all documentation readily at hand for our monthly review’s yearly reviews and especially for the audit. Our process includes the following: 1) As items are entered into the vendor center of our accounting software, they are then scanned into the following system labeled by the individual in which it's entering the information into the system. 2) Invoices are prepared within the accounting software printed and then scanned with all supporting documentation into this electronic filing system. 3) Journal entries once prepared are printed attached with supporting documentation and then scan it to the electronic filing system. 4) Other items in which we keep electronic documentation following similar process these include bank reconciliations, contracts, and other pertinent files. All documentation is also kept within a filing system here within our department. Each group of documented items are labeled and filed chronologically in a centralized location. As we move through FY24 into FY25 we will continue to review and improve this internal process.
During testing of reporting, we noted the Annual Form SF-425 included revenue for months beyond the reporting period end date. Criteria: Amounts included on the Annual SF-425 report filed were to include amounts through July 31, 2023, the reporting period end date. Cause: The Organization did not review the report prior to filing to ensure the correct data was used to prepare the report. Effect: The Organization filed a report with incorrect data. Recommendation: We recommend the Organization create processes and procedures whereby all someone independent of the report preparation process reviews the reports with supporting documentation prior to filing to ensure the reports were prepared accurately. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2023-010 Repeat Finding: No Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Inaccurate Reporting Major Programs: AL#93.859 – Biomedical Research and Research Training – Direct Award (DHHS) – Award numbers: 5S06GM142115-02 and 5S06GM142115-03 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Condition: During testing of reporting, we noted the Annual Form SF-425 included revenue for months beyond the reporting period end date. Criteria: Amounts included on the Annual SF-425 report filed were to include amounts through July 31, 2023, the reporting period end date. Cause: The Organization did not review the report prior to filing to ensure the correct data was used to prepare the report. Effect: The Organization filed a report with incorrect data. Recommendation: We recommend the Organization create processes and procedures whereby all someone independent of the report preparation process reviews the reports with supporting documentation prior to filing to ensure the reports were prepared accurately. Views of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
2023-010- Significant Deficiency in Internal Control and Non-material Noncompliance – Inaccurate Reporting WPHW understands this finding and has already taken steps to ensure this issue does not happen again. The following process has been put into place to ensure all expenses are appropriately accrued into the correct period and ensure that reporting is correct. 1) The Accounting and AR/AP Specialist will review all incoming expenses for a period of 90 days after grant end to determine appropriate grant year for the expense 2) Accounting Manager and Director of Accounting will conduct monthly grant review to ensure all expenses are in the appropriate period 3) Director of Accounting and Director of Grants Management will meet on a monthly basis to review all grants due to close a. Director of Grants Management will review all financial reports to ensure programmatic dates match and expenses are correctly allocated
FAC accepted this audit on June 29, 2023 — management decision was due December 29, 2023.
During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2022-001 Repeat Finding: Yes Type of Finding: Material Weakness Description: Material Adjusting Journal Entries Condition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, refundable advance liability, notes payable, grant revenue and expenses, contributions with and without donor restrictions and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2021 audit, finding number 2021-001. Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit. Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit. Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting. Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles. View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.
Wabanaki Public Health and Wellness received our FY21 audit in April 2023, which did not allow for the changes to be made in time for FY22. The corrective action plan from FY21 continues to be our course of action and will be fully implementing the following to ensure compliance in FY23. Wabanaki Public Health & Wellness has implemented an updated journal entry (JE) process as soon as the issues was mentioned during the audit process in July 2022. All Accounting Specialists, Accountants, and Senior Accountants have access to the accounting software and have the ability to do the journal entry. Once they complete the JE, the team member goes to another Accountant/Senior Accountant to review and sign off after making the entry. Items are reviewed for accuracy, appropriateness, and correctness. The JE is then printed (with supporting documentation attached), signed by both the individual initiating the entry as well as the person approving the entry, and then kept on file in a locked file cabinet. After the audit process concluded, the Finance department was reorganized to have two new key roles. The Director of Finance oversees all the financial functions for WPHW, and the Financial Quality and Compliance Manager will be responsible for ensuring that practices and financials are completed per policy and regulations. Starting 2nd quarter of 2023, WPHW will be using a new accounting software that will lessen the need to print JE. However, the system has a built-in monitoring and approval function that will require all JE to be reviewed and approved. This entire process will be able to be seen from start to finish within the software. In addition, the Financial Quality and Compliance Manager will conduct a monthly review all journal entries completed, starting the second quarter of 2023. Person(s) Responsible: Beth McLean Timing for Implementation: Summer 2023
2021-001
The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2022-002 Repeat Finding: Yes Type of Finding: Material Weakness Description: Year End Cutoff Condition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grants receivable and refundable advances for current year activity, to record promises to give, to adjust contributions with and without donor restrictions and to adjust debt for payments made during the year. This is a repeat finding from the December 31, 2021 audit, finding number 2021-002. Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting. Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed. Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States. Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Wabanaki Public Health and Wellness received our FY21 audit in April 2023, which did not allow for the changes to be made in time for FY22. The corrective action plan from FY21 continues to be our course of action and will be fully implementing the following to ensure compliance in FY23. Wabanaki Public Health & Wellness has been reviewing the year end close process as soon as we learned that there was a need for a stronger year end closing procedure. With the two new key roles being implemented the organization will have a full review of the internal control process and the yearend close process. A new full year end closing check list will be set forth to help designate appropriate steps to verify that all accounts have been review and reconciled with support from general ledger. The Director of Finance will review the processes as the accounting teams works through the checklist and once the Accounting team has determined that the process has been completed, the Financial Quality and Compliance Manager will complete a full review/audit of items to ensure that each have followed the year end closing check list and that the accounts have been reviewed and reconciled with the support of the general ledger accounts. Person(s) Responsible: Beth McLean Timing for Implementation: Summer 2023
2021-002
Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2022-003 Repeat Finding: Yes Type of Finding: Significant Deficiency Description: Segregation of Duties Condition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements. This is a repeat finding from the December 31, 2021 audit, finding number 2021-003. Criteria: Internal controls that provide for proper segregation of duties should be in place. Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations. Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists. Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness, NPC. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Wabanaki Public Health and Wellness received our FY21 audit in April 2023, which did not allow for the changes to be made in time for FY22. The corrective action plan from FY21 continues to be our course of action and will be fully implementing the following to ensure compliance in FY23. Wabanaki Public Health & Wellness has acquired a new accounting software, go live 2nd quarter of 2023, that allows the separation of access to items, accounts, lists, assets, etc. to be segregated by positions assignments. Each position has different limitations within the software and access to different levels of accounting limits. The new system has approval processes attached to different sections within the recording aspect of different transactions that requires separate staff to approve entries. Wabanaki Public Health & Wellness has also increased the number of staff to help in the separation amongst duties, to strengthen the internal controls within the accounting system and department. The organization is going through a restructure to ensure there are separations of duties, lack of single staff having full access to all items. The Director of Finance and the Financial Quality and Compliance Manager are two of the new positions that have been implemented to help work through the required changes to get the internal control structure and the separations of duties in place. The Financial Quality and Compliance Manager will continue to review processes and validate compliance within the department and suggest changes for processes as they arise within the accounting department. Person(s) Responsible: Beth McLean Timing for Implementation: Summer 2023
2021-003
Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2022-006 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Payroll Expenditures Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost Principles Condition: Out of the sample tested, there were numerous payroll transactions where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger. Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated?. Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets. Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged. Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Wabanaki Public Health and Wellness received our FY21 audit in April 2023, which did not allow for the changes to be made in time for FY22. The corrective action plan from FY21 continues to be our course of action and will be fully implementing the following to ensure compliance in FY23. Wabanaki Public Health & Wellness has transitioned to an allocation-based payroll in the summer of FY 2022. This change was determined the best practice for the organization to help set standards for forth coming periods. The payroll process is timely and consistent with the allocation base. Staff will maintain clocking hours for time worked, after each quarter a review of actual time spent on grants is compared to the allocated time for each grant. These times studies will the determine the reconciling JE, if any, will be processed to show the actual amounts due for the grants. The time studies will effectively assist in the allocation for the next quarter to determine how each staff member is allocated for payroll. Each WPHW staff member will receive a certification letter for them to review and sign to verify the hours in which they have worked. These certification letters will be built by the Senior Accountant that oversees the payroll entry process. The Director of Finance will have a review process to verify that all staff members have had a full-time study review and that certification letter are correct before staff receive them and the Financial Quality and Compliance Manager will review entire process for each of the first two quarters. Through the multi-step review the overall payroll allocation and expenditure process will be more defined and follows the internal control processes. After receiving the FY22 audit we will be switching back to time-based payroll processing based on actual hours posted by staff. Beginning effective 3rd quarter FY23 our payroll process will remain with Director of HR and the Financial Quality & Compliance Manger reviewing and submitting payroll through TRAXpayroll. The accounting team will then use the Project hours report from Bamboo HR, directly tied to staff time sheets, to input the data for actual hours worked into the payroll workbook to build the JE for each remaining payroll for FY23. The JE will be entered into the financial software prior to the federal draw. Person(s) Responsible: Beth McLean Timing for Implementation: Summer 2023
2021-006
The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.
Show full finding ▾Hide full finding ▴Finding Number: 2022-007 Repeat Finding: Yes Type of Finding: Material Weakness in Internal Control and Material Noncompliance Description: Subrecipient Monitoring and Management Major Programs AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Subrecipient Monitoring Condition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332. Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must: Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes: Federal award identification; All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federal statutes, regulations and the terms and conditions of the Federal award; Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet its own responsibility to the Federal awarding agency including identification of any required financial and performance reports. An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government. If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient, which is either: The negotiated indirect cost rate between the pass-through entity and the subrecipient; The de minimis indirect cost rate The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approved rate. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records and financial statements as necessary for the pass-through entity to meet the requirements of this part; and Appropriate terms and conditions concerning closeout of the subaward. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate subrecipient monitoring. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance with Federal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved. Pass-through entity monitoring of the subrecipient must include: Reviewing financial and performance reports required by the pass-through entity. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federal award provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmation from the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particular subaward. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient from the pass-through entity as required by ? 200.521. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible for resolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and has not otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity may rely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make management decisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate the responsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage risk through ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for the pass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals: Providing subrecipients with training and technical assistance on program-related matters; and Performing on-site reviews of the subrecipient's program operations; Arranging for agreed-upon-procedures engagements as described in ? 200.425. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awards expended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitate adjustments to the pass-through entity's own records. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations. Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements. Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.
Wabanaki Public Health and Wellness received our FY21 audit in April 2023, which did not allow for the changes to be made in time for FY22. The corrective action plan from FY21 continues to be our course of action and will be fully implementing the following to ensure compliance in FY23. Wabanaki Public Health & Wellness followed sections of the subrecipient monitoring for requirements of documentation and follow through, however there were areas in which the audit team brough forth to light that needed some enhancing for procedures. WPHW will follow through with full review of the OMB standards for the subrecipient monitoring and build a check list to determine that each required section/item is followed throughout the period of award. The WPHW team, which includes, the Director of Finance, Financial Quality and Compliance Manager, and the Contract Specialist will be working together to build the required list and procedure and reviewing the checklist for when the award is first presented to allow both parties, (sub awardee and WPHW) to understand the requirements for the award. Throughout the award period WPHW will maintain required documentation following the CFR 200.332 guidelines. The Financial Quality and Compliance Manager will review processes through the periodic review of all awards to verify that monitoring has been completed at the deemed timeframe and all parties involved are maintaining the set forth requirements of the award. Person(s) Responsible: Beth McLean Timing for Implementation: Summer 2023
2021-005
The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.
Show full finding ▾Hide full finding ▴Finding Number: 2022-008 Repeat Finding: Yes Type of Finding: Significant Deficiency in Internal Control and Nonmaterial Noncompliance Description: Data Collection Form Late Filing Major Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 1H79SM087536-01, 1H79M087590-01, 5H79SP081724-03, 5H79SP081724-04, 5IH79SM082160-03, 5IH79SM082160-04, 6H79SP082229-01M001, 6H79SP082229-01M002, 5H79SM080189-03 AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.738 ? PPHF: Racial and Ethnic Approaches to Community Health Program financed solely by Public Prevention and Health Funds ? Direct Award (DHHS) ? Award numbers: 5NU58DP006960-02-00 and 6NU58DP006960-01-01 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 5NU38OT000257-04-00 and 5NU38OT000257-05-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirement: Reporting Requirement Condition: The Organization did not submit the 2021 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner. Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period. Cause: The Organization?s 2021 audit was not completed prior to the due date. Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance. Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.
Wabanaki Public Health and Wellness received our FY21 audit in April 2023, which did not allow for the changes to be made in time for FY22. The corrective action plan from FY21 continues to be our course of action and will be fully implementing the following to ensure compliance in FY23. Wabanaki Public Health & Wellness is committed to having our Single audits completed in time for submission to the clearing house within the appropriate time frame. WPHW has obtained WIPFLI for the next five years and will schedule our audit as early in the season as possible. Wabanaki Public Health & Wellness will be prepared to provide all information that is requested prior to the auditors being within our offices by the designated date in which the items are requested. During the period in which the auditors are within house and the weeks following the Director of Finance and the Financial Quality and Compliance Manager will be available to answer any questions, provide documentation, and details for all requirements for WIPFLI to complete the audit for submission to the clearing house. Person(s) Responsible: Beth McLean Timing for Implementation: Summer 2023
2021-008
The Organization did not meet its financial reporting obligations under the grant during the year. Context: During the audit, it was determined the Organization did not submit reports on a timely basis. Cause: The Organization was not aware of the due dates of the reports. Effect: The Organization was not in compliance with federal regulations and guidelines. Recommendation: Management should develop proper controls around federal grant related reporting requirements. We recommend management develop a due date list of all reports required to be filed for each grant and assign responsibility for review, approval and submission of the reports to the funding sources. The Organization should file the monthly reports in a timely manner and ensure amounts reported agree to supporting documentation and comply with federal compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2022-009 Repeat Finding: Yes Type of Finding: Significant deficiency in Internal Control and Nonmaterial Noncompliance Description: Late reporting Major Programs: AL#93.665 - Emergency Grants to Address Mental and Substance Use Disorders During COVID-19 ? Direct Award (DHHS) ? Award numbers: 6H79FG000252-01M003 and 6H79FG000689-01M004 AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00 AL#93.933 ? Demonstration Projects for Indian Health ? Direct Award (DHHS) ? Award numbers: H1H5IHS001-01-01 and H1H5IHS001-02-00 Questioned Costs: None How the questioned costs were computed: N/A Compliance Requirements: Reporting Requirement Criteria: The Organization is required to submit monthly fiscal reports to the federal funding source beginning 60 days after the Notice of Awards are issued. Condition: The Organization did not meet its financial reporting obligations under the grant during the year. Context: During the audit, it was determined the Organization did not submit reports on a timely basis. Cause: The Organization was not aware of the due dates of the reports. Effect: The Organization was not in compliance with federal regulations and guidelines. Recommendation: Management should develop proper controls around federal grant related reporting requirements. We recommend management develop a due date list of all reports required to be filed for each grant and assign responsibility for review, approval and submission of the reports to the funding sources. The Organization should file the monthly reports in a timely manner and ensure amounts reported agree to supporting documentation and comply with federal compliance requirements. View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Wabanaki Public Health and Wellness received our FY21 audit in April 2023, which did not allow for the changes to be made in time for FY22. The corrective action plan from FY21 continues to be our course of action and will be fully implementing the following to ensure compliance in FY23. Wabanaki Public Health & Wellness has implemented new positions and transitions of staff on order to increase processes to fall within compliance of all requirements for grants. This includes the reporting aspect financially and programmatically. The Financial Quality and Compliance Manager will be in complete review to verify that all reporting is completed within the correct time frame for each grant. The Grants and Accounting teams will compile a comprehensive list of all grants and dates for all reporting. The Financial Quality and Compliance Manager will maintain the list, file financial reports, and review that program staff has submitted all required reports as needed. Person(s) Responsible: Beth McLean Timing for Implementation: Summer 2023
2021-007
FAC accepted this audit on April 18, 2023 — management decision was due October 18, 2023.
During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, accrued payroll and related expenses, refundable advance liability, notes payable, grant revenue and expenses and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2020 audit, finding number 2020-001.Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit.Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit.Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting.Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles.View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.Finding Number 2021-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC?s major federal programs.Questioned Costs: NoneMajor Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 6H79SM083569-01M002, 6H79SPO81724-02M003, 5H79SP081724-03, 5H79SM082160-03M001, 5H79SM082160-03M002, 6H79SP082229-01M001, 5H79SM080189-02, 5H79SM080189-03AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00
Show full finding ▾Hide full finding ▴Finding Number: 2021-001Repeat Finding: YesType of Finding: Material WeaknessDescription: Material Adjusting Journal EntriesCondition: During the audit, Wipfli LLP proposed prior period adjustments and several adjusting journal entries to properly record cash, grants receivable, property and equipment, accounts payable, accrued payroll and related expenses, refundable advance liability, notes payable, grant revenue and expenses and the activity in Wabanaki Healing and Recovery, LLC, which we deem to be material in relation to the financial statements. We noted that not all accounts were consistently reconciled on a timely basis and adjusting journal entries are not consistently reviewed by someone other than the preparer. Since the internal controls of the Organization did not detect and record the adjustments described above prior to the audit, a material weakness exists in the Organization?s internal controls over financial reporting and the preparation of the financial statements in accordance with accounting principles generally accepted in the United States. This is a repeat finding from the December 31, 2020 audit, finding number 2020-001.Criteria: Internal controls are effective if they are properly designed and implemented to prevent or detect account misstatements prior to the audit.Cause: The internal controls of the Organization were not effective in preventing or detecting and correcting the misstatements described above prior to the audit.Effect: As a result of the financial reporting matter identified in the condition paragraph, a material weakness exists in the Organization?s internal controls over financial reporting.Recommendation: We recommend the Organization implement procedures, such as timely reconciling of accounts and review of all reconciliations and adjusting journal entries by someone other than the preparer, to provide sufficient internal control over financial reporting so all necessary transactions are recorded in accordance with generally accepted accounting principles.View of responsible officials: Management agrees with the finding and has committed to a corrective action plan.Finding Number 2021-001: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC?s major federal programs.Questioned Costs: NoneMajor Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 6H79SM083569-01M002, 6H79SPO81724-02M003, 5H79SP081724-03, 5H79SM082160-03M001, 5H79SM082160-03M002, 6H79SP082229-01M001, 5H79SM080189-02, 5H79SM080189-03AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00
Wabanaki Public Health & Wellness has implemented an updated journal entry (JE) process as soon as the issues was mentioned during the audit process in July 2022. All Accounting Specialists, Accountants, and Senior Accountants have access to the accounting software and have the ability to do the journal entry. Once they complete the JE, the team member goes to another Accountant/Senior Accountant to review and sign off after making the entry. Items are reviewed for accuracy, appropriateness, and correctness. The JE is then printed (with supporting documentation attached), signed by both the individual initiating the entry as well as the person approving the entry, and then kept on file in a locked file cabinet.After the audit process concluded, the Finance department was reorganized to have two new key roles. The Director of Finance oversees all the financial functions for WPHW, and the Financial Quality and Compliance Manager will be responsible for ensuring that practices and financials are completed per policy and regulations. Starting 2nd quarter of 2023, WPHW will be using a new accounting software that will lessen the need to print JE. However, the system has a built-in monitoring and approval function that will require all JE to be reviewed and approved. This entire process will be able to be seen from start to finish within the software. In addition, the Financial Quality and Compliance Manager will conduct a monthly review all journal entries completed, starting the second quarter of 2023.Person(s) Responsible: Beth McLeanTiming for Implementation: Summer 2022- Spring 2023
2020-001
The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grant receivable and refundable advances for prior year amounts not cleared out in 2021, to adjust grants receivable and refundable advances for current year activity, to adjust debt for payments made during the year and adjustments to accruals in order to properly record payroll accruals for financial reporting purposes. This is a repeat finding from the December 31, 2020 audit, finding number 2020-002.Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting.Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed.Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States.Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements.View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.Finding Number 2021-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC?s major federal programs.Questioned Costs: NoneMajor Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 6H79SM083569-01M002, 6H79SPO81724-02M003, 5H79SP081724-03, 5H79SM082160-03M001, 5H79SM082160-03M002, 6H79SP082229-01M001, 5H79SM080189-02, 5H79SM080189-03AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00
Show full finding ▾Hide full finding ▴Finding Number: 2021-002Repeat Finding: YesType of Finding: Material WeaknessDescription: Year End CutoffCondition: The Organization is responsible for the internal controls over the period-end financial reporting process, including controls over procedures to recognize transactions in the correct period and properly adjust the general ledger. During the audit, it was required to post several material adjusting journal entries to convert the Organization?s financial records to the financial statements as reported. Adjustments were required to correct accounts payable not reconciled at year end, to adjust prepaid expenses, to adjust grant receivable and refundable advances for prior year amounts not cleared out in 2021, to adjust grants receivable and refundable advances for current year activity, to adjust debt for payments made during the year and adjustments to accruals in order to properly record payroll accruals for financial reporting purposes. This is a repeat finding from the December 31, 2020 audit, finding number 2020-002.Criteria: Internal controls should be properly designed and implemented for the Organization to ensure timely and accurate period-end financial reporting.Cause: Internal controls over year end reconciliations of the general ledger and financial reporting were not operating as designed.Effect: The Organization?s internal controls over financial reporting at the general ledger and financial statement levels were not adequate to ensure that a material misstatement of grant agreements would be prevented and/or detected. The Organization was not always in compliance with accounting principles generally accepted in the United States.Recommendation: We recommend the Organization continue to evaluate its year end closeout procedures and put processes in place to ensure that all balance sheet accounts are reconciled from support to the general ledger. The Organization should design and implement effective internal control procedures to ensure the financial statements and related notes are free from material misstatements.View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.Finding Number 2021-002: Represents a material weakness in internal control over compliance with Wabanaki Public Health and Wellness, NPC?s major federal programs.Questioned Costs: NoneMajor Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 6H79SM083569-01M002, 6H79SPO81724-02M003, 5H79SP081724-03, 5H79SM082160-03M001, 5H79SM082160-03M002, 6H79SP082229-01M001, 5H79SM080189-02, 5H79SM080189-03AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00
Wabanaki Public Health & Wellness has been reviewing the year end close process as soon as we learned that there was a need for a stronger year end closing procedure. With the two new key roles being implemented the organization will have a full review of the internal control process and the yearend close process. A new full year end closing check list will be set forth to help designate appropriate steps to verify that all accounts have been review and reconciled with support from general ledger.The Director of Finance will review the processes as the accounting teams works through the checklist and once the Accounting team has determined that the process has been completed, the Financial Quality and Compliance Manager will complete a full review/audit of items to ensure that each have followed the year end closing check list and that the accounts have been reviewed and reconciled with the support of the general ledger accounts.Person(s) Responsible: Beth McLeanTiming for Implementation: Spring 2023
2020-002
Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements.Criteria: Internal controls that provide for proper segregation of duties should be in place.Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations.Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists.Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness.View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.Finding Number 2021-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC?s major federal programs.Questioned Costs: NoneMajor Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 6H79SM083569-01M002, 6H79SPO81724-02M003, 5H79SP081724-03, 5H79SM082160-03M001, 5H79SM082160-03M002, 6H79SP082229-01M001, 5H79SM080189-02, 5H79SM080189-03AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00
Show full finding ▾Hide full finding ▴Finding Number: 2021-003Repeat Finding: NoType of Finding: Significant DeficiencyDescription: Segregation of DutiesCondition: Access to the general ledger, subsidiary ledgers, and assets of the Organization - The accounting manager and certain other individuals have full access to all functions in the accounting software and have the ability to make changes in the general ledger and subsidiary ledgers including fixed assets, accounts payable, and payroll-related ledgers. These individuals also have access to general assets of the Organization, including bank accounts. The lack of segregation of duties and compensating oversight controls creates risk of significant errors or fraudulent transactions, leading to the potential of misstated financial statements.Criteria: Internal controls that provide for proper segregation of duties should be in place.Cause: In an organization with a small number of personnel in its business office and accounting department, there may be an inadequate segregation of duties. This results in certain internal control limitations.Effect: Because of this lack of segregation of duties, the potential for misstatements or misappropriated assets exists.Recommendation: Management should review the user access list for the accounting software to ensure users only have access to what is needed based on their role in the Organization. Management should establish proper mitigating review procedures to be performed by someone who would not have access to the general ledger, subsidiary ledgers, and assets of Wabanaki Public Health and Wellness.View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.Finding Number 2021-003: Represents a significant deficiency in internal control over compliance with Wabanaki Public Health and Wellness, NPC?s major federal programs.Questioned Costs: NoneMajor Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 6H79SM083569-01M002, 6H79SPO81724-02M003, 5H79SP081724-03, 5H79SM082160-03M001, 5H79SM082160-03M002, 6H79SP082229-01M001, 5H79SM080189-02, 5H79SM080189-03AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00
Wabanaki Public Health & Wellness has acquired a new accounting software, go live 2nd quarter of 2023, that allows the separation of access to items, accounts, lists, assets, etc. to be segregated by positions assignments. Each position has different limitations within the software and access to different levels of accounting limits. The new system has approval processes attached to different sections within the recording aspect of different transactions that requires separate staff to approve entries.Wabanaki Public Health & Wellness has also increased the number of staff to help in the separation amongst duties, to strengthen the internal controls within the accounting system and department. The organization is gong through a restructure to ensure there are separations of duties, lack of single staff having full access to all items. The Director of Finance and the Financial Quality and Compliance Manager are two of the new positions that have been implemented to help work through the required changes to get the internal control structure and the separations of duties in place. The Financial Quality and Compliance Manager will continue to review processes and validate compliance within the department and suggest changes for processes as they arise within the accounting department.Person(s) Responsible: Beth McLeanTiming for Implementation: Summer 2022- Spring 2023
Out of a sample of 30 payroll transactions there were a total of 4 where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger.Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;?.Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets.Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged.Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses.View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2021-004Repeat Finding: NoType of Finding: Significant Deficiency in Internal Control and Nonmaterial NoncomplianceDescription: Payroll ExpendituresMajor Programs: 93.243 - Substance Abuse and Mental Health Services ? Direct Awards (DHHS) ?Award numbers: 6H79SM083569-01M002, 5H79SP081724-03, 5H79SM082160-03M001, 5H79SM082160-03M002, 6H79SP082229-01M001, 5H79SM080189-02, 5H79SM080189-03Questioned Costs: NoneHow the questioned costs were computed: N/ACompliance Requirements: Activities Allowed or Unallowed and Allowable Costs, Cost PrinciplesCondition: Out of a sample of 30 payroll transactions there were a total of 4 where the number of hours on the timesheet for the program, was not the amount that was allocated to the grant in the general ledger.Criteria: 2 CFR 200.430(i) states that ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: Be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated;?.Cause: The Organization does not have the proper review process in place to ensure salaries and wages allocated to grants agree to employee timesheets.Effect: Without proper reconciliation between the number of hours coded to grants on the timesheets to the allocation to the grants in the general ledger, it is possible that grants could be over or undercharged.Recommendation: We recommend that a comparison of time charged to grants on the timesheet to the amount charged to the grants in the general ledger be performed prior to payroll being processed to ensure grants are charged for the correct amount of payroll expenses.View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Wabanaki Public Health & Wellness has transitioned to an allocation-based payroll in the summer of FY 2022. This change was determined the best practice for the organization to help set standards for forthcoming periods. The payroll process is timely and consistent with the allocation base. Staff will maintain clocking hours for time worked, after each quarter a review of actual time spent on grants is compared to the allocated time for each grant. These times studies will the determine the reconciling JE, if any, will be processed to show the actual amounts due for the grants.The time studies will effectively assist in the allocation for the next quarter to determine how each staff member is allocated for payroll. Each WPHW staff member will receive a certification letter for them to review and sign to verify the hours in which they have worked. These certification letters will be built by the Senior Accountant that oversees the payroll entry process. The Director of Finance will have a review process to verify that all staff members have had a full-time study review and that certification letter are correct before staff receive them and the Financial Quality and Compliance Manager will review entire process each quarter. Through the multi-step review the overall payroll allocation and expenditure process will be more defined and follows the internal control processes.Person(s) Responsible: Beth McLeanTiming for Implementation: Summer 2022- Spring 2023
The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332.Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must:a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes:1. Federal award identification;2. All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federalstatutes, regulations and the terms and conditions of the Federal award;3. Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet itsown responsibility to the Federal awarding agency including identification of any required financial and performance reports.4.(i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government.If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient,which is either:1. The negotiated indirect cost rate between the pass-through entity and the subrecipient;2. The de minimis indirect cost rate;(ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approvedrate.5. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records andfinancial statements as necessary for the pass-through entity to meet the requirements of this part; and6. Appropriate terms and conditions concerning closeout of the subaward.b. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward forpurposes of determining the appropriate subrecipient monitoring.c. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208.d. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance withFederal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.Pass- through entity monitoring of the subrecipient must include:1. Reviewing financial and performance reports required by the pass-through entity.2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federalaward provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmationfrom the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particularsubaward.3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient fromthe pass-through entity as required by ? 200.521.4. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible forresolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and hasnot otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity mayrely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make managementdecisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate theresponsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage riskthrough ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward.e. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for thepass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals:1. Providing subrecipients with training and technical assistance on program-related matters; and2. Performing on-site reviews of the subrecipient's program operations;3. Arranging for agreed-upon-procedures engagements as described in ? 200.425.f. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awardsexpended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.g. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitateadjustments to the pass-through entity's own records.h. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations.Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements.Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance.Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2021-005Repeat Finding: NoType of Finding: Material Weakness in Internal Control and Material NoncomplianceDescription: Subrecipient Monitoring and ManagementMajor Programs: AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Awards (DHHS) ? Award numbers: 6NU38OT00257-03-06and 5NU38OT000257-04-00Questioned Costs: NoneHow the questioned costs were computed: N/ACompliance Requirement: Subrecipient MonitoringCondition: The Organization did not comply with any of the subrecipient monitoring and management requirements in accordance with 2 CFR Part 200.332.Criteria: The subrecipient monitoring and management requirements that are codified in 2 CFR Part 200.332 requires the pass-through entity must:a. Ensure that every subaward is clearly identified to the subrecipient as a subaward and includes:1. Federal award identification;2. All requirements imposed by the pass-through entity on the subrecipient so that the Federal award is used in accordance with Federalstatutes, regulations and the terms and conditions of the Federal award;3. Any additional requirements that the pass-through entity imposes on the subrecipient in order for the pass-through entity to meet itsown responsibility to the Federal awarding agency including identification of any required financial and performance reports.4.(i) An approved federally recognized indirect cost rate negotiated between the subrecipient and the Federal Government.If no approved rate exists, the pass-through entity must determine the appropriate rate in collaboration with the subrecipient,which is either:1. The negotiated indirect cost rate between the pass-through entity and the subrecipient;2. The de minimis indirect cost rate;(ii) The pass-through entity must not require use of a de minimis indirect cost rate if the subrecipient has a Federally approvedrate.5. A requirement that the subrecipient permit the pass-through entity and auditors to have access to the subrecipient?s records andfinancial statements as necessary for the pass-through entity to meet the requirements of this part; and6. Appropriate terms and conditions concerning closeout of the subaward.b. Evaluate each subrecipient?s risk of noncompliance with Federal statutes, regulations, and the terms and conditions of the subaward forpurposes of determining the appropriate subrecipient monitoring.c. Consider imposing specific subaward conditions upon a subrecipient if appropriate as described in ? 200.208.d. Monitor the activities of the subrecipient as necessary to ensure that the subaward is used for authorized purposes, in compliance withFederal statutes, regulations, and the terms and conditions of the subaward; and that subaward performance goals are achieved.Pass- through entity monitoring of the subrecipient must include:1. Reviewing financial and performance reports required by the pass-through entity.2. Following-up and ensuring that the subrecipient takes timely and appropriate action on all deficiencies pertaining to the Federalaward provided to the subrecipient from the pass-through entity detected through audits, on-site reviews, and written confirmationfrom the subrecipient, highlighting the status of actions planned or taken to address Single Audit findings related to the particularsubaward.3. Issuing a management decision for applicable audit findings pertaining only to the Federal award provided to the subrecipient fromthe pass-through entity as required by ? 200.521.4. The pass-through entity is responsible for resolving audit findings specifically related to the subaward and not responsible forresolving crosscutting findings. If a subrecipient has a current Single Audit report posted in the Federal Audit Clearinghouse and hasnot otherwise been excluded from receipt of Federal funding (e.g., has been debarred or suspended), the pass-through entity mayrely on the subrecipient's cognizant audit agency or cognizant oversight agency to perform audit follow-up and make managementdecisions related to cross-cutting findings in accordance with section ? 200.513(a)(3)(vii). Such reliance does not eliminate theresponsibility of the pass-through entity to issue subawards that conform to agency and award-specific requirements, to manage riskthrough ongoing subaward monitoring, and to monitor the status of the findings that are specifically related to the subaward.e. Depending upon the pass-through entity's assessment of risk posed by the subrecipient, the following monitoring tools may be useful for thepass-through entity to ensure proper accountability and compliance with program requirements and achievement of performance goals:1. Providing subrecipients with training and technical assistance on program-related matters; and2. Performing on-site reviews of the subrecipient's program operations;3. Arranging for agreed-upon-procedures engagements as described in ? 200.425.f. Verify that every subrecipient is audited as required by Subpart F of this part when it is expected that the subrecipient's Federal awardsexpended during the respective fiscal year equaled or exceeded the threshold set forth in ? 200.501.g. Consider whether the results of the subrecipient's audits, on-site reviews, or other monitoring indicate conditions that necessitateadjustments to the pass-through entity's own records.h. Consider taking enforcement action against noncompliant subrecipients as described in ? 200.339 of this part and in program regulations.Cause: The Organization?s management was not aware of the subrecipient monitoring and management requirements.Effect: The Organization was not in compliance with any of the subrecipient monitoring and management requirements, resulting in a material noncompliance and a material weakness in internal controls over compliance.Recommendation: We recommend the Organization implement systems and procedures to ensure compliance with the subrecipient monitoring and management compliance requirements.View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Wabanaki Public Health & Wellness followed sections of the subrecipient monitoring for requirements of documentation and follow through, however there were areas in which the audit team brough forth to light that needed some enhancing for procedures. WPHW will follow through with full review of the OMB standards for the subrecipient monitoring and build a check list to determine that each required section/item is followed throughout the period of award.The WPHW team, which includes, the Director of Finance, Financial Quality and Compliance Manager, and the Contract Specialist will be working together to build the required list and procedure and reviewing the checklist for when the award is first presented to allow both parties, (subawardee and WPHW) to understand the requirements for the award.Throughout the award period WPHW will maintain required documentation following the CFR 200.332 guidelines. The Financial Quality and Compliance Manager will review processes through the periodic review of all awards to verify that monitoring has been completed at the deemed timeframe and all parties involved are maintaining the set forth requirements of the award.Person(s) Responsible: Beth McLeanTiming for Implementation: Spring 2023
The Organization did not submit the 2020 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner.Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period.Cause: The Organization?s 2020 audit was not completed prior to the due date.Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance.Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2021-006Repeat Finding: NoType of Finding: Significant Deficiency in Internal Control and Nonmaterial NoncomplianceDescription: Data Collection Form Late FilingMajor Programs: AL#93.243 - Substance Abuse and Mental Health Services ? Direct Award (DHHS) ? Award numbers: 6H79SM083569-01M002, 6H79SPO81724-02M003, 5H79SP081724-03, 5H79SM082160-03M001, 5H79SM082160-03M002, 6H79SP082229-01M001, 5H79SM080189-02, 5H79SM080189-03AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct Award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00Questioned Costs: NoneHow the questioned costs were computed: N/ACompliance Requirement: Reporting RequirementCondition: The Organization did not submit the 2020 data collection form and reporting package to the Federal Audit Clearinghouse in a timely manner.Criteria: The Report Submission that is codified in 2 CFR Part 200.512 requires the auditee must submit the applicable data elements of the data collection form to the Federal Audit Clearinghouse within the earlier of 30 calendar days after receipt of the auditor?s report or nine months after the end of the audit period.Cause: The Organization?s 2020 audit was not completed prior to the due date.Effect: The Organization was not in compliance with audit submission requirements, resulting in a non-material noncompliance and significant deficiency in internal controls over compliance.Recommendation: We recommend the Organization implement systems and procedures to ensure timely completion of its audit and submission of the audit package to the Federal Audit Clearinghouse.View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Wabanaki Public Health & Wellness is committed to having our Single audits completed in time for submission to the clearing house within the appropriate time frame.We acquired WIPFLI to preform our FY 2021 audit as soon as we were informed by our previous auditor that they indeed were not going to be able to complete the audit in which we were under contract for them to do. WPHW has obtained WIPFLI for the next five years and will schedule our audit as early in the season as possible. Wabanaki Public Health & Wellness will be prepared to provide all information that is requested prior to the auditors being within our offices by the designated date in which the items are requested. During the period in which the auditors are within house and the weeks following the Director of Finance and the Financial Quality and Compliance Manager will be available to answer any questions, provide documentation, and details for all requirements for WIPFLI to complete the audit for submission to the clearing house.Person(s) Responsible: Beth McLeanTiming for Implementation: Summer 2022- Spring 2023
The Organization did not meet its financial reporting obligations under the grant during the year.Context: During the audit, it was determined the Organization did not submit any monthly fiscal reports during the year.Cause: The Organization was not aware of the requirement to submit monthly financial reports.Effect: The Organization was not in compliance with federal regulations and guidelines.Recommendation: Management should develop proper controls around federal grant related reporting requirements. We recommend management develop a due date list of all reports required to be filed for each grant and assign responsibility for review, approval and submission of the reports to the funding sources. The Organization should file the monthly reports in a timely manner and ensure amounts reported agree to supporting documentation and comply with federal compliance requirements.View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Show full finding ▾Hide full finding ▴Finding Number: 2021-007Repeat Finding: NoType of Finding: Material Weakness in Internal Control and Material NoncomplianceDescription: Submission of Monthly Fiscal ReportsMajor Programs: AL#93.772 - Tribal Public Health Capacity Building and Quality Improvement Umbrella Cooperative Agreement ? Direct award (DHHS) ? Award numbers: 6NU38OT00257-03-06, COVID-19 6NU38OT00257-03-06, 5NU38OT000257-04-00 and COVID-19 5NU38OT000257-04-00Questioned Costs: NoneHow the questioned costs were computed: N/ACompliance Requirements: Reporting RequirementCriteria: The Organization is required to submit monthly fiscal reports to the federal funding source beginning 60 days after the Notice of Awards are issued. These reports should be supported by appropriate documentation.Condition: The Organization did not meet its financial reporting obligations under the grant during the year.Context: During the audit, it was determined the Organization did not submit any monthly fiscal reports during the year.Cause: The Organization was not aware of the requirement to submit monthly financial reports.Effect: The Organization was not in compliance with federal regulations and guidelines.Recommendation: Management should develop proper controls around federal grant related reporting requirements. We recommend management develop a due date list of all reports required to be filed for each grant and assign responsibility for review, approval and submission of the reports to the funding sources. The Organization should file the monthly reports in a timely manner and ensure amounts reported agree to supporting documentation and comply with federal compliance requirements.View of Responsible Officials: Management agrees with the finding and has committed to a corrective action plan.
Wabanaki Public Health & Wellness has implemented new positions and transitions of staff on order to increase processes to fall within compliance of all requirements for grants. This includes the reporting aspect financially and programmatically. The Financial Quality and Compliance Manager will be in complete review to verify that all reporting is completed within the correct time frame for each grant. The Grants and Accounting teams will compile a comprehensive list of all grants and dates for all reporting. The Financial Quality and Compliance Manager will maintain the list, file financial reports, and review that program staff has submitted all required reports as needed.Person(s) Responsible: Beth McLeanTiming for Implementation: Spring 2023
FAC accepted this audit on June 2, 2022 — management decision was due December 2, 2022.
Information on the federal program
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Internal control over payroll compliance
FAC accepted this audit on January 17, 2021 — management decision was due July 17, 2021.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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