Great Lakes Inter-Tribal Council Inc.

Item 2024-002: Reporting [See table in report] Federal and state agencies: • 93.231 – U.S. Department of Health and Human Services • 445.566 – Wisconsin Department of Workforce Development • 435.65859 – Wisconsin Department of Health Services Pass-through entity: None Criteria: The Organization is required to comply with 2 CFR section 200.303 which requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing of reporting requirements, we noted that there was no documentation that reports were reviewed prior to submission to grantor. Cause: Staffing changes in the finance department. A review is performed, however this review is not documented due to the electronic filing of the reports. Due to these events, management has not documented review of the reports. Effect: Likelihood of inaccurate reporting is increased when reports are not thoroughly reviewed. Questioned costs: None Prevalence: The population of reports subject to reporting requirements included 24 reports for the programs referred to in this finding. For 9 of the 10 reports tested, the Organization did not have documentation showing the reports were reviewed. The sample size of 10 was determined using guidance in the American Institute of Certified Public Accountants (AICPA) Audit and Accounting Guide—Government Auditing Standards and Single Audits. Our sample was not a statistical sample. Repeat finding: Yes Recommendation: We recommend that the Organization review their processes to ensure review of all reports required are accurately reviewed and documented. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.

2024-003 Procurement, Suspension and Debarment Federal agency: U.S. Department of Health and Human Services Federal program: Epidemiology Program (ALN 93.231) Pass-through Entity: None Federal Award Year: Year ended September 30, 2024 Criteria: The Uniform Guidance stipulates that when a nonfederal entity enters into a contract or purchase with an entity (vendor or subrecipient), the nonfederal entity must verify the entity is not suspended or debarred from participation in federal programs/grants when entering into a covered transaction that is expected to equal or exceed $25,000. Condition: During our testing of suspension and debarment requirements, we noted that there was no documentation that the Organization verified that certain vendors were not suspended or debarred prior to entering into the covered transaction. We did not note any vendors in our sample that appeared at sam.gov as being precluded from participating in a federally funded procurement. Cause: The Organization does not always maintain documentation that the verification was performed. Effect: The Organizations internal controls related to suspension and debarment were not supported in all instances to show that they were performed. Questioned costs: None Prevalence: The population of covered transactions equal to or greater than $25,000 included 3 vendors for the program referred to in this finding. For 2 of the 3 vendors tested, the Organization did not have documentation showing that they verified the status of the vendor prior to entering into a covered transaction. The sample size of 3 was determined using guidance in the American Institute of Certified Public Accountants Audit and Accounting Guide – Government Auditing Standards and Single Audits. Repeat finding: No Recommendation: We recommend the Organization verify status of all vendors prior to entering into a covered transaction and maintain supporting documentation.

Item 2023-003: Reporting [See table in report] Federal and state agencies: • 93.231, 93.479, 93.772 – U.S. Department of Health and Human Services • 435.566 – Wisconsin Department of Health Services • 445.65859 – Wisconsin Department of Workforce Development Pass-through entity: None Criteria: The Organization is required to comply with 2 CFR section 200.303 which requires that non-federal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the non-federal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. Condition: During our testing of reporting requirements, we noted that there was no documentation that reports were reviewed prior to submission to grantor. Cause: Staffing changes in the finance department. A review is performed, however this review is not documented due to the electronic filing of the reports. Due to these events, management has not documented review of the reports. Effect: Likelihood of inaccurate reporting is increased when reports are not thoroughly reviewed. Questioned costs: None Prevalence: The population of reports subject to reporting requirements included 28 reports. For 13 of the 13 reports tested, the Organization did not have documentation showing the reports were reviewed. The sample size of 13 was determined using guidance in the American Institute of Certified Public Accountants (AICPA) Audit and Accounting Guide—Government Auditing Standards and Single Audits. Our sample was not a statistical sample. Repeat finding: No Recommendation: We recommend that the Organization review their processes to ensure review of all reports required are accurately reviewed and documented. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.

Item 2022-001: Reporting Federal program: ALN 93.479 ? Good Health and Wellness in Indian Country Federal award grant numbers and years: 6 NU58DP006720-03-03 ? 2022 Federal agency: U.S. Department of Health and Human Services?Center for Disease Control and Prevention Pass-through entity: None Criteria: The Organization is required to comply with 2 CFR Subpart D 200.300 (b) which indicates that a non-Federal entity is responsible for complying with Federal Funding Accountability and Transparency Act (FFATA). FFATA requires prime grant recipients to file a FFATA sub-award report by the end of the month following the month in which the prime recipient awards any sub-grant greater than or equal to $30,000. Condition: During our testing of the reporting requirements, we noted subawards to seven subrecipients where the FFATA sub-award report was not filed timely. The amount of subawards required to be reported were $874,045. Subsequent to year end, the Organization prepared and submitted the FFATA sub-award reports. Cause: The Organization was unaware of the FFATA reporting requirement as the requirement was not explicit in the grant agreement. Effect: Potential loss or suspension of grant funding. Questioned costs: None Prevalence: The population of first-tier subwards subject to reporting requirements included seven subawards. The sample size of seven was determined using guidance in the American Institute of Certified Public Accountants (AICPA) Audit and Accounting Guide?Government Auditing Standards and Single Audits. Our sample was not a statistical sample. Recommendation: We recommend the Organization implement procedures to comply with the requirements of FFATA. Views of responsible officials of the auditee: We agree with the above finding and our response is included in the corrective action plan.