GRAND PORTAGE RESERVATION TRIBAL COUNCILTribal Government

Item 2023-003: Suspension and Debarment Assistance Listing Number: 15.022 – Tribal Self-governance 21.027 – Coronavirus State and Local Fiscal Recovery Funds Federal award grant number: 15.022 – OSGT406 21.027 – Not available Federal agency: • 15 – U.S. Department of Interior • 21 – U.S. Department of Treasury Award year: 15.022 – 2023 21.027 – 2023 Pass-through entity: None Criteria: The Band is required to verify contractors are not suspended or debarred for all contracts for goods and services that equal or exceed $25,000 and are funded by federal awards (2 CFR part 180.995). This verification may be accomplished by 1) searching the System for Award Management (SAM), 2) collecting a certification from the entity and 3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Procurement records should document the method used to comply with the requirements of suspension and debarment. Condition: During our testing of suspension and debarment requirements, we noted there was no documentation indicating the Band verified that contractors were not suspended or debarred. Cause: The exception noted above was due to a breakdown in the Band’s procedures to ensure that all contracts for goods and services entered into have suspension and debarment verified. Effect: The Band did not consistently follow its procedures designed to verify vendors are not suspended or debarred prior to the awarding the contract. During the audit, there were no vendors that were suspended or debarred for our samples tested. Questioned costs: None Context: The population subject to suspension and debarment requirements totaled 8 contracts. The sample size of 6 was determined using the guidance in the AICPA Audit and Accounting Guide – Government Auditing Standards and Single Audits. We noted 6 instances in our sample size of 6 where there was no documentation indicating the Band verified the contractor was not suspended or debarred. Repeat finding: No Recommendation: The Band should continue to improve its procedures to ensure that all vendors are properly verified prior to the awarding of contracts or purchase orders. It is also recommended that evidence related to the procedures performed to verify vendors are not suspended or debarred is maintained with the individual contracts and purchase orders. Views of responsible officials of the auditee: The Band agrees with the above finding and its response is included in the corrective action plan.

2019-002 U.S. Department of the Health and Human Services CFDA Number: 93.600 Head Start Internal Control: Significant Deficiency Compliance: Special Tests Criteria ? 45 CFR sections 1303.46(b)(4) and 47(c) requires, ?A Head Start Agency that uses Head Start funds to purchase or renovate (major) a modular unit must post a Notice of Federal Interest which includes the required language content in clearly visible locations on the exterior and the interior of the modular unit.? Condition ? During our audit we inquired if the required language was posted in a clearly visible location and this requirement was not met. This is not a repeat finding. Cause ? The Council was not aware of the specific requirement to post a Notice of Federal Interest. Effect - The Council has a significant deficiency in internal control over special tests and is not in compliance with the requirement. Recommendation ? The Council should post the require language when using Head Start funds for any construction project. View of Responsible Officials ? We agree with the auditor?s finding and we will implement a corrective action plan to ensure Notices of Federal Interests are properly posted in the future.

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