EIN: 470533471
UEI: E8GHH34ACJJ3
Audited by: Walker & Armstrong LLP
Oversight agency: 93 [Department of Health and Human Services]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 30, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by December 30, 2026 (119 days from today).
What is a management decision? →2024-102
FAC accepted this audit on June 30, 2025 — management decision was due December 30, 2025.
2023-102
2023-104
FAC accepted this audit on July 1, 2024 — management decision was due January 1, 2025.
2022-101
FAC accepted this audit on June 29, 2023 — management decision was due December 29, 2023.
2021-101
FAC accepted this audit on June 29, 2022 — management decision was due December 29, 2022.
2020-003
FAC accepted this audit on October 24, 2021 — management decision was due April 24, 2022.
2019-001
2019-002
2019-003
FAC accepted this audit on June 25, 2020 — management decision was due December 25, 2020.
Voucher authorization controls were overridden on two of the 120 items sampled. Noted two items to be incorrectly excluded from capital assets. Segregation of duties is limited in the expenditure and deposit process. Criteria: Prevention of approval and authorization of unallowable costs and coding costs correctly requires adequately trained and informed employees to prepare and approve payment vouchers as well as an environment that monitors and enforces the controls. Title 25 CFR 276.7 (a) (7) standards for grantee financial management systems state that accounting records must be supported by source documents. Effect: Without appropriate documentation or appropriate approval or coding, costs may be disallowed and required to be paid back by the grantee. If established policies are overridden, non-compliance risk increases and future adverse audit findings are more likely. Context and Cause: Lack of adopted official internal control procedures and lack of compliance with implied internal control procedures. This finding is a repeat finding from the prior year. The finding was identified as 2018-001 in the prior year audit. Recommendation: The Organizational Unit should implement better internal control over vouchering by requiring strict adherence to standard practice and provide adequate training to the vouchering employees. Response: Management will review their procedures surrounding vouchering and cash disbursements to find ways to eliminate vouchers that are not approved or recorded incorrectly. The number of unapproved vouchers has been greatly reduced the last couple years and they will continue to work toward eliminating them.
Show full finding ▾Hide full finding ▴2019-001 Finding: Internal Control to Prevent Unallowable Costs and miscoding of expenditures. Condition: Voucher authorization controls were overridden on two of the 120 items sampled. Noted two items to be incorrectly excluded from capital assets. Segregation of duties is limited in the expenditure and deposit process. Criteria: Prevention of approval and authorization of unallowable costs and coding costs correctly requires adequately trained and informed employees to prepare and approve payment vouchers as well as an environment that monitors and enforces the controls. Title 25 CFR 276.7 (a) (7) standards for grantee financial management systems state that accounting records must be supported by source documents. Effect: Without appropriate documentation or appropriate approval or coding, costs may be disallowed and required to be paid back by the grantee. If established policies are overridden, non-compliance risk increases and future adverse audit findings are more likely. Context and Cause: Lack of adopted official internal control procedures and lack of compliance with implied internal control procedures. This finding is a repeat finding from the prior year. The finding was identified as 2018-001 in the prior year audit. Recommendation: The Organizational Unit should implement better internal control over vouchering by requiring strict adherence to standard practice and provide adequate training to the vouchering employees. Response: Management will review their procedures surrounding vouchering and cash disbursements to find ways to eliminate vouchers that are not approved or recorded incorrectly. The number of unapproved vouchers has been greatly reduced the last couple years and they will continue to work toward eliminating them.
2019-001 Finding: Internal Control to Prevent Unallowable Costs and Miscoding of Expenditures. The number of transactions into the accounting system that have had controls overridden has declined and will continue to decline. More and better training and resources to our program directors and vouchering agents has been happening. We have also hired a CEO that now reviews and approves all transactions. This was in effect for FY2019 and aided in the compliance with policies and procedures.
2018-001
Payroll Files We sampled 49 payroll files ? 2 pay period samples for each employee selected. 4 samples did not have the proper pay authorization. Numerous samples did not have a supervisor signature, but someone else approving. There were inconsistencies on when a lunch break was deducted versus when it was not, as well as miscalculations on total hours worked. Criteria: The Organizational Unit?s largest expenditure is payroll. Proper control over payroll is required to avoid any material misstatements in the Organizational Unit?s financial statements. Effect: Inadequate or incomplete supporting payroll documents and authorizations could result in incorrect payroll processing and result in misstated financial statements and noncompliance with Federal agency standards. Context and Causes: The Organizational Unit does not maintain sufficient controls over its payroll system incomplete payroll files and noncompliant payroll reporting. This finding is a repeat finding from the prior year. The finding was identified as 2018-002 in the prior year audit. Recommendation: Proper filing of payroll records should begin immediately. Implementing a streamlined and less manual system is recommended to avoid errors. Response: Management will continue to work on improvements to the system that have already been implemented. Management will also work to implement new technology to improve the process.
Show full finding ▾Hide full finding ▴2019-002 Finding: Payroll Processing and Records Condition: Payroll Files We sampled 49 payroll files ? 2 pay period samples for each employee selected. 4 samples did not have the proper pay authorization. Numerous samples did not have a supervisor signature, but someone else approving. There were inconsistencies on when a lunch break was deducted versus when it was not, as well as miscalculations on total hours worked. Criteria: The Organizational Unit?s largest expenditure is payroll. Proper control over payroll is required to avoid any material misstatements in the Organizational Unit?s financial statements. Effect: Inadequate or incomplete supporting payroll documents and authorizations could result in incorrect payroll processing and result in misstated financial statements and noncompliance with Federal agency standards. Context and Causes: The Organizational Unit does not maintain sufficient controls over its payroll system incomplete payroll files and noncompliant payroll reporting. This finding is a repeat finding from the prior year. The finding was identified as 2018-002 in the prior year audit. Recommendation: Proper filing of payroll records should begin immediately. Implementing a streamlined and less manual system is recommended to avoid errors. Response: Management will continue to work on improvements to the system that have already been implemented. Management will also work to implement new technology to improve the process.
2019-002 Finding: Payroll Processing and Records In FY2017 a new HR manager was hired and has given priority to the audit findings and recommendations and has redirected resources to accomplish proper filing and clear up compliance in the Human Resource and Payroll internal accounting and administrative control in payroll transactions. Some of those improvements have already been seen as there were not findings related to the HR files for FY2019. A new finger print ID timecard system has been implemented on a trial basis to determine if this will work for the organization. This would greatly improve accuracy and control on payroll and it is anticipated it will go live in 2020.
2018-002
We found that management has not identified and addressed specific risks relevant to an overall risk assessment for the entire organization. There is no formal process to assess, analyze and manage these risks on an ongoing basis. Although there are certain procedures followed by the tribal members, there are no adopted accounting or procurement policies which provide minimum standards for accounting and internal control over financial reporting and federal awards. Criteria: An organization?s risk assessment program should identify and consider the implications of relevant risks, at both organizational and activity levels. This process should consider external and internal factors that could impact the achievement of organizational objectives, should include analyzing the risks and provide a basis and procedures for managing those risks. In the current accounting environment, the risk assessment process should also include an assessment of an organization?s risk specifically related to fraud. That assessment should be a part of the development of accounting and procurement procedures and policies adopted by the Organizational Unit. According to 25 CFR 900.36?when carrying out selfdetermination contracts, Indian tribes and tribal organizations shall develop, implement, and maintain systems that meet [certain] minimum standards, unless one or more of the standards have been waived, in whole or in part, under section 107(e) of the Act and subpart K. Also, 2 CFR 200 subparts D and E require written policies and procedures relative to federal awards. The Uniform Guidance also requires procurement policies that ensure compliance with rules and regulations regarding procurements using federal funds. Effect: The Organizational Unit will have a higher risk of non-compliance in the absence of risk assessment and implemented standard policies and procedures for internal control, accounting and procurement. Context and Cause: The Tribe commissioned the preparation of an extensive Financial Management Manual in 2000, but no manual has been adopted or fully implemented by the Organizational Unit. The primary reason behind it has been the lack of consensus among the Tribal members on standard policies and procedures for accounting and procurement. This finding is a repeat finding from the prior year. The finding was identified as 2018-003 in the prior year audit.Recommendation: The Tribal council should develop and adopt a formal risk assessment evaluation program for the Organizational Unit to assess all relevant risks. An accounting policy manual should be adopted that addresses financial reporting and federal awards. A procurement policy section should be added to their existing fixed asset policy manual. Response: Management will continue to work on drafting and approving manuals and procedures that identify assessed risks. Management did adopt a procurement policy in FY2016 and is still working on adopting the accounting policy manual.
Show full finding ▾Hide full finding ▴2019-003 Finding: Accounting, Procurement and Risk Assessment Policies Condition: We found that management has not identified and addressed specific risks relevant to an overall risk assessment for the entire organization. There is no formal process to assess, analyze and manage these risks on an ongoing basis. Although there are certain procedures followed by the tribal members, there are no adopted accounting or procurement policies which provide minimum standards for accounting and internal control over financial reporting and federal awards. Criteria: An organization?s risk assessment program should identify and consider the implications of relevant risks, at both organizational and activity levels. This process should consider external and internal factors that could impact the achievement of organizational objectives, should include analyzing the risks and provide a basis and procedures for managing those risks. In the current accounting environment, the risk assessment process should also include an assessment of an organization?s risk specifically related to fraud. That assessment should be a part of the development of accounting and procurement procedures and policies adopted by the Organizational Unit. According to 25 CFR 900.36?when carrying out selfdetermination contracts, Indian tribes and tribal organizations shall develop, implement, and maintain systems that meet [certain] minimum standards, unless one or more of the standards have been waived, in whole or in part, under section 107(e) of the Act and subpart K. Also, 2 CFR 200 subparts D and E require written policies and procedures relative to federal awards. The Uniform Guidance also requires procurement policies that ensure compliance with rules and regulations regarding procurements using federal funds. Effect: The Organizational Unit will have a higher risk of non-compliance in the absence of risk assessment and implemented standard policies and procedures for internal control, accounting and procurement. Context and Cause: The Tribe commissioned the preparation of an extensive Financial Management Manual in 2000, but no manual has been adopted or fully implemented by the Organizational Unit. The primary reason behind it has been the lack of consensus among the Tribal members on standard policies and procedures for accounting and procurement. This finding is a repeat finding from the prior year. The finding was identified as 2018-003 in the prior year audit.Recommendation: The Tribal council should develop and adopt a formal risk assessment evaluation program for the Organizational Unit to assess all relevant risks. An accounting policy manual should be adopted that addresses financial reporting and federal awards. A procurement policy section should be added to their existing fixed asset policy manual. Response: Management will continue to work on drafting and approving manuals and procedures that identify assessed risks. Management did adopt a procurement policy in FY2016 and is still working on adopting the accounting policy manual.
2019-003 Finding: Accounting and Risk Assessment In FY2010 the Tribe hired professional assistance in redrafting of the Tribe?s accounting manual. The work on this manual was completed in FY2010 and continues to be amended to work towards consensus among the Tribe?s executive members on the standardized policies and procedures. The Council did approve a fixed asset policy in FY2016, but that did not include updated uniform guidance standards on procurement. They are now looking to take the 2010 accounting manual, simplify it, and implement it, as well as update the fixed asset policy to include required procurement standards.
2018-003
FAC accepted this audit on June 26, 2019 — management decision was due December 26, 2019.
GSA_MIGRATION
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2017-001
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2017-002
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2017-003
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FAC accepted this audit on June 27, 2018 — management decision was due December 27, 2018.
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2016-002
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2016-001
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2016-002
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2016-001
FAC accepted this audit on June 28, 2017 — management decision was due December 28, 2017.
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2015-001
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2015-002
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2015-003
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