Turtle Mountain Band of Chippewa Indians

2021-005 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Program Information: See schedule of findings and questioned costs for chart/table Criteria ? A good system of internal accounting control contemplates an adequate system for ensuring that all reports are completed and submitted accurately and timely. Condition ? During the course of our engagement we noted that the controls surrounding the reporting function of this program were not operating effectively. There were instances in which the reports were not submitted and instances of reports being submitted with amounts not supported by the Department?s general ledger. Cause ? The Department does not have an internal control system designed to ensure all reports are being submitted by the required date and are submitted accurately. Effect ? The control deficiency could result in the Department?s reports within this program not being completed accurately and timely. Questioned Costs ? None reported. Context/Sampling ? Four of the four quarterly OIG Financial Progress Reports were selected for testing. Repeat Finding from Prior Year(s) ? Yes, prior year finding 2020-005. Recommendation ? Management should put procedures in place to ensure that all reports are submitted by the required date and are submitted with accurate information that is supported by the Department?s general ledger. Views of Responsible Officials ? Management of the Department is in agreement with the finding.

2021-006 Subrecipient Monitoring Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Program Information: See schedule of findings and questioned costs for chart/table Criteria ? A good system of internal controls includes monitoring of subsequent recipient activities ensuring they meet all requirements determined by the grant agreement. Condition ? We noted that the Department failed to provide sufficient oversight regarding the performance of single audits for subrecipients. Cause ? Procedures are not in place to ensure that the Department is maintaining adequate monitoring for each federal subrecipient. Effect ? Failure to maintain sufficient subrecipient monitoring may result in the wrongful use of federal funds and non-compliance with the provisions of applicable requirements. Questioned Costs ? None reported. Context/Sampling ? Four of the four subrecipients were selected for testing. Repeat Finding from Prior Year(s) ? No. Recommendation ? The Department should maintain adequate monitoring activities for each subrecipient and ensure that proper procedures are maintained relating to the expenditure of federal funds. Views of Responsible Officials ? Management of the Department is in agreement with the finding.

2021-007 Allowable Costs/Activities and Period of Performance Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Program Information: See schedule of findings and questioned costs for chart/table Criteria ? A good system of internal accounting control includes keeping accurate recording of expenditures in the correct period. Condition ? We noted that the Department failed to record expenditures in the appropriate period when the costs were incurred. Cause ? Procedures are not in place to ensure that the Department is recording expenditures in the appropriate period when the costs are incurred. There were eleven unallowed costs for expenditures that did not occur in the current year. Effect ? Failure to record expenditures in the correct period may result in the wrongful use of federal funds and non-compliance with the provisions of applicable requirements. Questioned Costs ? $3,407 of errors were noted out of $155,785 of items tested. Context/Sampling ? A nonstatistical sample of 60 transactions out of 1,048 total transactions were selected for testing, which accounted for $155,785 of $2,956,554 of federal program expenditures. Repeat Finding from Prior Year(s) ? No. Recommendation ? The Department should put procedures in place to ensure that all expenditures are recorded in the correct period. Views of Responsible Officials ? Management of the Department is in agreement with the finding.

2021-008 Allowable Costs/Activities Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Program Information: See schedule of findings and questioned costs for chart/table Criteria ? A good system of internal accounting control includes keeping accurate recording of expenditures in the correct period. Condition ? We noted that the Department failed to record expenditures in the appropriate period when the costs were incurred. Cause ? Procedures are not in place to ensure that the Department is recording expenditures in the appropriate period when the costs are incurred. There were eleven unallowed costs for expenditures that did not occur in the current year. Effect ? Failure to record expenditures in the correct period may result in the wrongful use of federal funds and non-compliance with the provisions of applicable requirements. Questioned Costs ? $677 of errors were noted out of $534,382 of items tested. Context/Sampling ? A nonstatistical sample of 60 transactions out of 678 total transactions were selected for testing, which accounted for $534,382 of $3,487,449 of federal program expenditures. Repeat Finding from Prior Year(s) ? Yes, prior year finding 2020-009. Recommendation ? The Department should put procedures in place to ensure that all expenditures are recorded in the correct period. Views of Responsible Officials ? Management of the Department is in agreement with the finding.

2021-009 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Program Information: See schedule of findings and questioned costs for chart/table Criteria ? A good system of internal accounting control contemplates an adequate system for ensuring that all reports are completed and submitted accurately and timely. Condition ? During the course of our engagement we noted that the controls surrounding the reporting function of this program were not operating effectively. There were instances in which the reports were not submitted timely and instances of reports being submitted with amounts not supported by the Department?s general ledger. Cause ? The Department does not have an internal control system designed to ensure all reports are being submitted by the required date and are submitted accurately. Effect ? The control deficiency could result in the Department?s reports within this program not being completed accurately and timely. Questioned Costs ? None reported. Context/Sampling ? Four of the twelve quarterly SF 425 Reports were selected for testing, and the one annual SF 429 Report was selected for testing. Repeat Finding from Prior Year(s) ? No. Recommendation ? Management should put procedures in place to ensure that all reports are submitted by the required date and are submitted with accurate information that is supported by the Department?s general ledger. Views of Responsible Officials ? Management of the Department is in agreement with the finding.

2021-010 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Program Information: See schedule of findings and questioned costs for chart/table Criteria ? A good system of internal accounting control contemplates an adequate system for ensuring that all reports are completed and submitted accurately and timely. Condition ? During the course of our engagement we noted that the controls surrounding the reporting function of this program were not operating effectively. There were instances in which the reports were not submitted. Cause ? The Department does not have an internal control system designed to ensure all reports are being submitted by the required date. Effect ? The control deficiency could result in the Department?s reports within this program not being completed accurately and timely. Questioned Costs ? None reported. Context/Sampling ? Two of four reports were selected for testing. Repeat Finding from Prior Year(s) ? Yes, prior year finding 2020-008. Recommendation ? Management should put procedures in place to ensure that all reports are submitted by the required date and are submitted with accurate information that is supported by the Department?s general ledger. Views of Responsible Officials ? Management of the Department is in agreement with the finding. Criteria ? A good system of internal accounting control contemplates an adequate system for ensuring that all reports are completed and submitted accurately.

2021-011 Eligibility Material Weakness in Internal Control over Compliance and Noncompliance Non-Major Federal Program Information See schedule of findings and questioned costs for chart/table Criteria ? A good system of internal accounting control contemplates an adequate system for ensuring that all eligibility requirements are met, documented and approved. Condition ? During the course of our engagement we noted that the internal controls of the Department did not obtain the adequate supporting documentation and appropriate approvals. Cause ? Internal control procedures are not in place to ensure that the Department is properly documenting and approving that individuals receiving federal awards are eligible to receive the dollars. Effect ? The failure to maintain documentation verifying the eligibility could result in the Department?s improper use of federal funds and non-compliance with the provisions of the applicable requirements. Questioned Costs ? Due to the lack of documentation we were unable to determine if all participants selected for testing were eligible. Therefore, possible unquantifiable questioned costs exist. Context/Sampling ? A nonstatistical sample of 10 participants out of approximately 137 total participants were selected for testing in which six items did not have an indication of approval. Repeat Finding from Prior Year(s) ? Yes, prior year finding 2020-010. Recommendation ? Management should put procedures in place to ensure that all eligibility requirements are properly being met, documented, and approved. Views of Responsible Officials ? Management of the Department is in agreement with the finding.

2020-005 Reporting Material Weakness in Internal Control over Compliance Federal Program Information See Schedule of Findings and Questioned Costs for chart/table Criteria ? A good system of internal accounting control contemplates an adequate system for ensuring that all reports are completed and submitted accurately. Condition ? During the course of our engagement we noted that the controls surrounding the reporting function of these programs were not being properly reviewed. There was no review being performed to ensure that all reported expenditures were submitted accurately. Cause ? The Department does not have an internal control system designed to ensure all reports submitted are reviewed by an individual separate from the person preparing the reports, and that the reports are accurate. Effect ? The control deficiency could result in the Department?s reports within these programs not being completed accurately and timely. Questioned Costs ? None reported. Context/Sampling ? Two out of two reports were selected for testing. Repeat Finding from Prior Year(s) ? No. Recommendation ? Management should put procedures in place to ensure that all reports are reviewed and accurate prior to being submitted. Views of Responsible Officials ? Management of the Department is in agreement with the finding.

2020-006 Allowable Costs/Activities Material Weakness in Internal Control over Compliance Federal Program Information See Schedule of Findings and Questioned Costs for chart/table Criteria ? A good system of internal controls includes keeping accurate supporting documentation for each expenditure of federal awards. Condition ? We noted that the Department failed to provide adequate documentation to satisfy if costs were allowable. Cause ? Procedures are not in place to ensure that the Department is maintaining adequate supporting documentation for each federal expenditure. There was an unallowed cost for duplicate payment and an unallowed cost for expenditures that did not occur in the current year. Effect ? Failure to maintain documentation verifying the purpose of the costs may result in the wrongful use of federal funds and non-compliance with the provisions of applicable requirements. Questioned Costs ? None reported. The total of known and likely questioned costs were less than the threshold that would require reporting. Context/Sampling ? A nonstatistical sample of 60 transactions out of 767 total transactions were selected for testing, which accounted for $48,353 of $2,786,232 of federal program expenditures. Repeat Finding from Prior Year(s) ? Yes, prior year finding 2019-007. Recommendation ? The Department should maintain adequate supporting documentation for each federal expenditure and ensure that proper approval is also obtained ensure that only allowable costs are being paid for with federal funds. Views of Responsible Officials ? Management of the Department is in agreement with the finding.

2020-007 Eligibility Material Weakness in Internal Control over Compliance Federal Program Information See Schedule of Findings and Questioned Costs for chart/table Criteria ? A good system of internal accounting control contemplates an adequate system for ensuring that all eligibility requirements are met, documented and approved. Condition ? During the course of our engagement we noted that the internal controls of the Department did not obtain the appropriate approvals. Cause ? Internal control procedures are not in place to ensure that the Department is properly documenting and approving that individuals receiving federal awards are eligible to receive the dollars. Effect ? The failure to maintain documentation verifying the eligibility could result in the Department?s improper use of federal funds and non-compliance with the provisions of the applicable requirements. Questioned Costs ? None reported. Context/Sampling ? A nonstatistical sample of 60 participants out of more than 250 total participants were selected for testing in which 16 items did not have an indication of approval. Repeat Finding from Prior Year(s) ? Yes, prior year finding 2019-008. Recommendation ? Management should put procedures in place to ensure that all eligibility requirements are properly being met, documented, and approved. Views of Responsible Officials ? Management of the Department is in agreement with the finding.

2020-008 Reporting Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Program Information See Schedule of Findings and Questioned Costs for chart/table Criteria ? A good system of internal accounting control contemplates an adequate system for ensuring that all reports are completed and submitted accurately. Condition ? During the course of our engagement we noted that the controls surrounding the reporting function of these programs were not being properly segregated. There was no review being performed to ensure that all required reports were submitted accurately. There were instances in which the reports were not submitted until requested by the auditor. Cause ? The Department does not have an internal control system designed to ensure all reports submitted are reviewed by an individual separate from the person preparing the reports, and that the reports are being submitted by the required date. Effect ? The control deficiency could result in the Department?s reports within these programs not being completed accurately and timely. Questioned Costs ? None reported. Context/Sampling ? Two out of four reports were selected for testing. Repeat Finding from Prior Year(s) ? Yes, prior year finding 2019-005. Recommendation ? Management should put procedures in place to ensure that all reports are reviewed prior to being submitted, and that they are submitted by the required date. Views of Responsible Officials ? Management of the Department is in agreement with the finding.

2020-009 Allowable Costs/Activities Material Weakness in Internal Control over Compliance and Material Noncompliance Federal Program Information See Schedule of Findings and Questioned Costs for chart/table Criteria ? A good system of internal controls includes keeping accurate recording of expenditures in the correct period. Condition ? We noted that the Department failed to record expenditures in the appropriate period when the costs were incurred. Cause ? Procedures are not in place to ensure that the Department is recording expenditures in the appropriate period when the costs are incurred. There were eight unallowed costs for expenditures that did not occur in the current year. Effect ? Failure to record expenditures in the correct period may result in the wrongful use of federal funds and non-compliance with the provisions of applicable requirements. Questioned Costs ? $3,355 or errors were noted out of $77,734 of items tested. Context/Sampling ? A nonstatistical sample of 60 transactions out of 751 total transactions were selected for testing, which accounted for $77,734 of $3,471,365 of federal program expenditures. Repeat Finding from Prior Year(s) ? Yes, prior year finding 2019-006. Recommendation ? The Department should put procedures in place to ensure that all expenditures are recorded in the correct period. Views of Responsible Officials ? Management of the Department is in agreement with the finding.

2020-010 Eligibility Material Weakness in Internal Control over Compliance and Noncompliance Non-Major Federal Program Information See Schedule of Findings and Questioned Costs for chart/table Criteria ? A good system of internal accounting control contemplates an adequate system for ensuring that all eligibility requirements are met, documented and approved. Condition ? During the course of our engagement we noted that the internal controls of the Department did not obtain the adequate supporting documentation and appropriate approvals. Cause ? Internal control procedures are not in place to ensure that the Department is properly documenting and approving that individuals receiving federal awards are eligible to receive the dollars. Effect ? The failure to maintain documentation verifying the eligibility could result in the Department?s improper use of federal funds and non-compliance with the provisions of the applicable requirements. Questioned Costs ? Due to the lack of documentation we were unable to determine if all participants selected for testing were eligible. Therefore, possible unquantifiable questioned costs exist. Context/Sampling ? A nonstatistical sample of 10 participants out of 137 total participants were selected for testing in which 2 items did not have an indication of approval, and four items did not have all the required documentation to support a conclusion of the participant being eligible. Repeat Finding from Prior Year(s) ? Yes, prior year finding 2019-009. Recommendation ? Management should put procedures in place to ensure that all eligibility requirements are properly being met, documented, and approved. Views of Responsible Officials ? Management of the Department is in agreement with the finding.

Federal Program information: See Schedule of Findings and Questioned Costs Criteria: A good system of internal accounting control contemplates an adequate system for ensuring that all reports are completed and submitted accurately. Condition: During the course of our engagement we noted that the controls surrounding the reporting function of these programs were not being properly segregated. There was no review being performed to ensure that all required reports were submitted accurately. There were instances in which the reports were not submitted until requested by the auditor. Cause: The Department does not have an internal control system designed to ensure all reports submitted are reviewed by an individual separate from the person preparing the reports, and that the reports are being submitted by the required date. Effect: The control deficiency could result in the Department?s reports within these programs not being completed accurately and timely Questioned Costs: None reported. Context/Sampling: For CFDA number 93.568 two out of four reports were selected for testing. For CFDA number 93.441 it was noted that none of the required reports were submitted. Repeat Finding from Prior Year(s): Yes, prior year finding 2018-007. Recommendation: Management should put procedures in place to ensure that all reports are reviewed prior to being submitted, and that they are submitted by the required date. Views of Responsible Officials: Management of the Department is in agreement with the finding.

Federal Program information: See Schedule of Findings and Questioned Costs Criteria: A good system of internal controls includes keeping accurate supporting documentation for each expenditure of federal awards. Condition: We noted that the Department failed to provide adequate documentation to satisfy if costs were allowable. Cause: Procedures are not in place to ensure that the Department is maintaining adequate supporting documentation for each federal expenditure. For CFDA number 93.596/93.575 the following item was found ? Unallowed cost for expenditure of interest on non-capital assets. For CFDA number 93.600 the following items were found. ? Unallowed cost for expenditure from prior periods. ? Unallowed cost for expenses that did not occur in the current year. Effect: Failure to maintain documentation verifying the purpose of the costs may result in the wrongful use of federal funds and non-compliance with the provisions of applicable requirements. Questioned Costs: None reported. The total of known and projected questioned costs were less than the threshold that would require reporting. Context/Sampling: For CFDA number 93.596/93.575 a nonstatistical sample of 60 transactions out of 1,600 total transactions were selected for testing, which accounted for $47,334 of $1,379,048 of federal program expenditures. For CFDA number 93.600 a nonstatistical sample of 60 transactions out of 753 total transactions were selected for testing, which accounted for $74,908 of $3,207,342 of federal program expenditures. Repeat Finding from Prior Year(s): Yes, prior year finding 2018-008. Recommendation: The Department should maintain adequate supporting documentation for each federal expenditure and ensure that proper approval is also obtained ensure that only allowable costs are being paid for with federal funds.

Federal Program information: See Schedule of Findings and Questioned Costs Criteria: A good system of internal controls includes keeping accurate supporting documentation for each expenditure of federal awards. Condition: We noted that the Department failed to provide adequate documentation to satisfy if costs were allowable. Cause: Procedures are not in place to ensure that the Department is maintaining adequate supporting documentation for each federal expenditure. The following items were found: ? Improper approval to use pay rates that do not agree to documentation in the personnel files ? Unallowed cost for expenses that did not occur in the current year. ? Unallowed cost for expenses for promotion and entertainment. Effect: Failure to maintain documentation verifying the purpose of the costs may result in the wrongful use of federal funds and non-compliance with the provisions of applicable requirements. Questioned Costs: The total of known errors in the sample was $4,101. Context/Sampling: A nonstatistical sample of 60 transactions out of 921 total transactions were selected for testing, which accounted for $122,726 of $3,029,012 of federal program expenditures. Repeat Finding from Prior Year(s): Yes, prior year finding 2018-009. Recommendation: The Department should maintain adequate supporting documentation for each federal expenditure and ensure that proper approval is also obtained ensure that only allowable costs are being paid for with federal funds. Views of Responsible Officials: Management of the Department is in agreement with the finding.

Federal Program information: See Schedule of Findings and Questioned Costs Criteria: A good system of internal accounting control contemplates an adequate system for ensuring that all eligibility requirements are met, documented and approved. Condition: During the course of our engagement we noted that the internal controls of the Department did not obtain the appropriate approvals. Cause: Internal control procedures are not in place to ensure that the Department is properly documenting and approving that individuals receiving federal awards are eligible to receive the dollars. Effect: The failure to maintain documentation verifying the eligibility could result in the Department?s improper use of federal funds and non-compliance with the provisions of the applicable requirements. Questioned Costs: Due to the lack of documentation we were unable to determine if all participants selected for testing were eligible. Therefore, possible unquantifiable questioned costs exist. Context/Sampling: A nonstatistical sample of 60 participants out of 2,350 participants were selected for eligibility testing in which 3 errors were noted. Repeat Finding from Prior Year(s): Yes, prior year finding 2018-011. Recommendation: Management should put procedures in place to ensure that all eligibility requirements are properly being met, documented, and approved. Views of Responsible Officials: Management of the Department is in agreement with the finding.

Federal Program information: See Schedule of Findings and Questioned Costs Criteria: A good system of internal accounting control contemplates an adequate system for ensuring that all eligibility requirements are met, documented and approved. Condition: During the course of our engagement we noted that the internal controls of the Department did not obtain the appropriate approvals. Cause: Internal control procedures are not in place to ensure that the Department is properly documenting and approving that individuals receiving federal awards are eligible to receive the dollars. Effect: The failure to maintain documentation verifying the eligibility could result in the Department?s improper use of federal funds and non-compliance with the provisions of the applicable requirements. Questioned Costs: Due to the lack of documentation we were unable to determine if all participants selected for testing were eligible. Therefore, possible unquantifiable questioned costs exist. Context/Sampling: A nonstatistical sample of 42 participants out of 209 participants were selected for eligibility testing in which 17 errors were noted. Repeat Finding from Prior Year(s): No. Recommendation: Management should put procedures in place to ensure that all eligibility requirements are properly being met, documented, and approved. Views of Responsible Officials: Management of the Department is in agreement with the finding

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