Nueta Hidatsa Sahnish College

2025 – 004: Procurement – Noncompetitive Procurement Documentation Federal Agency: U.S. Department of Education Federal Program Name: Higher Education – Institutional Aid Assistance Listing Number: 84.031 Federal Award Identification Number and Year: P03IT200009 - 2024 Award Period: October 1, 2020 through September 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Condition: During our testing of procurement transactions charged to Program 84.031, all three items selected met the criteria for noncompetitive procurement. However, the College did not maintain sufficient documentation to clearly support the sole source rationale for these purchases. Specifically, documentation was not retained to demonstrate why competition was determined to be impracticable or why the vendor was considered a sole source in accordance with federal procurement requirements. Criteria or specific requirement: Under 2 CFR § 200.320, noncompetitive procurement is permitted only under specific circumstances and must be supported by adequate written justification. Recipients are required to maintain documentation supporting the method of procurement and the basis for contractor selection. Cause: The College’s procurement policies and procedures do not clearly define documentation requirements for noncompetitive procurement or require formal written justification to support sole source determinations. Effect: Without sufficient documentation supporting sole source procurement decisions, the College is unable to demonstrate compliance with federal procurement requirements. This increases the risk of questioned costs and noncompliance with Uniform Guidance. Repeat Finding: No Recommendation: We recommend that the College update its procurement policies and procedures to require clear documentation supporting noncompetitive (sole source) procurement decisions. This documentation may include a written justification, signed memo, or other formal record explaining the rationale for selecting a sole source vendor and why competitive procurement methods were not used. Such documentation should be retained in the procurement file. View of responsible officials: There is no disagreement with this audit finding.

2025 – 005: Suspension and Debarment Documentation Federal Agency: U.S. Department of Education Federal Program Name: Higher Education – Institutional Aid Assistance Listing Number: 84.031 Federal Award Identification Number and Year: P03IT200009 - 2024 Award Period: October 1, 2020 through September 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Condition: During our testing of expenditures under Program 84.031, documentation evidencing verification of vendor eligibility related to suspension and debarment was not maintained. Specifically, the College did not retain documentation demonstrating that vendors associated with payments exceeding $25,000 were checked against the System for Award Management (SAM.gov) or other allowable verification methods to confirm they were not suspended or debarred at the time of payment. Criteria or specific requirement: Federal regulations require non‑Federal entities to verify that vendors receiving federal funds are not suspended or debarred from participation in federal programs. This verification may be performed through SAM.gov or other approved methods and must be documented for applicable transactions in accordance with 2 CFR 200.214 and 2 CFR 180. Cause: The College did not have a documented process to ensure suspension and debarment checks were performed and retained for applicable vendors, nor did its procedures clearly specify documentation requirements for compliance with suspension and debarment regulations. Effect: Without documented verification of suspension and debarment status, the College is unable to demonstrate compliance with federal requirements. This increases the risk that federal funds could be paid to ineligible vendors and results in noncompliance with Uniform Guidance. Repeat Finding: No Recommendation: We recommend that the College implement procedures to verify and document suspension and debarment status for all vendors receiving payments greater than $25,000. This verification should be performed using SAM.gov or another allowable method and retained in the College’s records to demonstrate compliance. View of responsible officials: There is no disagreement with this audit finding.

2025 – 006: Cash Management – Advance Drawdowns Federal Agency: U.S. Department of the Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Indian Education Assistance to Schools Assistance Listing Number: 15.027; 15.130 Federal Award Identification Number and Year: A19AP00111 – 2020; A24AP00281 – 2024 Award Period: July 1, 2019 through June 30, 2025; July 1, 2024 through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Condition: The College’s cash management procedures for Programs 15.027 and 15.130 allow for requesting federal funds in advance of disbursement. During our review, we noted that the College routinely draws down federal funds well in advance of when the funds are expended. The timing of these drawdowns was not consistently aligned with immediate cash needs, and documentation demonstrating efforts to minimize the time between receipt of funds and disbursement was not maintained. Criteria or specific requirement: Under 2 CFR 200.305(b), recipients other than States must minimize the time elapsing between the transfer of funds from the Federal awarding agency or pass‑through entity and the disbursement of those funds. Advance payments must be limited to the minimum amounts needed and timed as close as administratively feasible to actual disbursements. Recipients are also required to maintain written procedures and financial management systems that support compliance with these requirements. Cause: The College’s cash management procedures did not include controls to ensure that federal drawdowns were limited to immediate cash needs or to document how draw amounts and timing were determined in compliance with Uniform Guidance. Effect: Drawing down federal funds significantly in advance of disbursement increases the risk of noncompliance with federal cash management requirements and may result in excess federal cash on hand. This exposes the College to potential monitoring issues and questioned costs related to cash management practices. Repeat Finding: No Recommendation: We recommend that the College update its cash management procedures to ensure that federal drawdowns are limited to immediate cash needs and requested as close as administratively feasible to the related disbursements. The College should also document the basis for drawdown amounts and timing to demonstrate compliance with 2 CFR 200.305(b). View of responsible officials: There is no disagreement with this audit finding.

2025 – 007: Reporting – Timeliness of Required Reports Federal Agency: U.S. Department of the Interior Federal Program Name: Indian Education Assistance to Schools Assistance Listing Number: 15.130 Federal Award Identification Number and Year: A24AP00281 – 2024 Award Period: July 1, 2024 through June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Condition: During our review of reporting requirements for Program 15.130, we noted that certain required reports were not submitted by the due dates specified in the applicable award terms and conditions. Documentation provided by the College indicated that these reports were submitted after the established due dates. Criteria or specific requirement: Federal regulations and award terms require recipients to submit required financial and performance reports in a timely manner in accordance with established due dates. Recipients must maintain procedures to ensure compliance with reporting requirements and deadlines, as required by Uniform Guidance. Cause: The College did not have a documented process to track reporting deadlines for federal awards or to monitor the timely submission of required reports. Effect: Failure to submit required reports by the specified due dates results in noncompliance with federal award requirements and may increase the risk of delayed funding, increased monitoring, or other administrative actions by the awarding agency. Repeat Finding: No Recommendation: We recommend that the College implement procedures to track reporting requirements and due dates for federal awards and to retain documentation evidencing timely submission of all required reports. This may include maintaining a centralized reporting calendar or checklist and documentation of report submission dates. View of responsible officials: There is no disagreement with this audit finding.

Information on Federal Program: U.S. Department of Education – Higher Education Emergency Relief Fund (HEERF) AL#84.425E, 84.425F, 84.425K Criteria – The granting agency requires that the grantee prepare financial and programmatic reports on a quarterly and annual basis. Internal controls should be adequately designed and implemented to allow for the accurate and timely preparation of these reports. Condition – For the year ended June 30, 2023, we identified grant reports that were prepared and reviewed by the same individual prior to being submitted to the granting agency. Cause – Internal controls, while appropriately designed, were not implemented consistently when staff turnover created a lack of independent review in the grant reporting process. Effect or Potential Effect – There is a potential that grant reports will be submitted that were not accurately prepared or included misleading programmatic information. Questioned Costs – None noted. Context – As part of our testing, we selected the quarterly and annual reports to view documentation to support the independent review of the grant reports prior to submission. Of the quarterly and annual reports selected for testing, we were unable to view documentation of this review. Repeating Finding – This is not a repeat finding. Recommendation – An additional staff member should be identified, that possesses the appropriate knowledge, to review the grant reports after they have been prepared to ensure accurate submissions to the granting agency. View of Responsible Officials We do agree with this finding. This occurred when we had turnover in positions. While hiring for one of the positions, one person was doing both tasks. We do not see this happening again as we have hired a new employee to prepare the quarterly and annual reports.

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