STANDING ROCK SIOUX TRIBETribal Government

AL Numbers: 93.568 Name of Federal Program or Cluster: Low-Income Home Energy Assistance Program (LIHEAP) and COVID-19 LIHEAP Award Number: 23PANDLIEA, 23PANDLIEE, 23 PANDLIEI Award Year: 2023 Criteria – In accordance with the Tribe’s grant award requirements and the Uniform Guidance 2 CFR 200.305, the timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements for project costs. Condition and context – The LIHEAP program had a significant amount of unearned revenue (i.e., unspent advanced grant funds) as of September 30, 2023, which was not expended within a reasonable amount of time. Cause – Lack of sufficient oversight on cash management requirements may have led to this finding. Questioned costs – There are no questioned costs to report related to this finding as the advanced funds were unexpended. Effect – Failure to adhere to these requirements can potentially cause the suspension of grant funds. Repeat finding – This is a repeat finding and was reported in the prior year as finding 2022-010. Recommendation – LIHEAP program should implement a supervisory review process over the cash management and drawdown process to ensure compliance with the requirements. Views of responsible officials and planned corrective actions – The Program will work with the finance department to better match advanced drawdowns to the actual disbursement for the period. This will be done by comparing the funds on hand (bank balance) to program costs. If sufficient funds are on hand a drawdown request will not be made.

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

AL Numbers: 93.441 Name of Federal Program or Cluster: Indian Self-Determination – Indian Health Services (IHS) and COVID-19 IHS Award Number: HHS-I-241-2021-0002 Award Year: 2023 Criteria – In accordance with the Tribe’s grant award requirements and the Uniform Guidance 2 CFR 200.303, the Tribe must have internal controls in place for documenting and verifying eligibility to ensure compliance with federal requirements. Condition and context – Of the 65 participants in the Tribe’s treatment program during fiscal year 2023, we used a random sample selection methodology to select and test 8 files for eligibility. We noted 4 participant files were missing the program’s eligibility intake form, which documents the participant’s eligibility. Of the 4 files, we noted one file was missing proof of Tribal enrollment. Subsequent to our testing, the program was able to provide evidence of eligibility for each file tested. Cause – Turnover and vacancies in the program may have contributed to insufficient internal controls over eligibility. Questioned costs – As a control finding, there are no questioned costs applicable to this finding. Effect – It is possible that individuals not eligible to receive services may have received services. Repeat finding – This is not a repeat finding for this program. Recommendation – The program should reexamine processes and controls over participant eligibility and implement a supervisory review process to establish strong internal controls over compliance. Views of responsible officials and planned corrective actions – ALN 93.441 (participant eligibility): The Program was able to locate the missing eligibility documents which were subsequently provided to the auditor. The Program will ensure that such documentation is maintained in participant files in the future.

AL Numbers: 10.760, 93.575 Name of Federal Program or Cluster: Water and Waste Disposal Systems for Rural Communities, Xhild Care and Development Block Grant – CCDF Cluster and COVID-19 CCDF Cluster Award Number: Multiple, 21PANDCCDF,22PANDCCDD, 23PANDCCDD Award Year: 2021, 2022, 2023 Criteria – In accordance with the Tribe’s grant award requirements and the Uniform Guidance 2 CFR 200.306, the Tribe must have internal controls over and ensure compliance with any federal cost-sharing/matching and earmarking requirements. Additionally, for the CCDF Cluster program, Tribal lead agencies must spend at least 12% of the total CCDF program expenditures on quality improvement activities. Tribal lead agencies must spend 3% of the 12% on activities to increase the quality of care for infants and toddlers. Condition and context – We noted the following for each program: ALN 10.760 – The program was unable to provide us evidence of monitoring of or compliance with the Tribe’s cost-sharing contributions for the program’s operations. ALN 93.575 – The program did not meet the minimum threshold of 12% on quality improvement activities during the year ended September 30, 2023. Additionally, the program did not monitor expenditures against the 3% threshold on quality improvement activities to increase the quality of care for infants and toddlers. Cause – Inadequate internal controls over cost-sharing and earmarking requirements may have led to this finding. Questioned costs – There are no questioned costs to report related to this finding. Effect – The Tribe could be subject to repayment of funds for not meeting cost-sharing and earmarking requirements. Repeat finding – This is a repeat finding for the CCDF Cluster program and was reported in the prior year as finding 2022-004. Recommendation – The programs should establish and implement internal controls over cost-sharing and earmarking requirements and implement a supervisory review over these requirements. Views of responsible officials and planned corrective actions – ALN 10.760: The Program will work with the Finance Department to thoroughly review the grant award documentation for any cost-sharing contribution requirements. If identified, this requirement will be marked on the intake form and tracked by the Finance Department. ALN 93.575: The Program satisfied these matching requirements in fiscal year 2024. In future awards, the Program will ensure that the match requirements are met in the appropriate period of performance.

AL Numbers: 93.568 Name of Federal Program or Cluster: Low-Income Home Energy Assistance Program (LIHEAP) and COVID-19 LIHEAP Award Number: 23PANDLIEA, 23PANDLIEE, 23 PANDLIEI Award Year: 2022, 2023 Criteria – At least 90 percent of the LIHEAP grant funds must be obligated in the first federal fiscal year in which they are awarded. Condition and context – The Tribe was unable to provide sufficient evidence that 90% of the award received was obligated. Cause – Lack of sufficient oversight may have led to period of performance grant requirements not being consistently followed. Questioned costs – There are no questioned costs to report related to this finding. Effect – The Tribe could be subject to repayment of funds for the unobligated balance over the 10% threshold. Repeat finding – This is a repeat finding and was reported in the prior year as finding 2022-005. Recommendation – LIHEAP program should implement a supervisory review process over the project and budget periods to establish strong internal controls over compliance. Views of responsible officials and planned corrective actions – ALN 93.568: The LIHEAP program reports were submitted late, and the obligations were reported on the Federal Financial Reports and Carryover/Allotment Report. The LIHEAP carryover/allotment report was late due to staff turnover.

AL Numbers: 15.518, 93.445 Name of Federal Program or Cluster: Garrison Diversion Unit, Indian Health Service Sanitation Facilities Construction Program Award Number: Multiple Award Year: 2023 Criteria – The Tribe’s procurement policies and procedures require at least three written bids or quotes for purchases over $3,000. Additionally, federal regulations require that grantees have controls in place to verify that vendors are not suspended or debarred prior to entering into contracts for goods or services exceeding $25,000. Condition and context – We noted the following for each program: ALN 15.518 – Of the 50 vendors for which the Tribe had total payments over $3,000 during fiscal year 2023, we used a random sample selection methodology to select and test 7 vendor files for procurement testing. We noted 5 vendor files had no evidence that three written bids or quotes were obtained. Of the 19 vendors for which the Tribe had vendor contracts over $25,000, we used a random sample selection methodology to select and test 5 vendor files for suspension and debarment testing. We noted 2 vendor files had no evidence that a suspension and debarment verification was performed. ALN 93.445 – Of the 6 vendors for which the Tribe had total payments over $3,000 during fiscal year 2023, we used a random sample selection methodology to select and test 4 vendor files for procurement testing. We noted 2 vendor files had no evidence that three written bids or quotes were obtained. Of the 5 vendors for which the Tribe had vendor contracts over $25,000, we used a random sample selection methodology to select and test 5 vendor files for suspension and debarment testing. We noted 1 vendor file had no evidence that a suspension and debarment verification was performed. Based on our verification on www.sam.gov, the vendors we tested were not suspended or debarred. Cause – Lack of sufficient oversight may have led to procurement policies not being followed and suspension and debarment checks not being performed in a consistent manner. Questioned costs – We are unable to determine if the Tribe could have obtained a better price for the procurement that was not made through a full and open competitive process, and as such we cannot determine if any overpayment may have occurred. Therefore, questioned costs are unknown. Effect – The Tribe could be subject to questioned costs or other sanctions from funding agencies if they determine that the programs did not follow its procurement policies or that the vendors paid with federal funds are later found to be suspended or debarred. Repeat finding – This is a repeat finding and was reported in the prior year as findings 2022-006 and 2022-007. Recommendation – The programs should implement a supervisory review process over the procurement process to ensure the Tribe’s policies are followed and documentation is maintained. Established procurement policies and procedures should include suspension and debarment requirements and training should be provided for all personnel involved in procurement. Views of responsible officials and planned corrective actions – ALN 15.518 and 93.445: Policies and procedures will be enforced requiring that the Tribe’s procurement policies and procedures are followed, including evidencing suspension and debarment verification.

AL Numbers: 10.760, 93.568 Name of Federal Program or Cluster: Water and Waste Disposal Systems for Rural Communities, Low-Income Home Energy Assistance Program (LIHEAP) and COVID-19 LIHEAP Award Number: Multiple, 23PANDLIEA, 23PANDLIEE, 23 PANDLIEI Award Year: 2022, 2023 Criteria – Federal regulations and grant and contract conditions require that financial and programmatic reports are filed in a timely manner and should be supported by accurate supporting documentation, such as general ledger or other reports. Condition and context – We noted the following for each program: ALN 10.760 – The program’s RD442-2 Statement of Budget Income and Equity report and Form RD 442-2 Balance Sheet report were not submitted for fiscal year 2023. ALN 93.568 – The annual financial and performance reports for the LIHEAP program were not submitted for fiscal year 2023. Cause – Inadequate internal controls over reporting requirements may have led to this finding. Questioned costs – There are no questioned costs to report. Effect – Federal agencies may impose sanctions due to noncompliance with reporting requirements. Repeat finding – This is a repeat finding for LIHEAP ALN 93.568 and was reported in the prior year as finding 2022-008. Recommendation – The Tribe’s finance department and program director should establish a supervisory review to ensure all finance and programmatic reports are submitted to granting agencies. Views of responsible officials and planned corrective actions – The Tribe will develop a quarterly, semi-annual, and annual checklist with timelines to complete the federal financial reports to ensure timely submission.

AL Numbers: 93.441, 93.575 Name of Federal Program or Cluster: Indian Self-Determination – Indian Health Services (IHS) and COVID-19 IHS, Child Care and Development Block Grant – CCDF Cluster and COVID-19 CCDF Cluster Award Number: HHS-I-241-2021-0002, 21PANDCCDF, 22PANDCCDD, 23PANDCCDD Award Year: 2021, 2022, 2023 Criteria – ALN 93.441 – The Indian Child Protection and Family Violence Prevention Act, 25 USC 3207, requires tribes and tribal organizations that receive funds under the ISDEAA to conduct an investigation of the character of each individual who is employed or is being considered for employment in a position that involves regular contact with, or control over, Indian children (25 U.S.C. § 3207(c); 34 U.S.C. § 20351). Each Indian tribe or tribal organization that receives funding shall: 1) Conduct an investigation of the character of each individual who is employed, or is being considered for employment, by such tribe or tribal organization in a position that involves regular contact with, or control over, Indian children; and 2) Employ individuals in those positions only if the individuals meet standards of character no less stringent than those prescribed under subsection (a) of this section, as the Indian tribe or tribal organization shall establish. ALN 93.575 – As part of their CCDF plans, lead agencies must certify that procedures are in effect (e.g., monitoring and enforcement) to ensure that providers serving children who receive subsidies comply with all applicable health and safety requirements. Condition and context – ALN 93.441 – Of the 61 employees paid by the Tribe’s Indian Self-Determination program during fiscal year 2023 that would require character investigations, we used a random sample selection methodology to select and test 13 employee files for testing. We noted 5 employees files had insufficient evidence that character investigations were performed. Additionally for all 13 employee files reviewed, we noted there was no evidence of review or other internal controls over the results of the character investigations. ALN 93.575 – The Tribe’s CCDF plan document states that specific initial and ongoing training requirements are required of childcare providers. There was no evidence of training provided during fiscal year 2023. Cause – Inadequate internal controls over these special test requirements may have led to this finding. Questioned costs – There are no questioned costs to report related to this finding. Effect – Federal agencies may impose sanctions due to noncompliance with these requirements. Repeat finding – This is a repeat finding for the CCDF Cluster ALN 93.575 and was reported in the prior year as finding 2022-009. Recommendation – Human Resources should implement a supervisory review over character investigations for all employees that fall under ISDEAA requirements. Additionally, the CCDF program should implement a monitoring control to ensure ongoing training requirements and health and safety requirements for childcare providers are being met on an annual basis. Views of responsible officials and planned corrective actions – ALN 93.441: The Tribe’s HR Department will develop and implement policies and procedures requiring that character investigations be performed for all program personnel. In addition, notation of the appropriate independent verification will be clearly notated. ALN 93.575: The Program hired a Training Monitor. The Training Monitor is responsible for scheduling training and ensuring all providers are up to date on training that is required by the CCDF program. The documentation will be kept on file.

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