EIN: 382316072
UEI: HCHWNDWBGWE5
Audited by: RSM US LLP
Oversight agency: 15 [Department of the Interior]
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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 June 29, 2026. 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 December 29, 2026 (116 days from today).
What is a management decision? →The Band did not have documentation to support that character investigations were performed on employees that have regular contact with, or control over Indian children for all employees subject to character investigations. Cause: Character investigations were not conducted in accordance with 42 CFR 136.406. Effect: The Band is not in compliance with special tests and provisions requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: None Context: The population of employees subject to character investigations included 19 employees. The Band did not have documentation to support that character investigations were performed on employees that have regular contact with, or control over Indian children for all employees subject to character investigations. Repeat finding: Yes Recommendation: We recommend that all individuals with access to vulnerable populations, including contractors and volunteers are subjected to the required background investigations and that documentation that these investigations are performed are retained in the records of the Band. Views of responsible officials: The Band agrees with the above finding and its response is included in the corrective action plan.
Show full finding ▾Hide full finding ▴2025-002 Special Tests and Provisions - Character Investigations Federal agency: U.S. Department of Health and Human Services Federal program: Tribal Self-Governance Program: IHS Compacts/Funding Agreements (ALN 93.210). Pass-through Entity: None Federal Award Year: Year ended September 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance; Adverse Opinion on Compliance Criteria: The Indian Child Protection and Family Violence Protection Act (25 USC 3207) requires that all Indian tribes or tribal organizations receiving funds under the authority of the Indian Self Determination and Education Assistance Act or Tribally Controlled Schools Act of 1988 must conduct a background investigation for individuals whose duties and responsibilities would allow them regular contact with or control over Indian children. The Act further states that the tribe or tribal organization can employ only individuals who meet standards of character that are no less stringent than those prescribed by the regulations, which are outlined in 42 CFR 136.405, and only after an individual has been the subject of a satisfactory background investigation as described in 42 CFR 136.406. Condition: The Band did not have documentation to support that character investigations were performed on employees that have regular contact with, or control over Indian children for all employees subject to character investigations. Cause: Character investigations were not conducted in accordance with 42 CFR 136.406. Effect: The Band is not in compliance with special tests and provisions requirements of the Uniform Guidance. The potential effect is submitting unallowable costs, or loss of federal funding. Questioned costs: None Context: The population of employees subject to character investigations included 19 employees. The Band did not have documentation to support that character investigations were performed on employees that have regular contact with, or control over Indian children for all employees subject to character investigations. Repeat finding: Yes Recommendation: We recommend that all individuals with access to vulnerable populations, including contractors and volunteers are subjected to the required background investigations and that documentation that these investigations are performed are retained in the records of the Band. Views of responsible officials: The Band agrees with the above finding and its response is included in the corrective action plan.
The Band has developed and initiated a procedure to subject all employees with access to vulnerable populations to be subjected to background investigations. The Band has instituted these procedures; however, they were initiated post the September 30, 2025 financial statements. OMB will continue to monitor this process in a quarterly review with Human Resources.
2024-002
During our testing of cash management requirements, we noted that a review of the reimbursement requests sampled for testing was not performed prior to submission. Cause: The Band does not have a procedure for a review of the reimbursement requests prior to submission for the identified programs. Currently, the same employee prepares and submits the reimbursement requests. Effect: Likelihood of inaccurate reimbursement requests is increased when they are not thoroughly reviewed. Questioned costs: None Context: • ALN 10.912 – The population of reimbursement requests subject to cash management requirements included one request. Our sample included one reimbursement request which did not have documentation showing it was reviewed. • ALN 11.463 – The population of reimbursement requests subject to cash management requirements included eight requests. Our sample included two reimbursement requests which did not have documentation showing they were reviewed. Repeat finding: No Recommendation: We recommend that the Band review their processes to ensure all reimbursement requests have review a process documented indicating that a secondary review was performed prior to submission. Views of responsible officials: The Band agrees with the above finding and its response is included in the corrective action plan.
Show full finding ▾Hide full finding ▴Item 2025-003: Material Weakness in Internal Control Over Compliance - Cash Management Federal agency: • U.S. Department of Agriculture • U.S. Department of Commerce Federal program: • Environmental Quality Incentives Program (ALN 10.912) • Habitat Conservation (ALN 11.463) Pass-through Entity: None Federal Award Year: Year ended September 30, 2025 Type of Finding: Material Weakness in Internal Control over Compliance Criteria: The Uniform Guidance (2 CFR 200.303) requires nonfederal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to review reimbursement requests. Condition: During our testing of cash management requirements, we noted that a review of the reimbursement requests sampled for testing was not performed prior to submission. Cause: The Band does not have a procedure for a review of the reimbursement requests prior to submission for the identified programs. Currently, the same employee prepares and submits the reimbursement requests. Effect: Likelihood of inaccurate reimbursement requests is increased when they are not thoroughly reviewed. Questioned costs: None Context: • ALN 10.912 – The population of reimbursement requests subject to cash management requirements included one request. Our sample included one reimbursement request which did not have documentation showing it was reviewed. • ALN 11.463 – The population of reimbursement requests subject to cash management requirements included eight requests. Our sample included two reimbursement requests which did not have documentation showing they were reviewed. Repeat finding: No Recommendation: We recommend that the Band review their processes to ensure all reimbursement requests have review a process documented indicating that a secondary review was performed prior to submission. Views of responsible officials: The Band agrees with the above finding and its response is included in the corrective action plan.
The Band has added additional staff within its OMB to increase their ability to perform more thorough seperation of duties and more accurately process these submissions. A complete internal review of the Band's OMB policies and procedures is scheduled and expected completion is December 31, 2026.
FAC accepted this audit on December 17, 2025 — management decision was due June 17, 2026.
2023-003
FAC accepted this audit on June 5, 2025 — management decision was due December 5, 2025.
FAC accepted this audit on June 28, 2023 — management decision was due December 28, 2023.
FAC accepted this audit on June 28, 2022 — management decision was due December 28, 2022.
FAC accepted this audit on December 28, 2021 — management decision was due June 28, 2022.
FAC accepted this audit on October 27, 2020 — management decision was due April 27, 2021.
One contract was tested. This contract did not include a provision that the contractor or subcontractor comply with the Wage Rate Requirements. Cause: Prevailing wage rate clauses were not included in the Band?s standard contract or subcontract forms. Effect: Prevailing wage rate clauses were not included in the contract or subcontract as a control to ensure the Band was in compliance with the Wage Rate Requirements. During audit fieldwork, the Band obtained the required certified payrolls to ensure that laborers were paid wages in accordance with the Davis-Bacon Act. Questioned costs: None Prevalence: The population of contracts subject to Special Tests and Provisions ? Wage Rate Requirements included one contract. The sample size of one was determined using the guidance in the AICPA Audit and Accounting Guide ? Government Auditing Standards and Single Audits. Expenditures under the contracts with the missing provisions totaled $325,000. This appears to be an isolated instance to the Highway Planning and Construction program as the Band has a process in place to obtain certified payrolls. Repeat finding: No Recommendation: The Band should perform a review of all contracts to ensure appropriate provisions are included.
Show full finding ▾Hide full finding ▴Item 2019-001: Special Tests and Provisions ? Wage Rate Requirements CFDA title and number: Highway Planning and Construction, CFDA 20.205 Federal award grant number: A12AV01107i Federal agency: Department of Transportation Pass-through entity: None Criteria: The Band is required to follow the wage rate requirements of 2 CFR Part 200, Appendix XI Compliance Supplement, Part 4-20.001 which states: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (40 USC 3141-3144, 3146, and 3147). Non-federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (?___.36(i)(5)); OMB Circular A-110 (2 CFR part 215, Appendix A, Contract Provisions); 2 CFR part 176, subpart C; and 2 CFR section 200.326). Condition: One contract was tested. This contract did not include a provision that the contractor or subcontractor comply with the Wage Rate Requirements. Cause: Prevailing wage rate clauses were not included in the Band?s standard contract or subcontract forms. Effect: Prevailing wage rate clauses were not included in the contract or subcontract as a control to ensure the Band was in compliance with the Wage Rate Requirements. During audit fieldwork, the Band obtained the required certified payrolls to ensure that laborers were paid wages in accordance with the Davis-Bacon Act. Questioned costs: None Prevalence: The population of contracts subject to Special Tests and Provisions ? Wage Rate Requirements included one contract. The sample size of one was determined using the guidance in the AICPA Audit and Accounting Guide ? Government Auditing Standards and Single Audits. Expenditures under the contracts with the missing provisions totaled $325,000. This appears to be an isolated instance to the Highway Planning and Construction program as the Band has a process in place to obtain certified payrolls. Repeat finding: No Recommendation: The Band should perform a review of all contracts to ensure appropriate provisions are included.
Identifying Number: 2019-001 Finding: The Band is required to follow the wage rate requirements of 2 CFR Part 200, Appendix XI Compliance Supplement, Part 4-20.001. For one contract tested under the Highway Planning and Construction program, CFDA 20.205, the contract did not include a provision that the contractor or subcontractor comply with the Wage Rate Requirements. Corrective Actions Taken or Planned: Purchasing has modified GTB?s Professional Services Contract (PSC) to include the language in agreement with the Davis-Bacon Act as follows: I,__________, agree to provide the above services and/or materials to the Grand Traverse Band of Ottawa and Chippewa Indians (Tribe) as an independent contractor. As an independent contractor, I am not representing the Tribe as an employee and I am doing this on my own personal time, and I agree to hold the Tribe harmless for any liabilities that may be incurred providing the above services and/or materials. I acquiesce to the jurisdiction of the Tribe?s court system (Tribal Judiciary) for purpose of resolving any issues related to this contract. I understand that payment requests for terms outside the contract limits will not be honored without written pre-approval. I understand that this service contract may be terminated at the convenience of either party by giving ten (10) business days notice, in writing, to terminate this contract. Termination costs for damages shall be the current billable hours under the contract at the time of termination. I must submit weekly wage records due to contract being over $2,000 to show Davis-Bacon wages were paid. Contact person(s) responsible for corrective action: Rob Kabfleisch, Land Acquisition and Road Management, (231) 534-7716 Anticipated completion date: October 15, 2020.
FAC accepted this audit on June 26, 2019 — management decision was due December 26, 2019.
FAC accepted this audit on June 28, 2018 — management decision was due December 28, 2018.
FAC accepted this audit on June 29, 2017 — management decision was due December 29, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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