NEBRASKA URBAN INDIAN HEALTH COALITION, INC.

Finding Number: 2025-002 Finding Title: Cash Collateralization (Repeat Finding 2024-004) Planned Corrective Action: Management acknowledges the finding regarding cash collateralization. As of September 30, 2025, the Coalition's cash deposits were pledged and collateralized. After year-end, management became aware that two affiliated financial institutions participating in the deposit sweep program had inadvertently assigned the same certificate numbers during the nightly sweep process. Consequently, a portion of the Coalition's deposits may have been swept into the same financial institution, resulting in balances that may have temporarily exceeded applicable FDIC insurance limits. Although this condition resulted from the financial institutions' sweep process rather than the Coalition's cash management practices, management recognizes its responsibility to monitor deposit coverage and ensure compliance. To address this finding, the Coalition will implement the following corrective actions: 1. Meet with representatives from both participating banks to discuss the issue and formally notify them of the audit finding. 2. Request written confirmation that the nightly sweep process has been reviewed and modified to prevent deposits from being placed with the same institution through duplicate certificate assignments or other system errors. This may happen from time-to-time but IntraFi corrects those deposits and reallocates them, It will be reviewed weekly to make sure they did reallocate those funds. 3. Communication with certain representatives within the financial institution will be contacted by NUHIC and will need to request that dollars are required to be transferred to IntraFi to remain in compliance of your audit before 2:30pm everyday. 4. Obtain and review periodic reports from the financial institutions identifying the banks holding swept deposits and the amount of funds placed with each institution. 5. Establish a weekly review process to monitor cash balances, FDIC insurance coverage, and collateralization to identify any exceptions on a timely basis. 6. Maintain documentation of all reviews, bank communications, and corrective actions as part of the Coalition's internal control procedures. 7. If the financial institutions cannot provide adequate assurance that deposits will remain fully insured or properly collateralized, the Coalition will evaluate alternative cash management options, including other insured cash sweep providers or collateralized deposit arrangements. Management believes these corrective actions will strengthen oversight of the Coalition's cash management process and reduce the risk of future noncompliance with FDIC insurance requirements. Responsible Official: Carlett Gregory Anticipated Completion Date: December 31, 2026

2024-004

Finding 2024-002 – Activities Allowed/Unallowed, Costs Principles and Period of Performance (Internal Controls Over Compliance) (Repeat Finding 2023-001) Condition: During our review of the Coalition’s disbursements related to the Title V major program, we examined 68 transactions for internal controls over compliance. 7 of the 68 transactions examined did not contain sufficient evidence that a review and approval process was completed prior to payment being processed. Corrective Action Plan: In response to the finding regarding insufficient internal controls over compliance for disbursements related to the Title V major program, the Nebraska Urban Indian Health Coalition (NUIHC) has previously taken several corrective actions to strengthen compliance, including: 1. Review and Revision of Policies and Procedures: NUIHC conducted a comprehensive review of internal control policies and procedures related to disbursements. Updates were made to ensure alignment with 2 CFR §200.313(a), and clear guidelines for review and approval processes were established. 2. Staff Training and Education: Training was provided to procurement and finance staff to ensure understanding of the revised procedures and federal compliance requirements, emphasizing the importance of proper approvals prior to disbursement. 3. Implementation of Standardized Approval Controls: A formal approval process and checklist system were implemented to ensure all disbursements are reviewed and approved by designated authorities before payment, with documentation retained for compliance. 4. Ongoing Monitoring and Internal Reviews: NUIHC began conducting quarterly internal compliance checks to verify adherence to updated procedures. Update and Continuation Plan: While these corrective actions were successfully implemented, the retirement of the former CEO temporarily stalled consistent oversight and reinforcement of these procedures. With new leadership in place, NUIHC is recommitting to the continued execution and monitoring of these corrective actions. Refresher training will be incorporated into ongoing professional development and onboarding for new staff, and quarterly internal audits will resume as scheduled. Timeline for Implementation: Corrective actions were initially implemented in 2024, and reinforcement activities—including staff refreshers and compliance monitoring—will continue a rolling basis starting July 2025. Responsible Party: Chief Financial Officer, Carlett Gregory Anticipated Completion Date: Ongoing; reinforcement begins July 2025

2023-001

Finding 2024-003 – Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) (Repeat Finding 2023-002) Condition: During our review of the Coalition's internal controls over compliance related to the Title V major program, we noted that the Coalition does not have an adequate system of controls established to identify, mark, record, or maintain equipment that has been purchased with federal funds. In addition, no annual physical inventory of the Title V equipment is being performed. Corrective Action Plan – Finding 2024-003 Corrective Action: The Nebraska Urban Indian Health Coalition (NUIHC), in conjunction with our IT provider, has implemented a tracking system to support effective management of computer and other equipment purchased with federal funds. This includes maintaining an active equipment list and regularly updating clinic inventory on a quarterly basis for both clinic sites. Additionally, other organizational equipment is tracked using our depreciation schedule and internal records for assets that do not meet fixed asset thresholds. Inventory identification and tagging procedures are currently underway, with the goal of ensuring all equipment is properly labeled with a unique identifier and clearly marked to reflect Title V or other applicable funding sources. To further strengthen our internal controls and ensure full compliance with 2 CFR §200.313, NUIHC will take the following steps: 1. Development of Written Procedures: Comprehensive written procedures will be finalized and implemented to cover the maintenance, repair, protection, preservation, control, and accountability of all equipment purchased with federal funds. 2. Training for Staff: Additional training will be provided to all relevant staff responsible for equipment procurement, inventory tracking, and maintenance. This training will focus on the importance of proper identification, documentation, and adherence to federal equipment management standards. 3. Ongoing Monitoring: NUIHC will continue quarterly updates of clinic inventories and include periodic spot checks to verify the accuracy of records and physical inventory. Timeline for Implementation: • Finalization of written procedures: By August 31, 2025 • Completion of equipment identification and labeling: By September 30, 2025 • Staff training: Starting August 2025 and incorporated into annual compliance training Responsible Party: Chief Financial Officer, Carlett Gregory Anticipated Completion Date: September 30, 2025

2023-002

Finding 2024-004 – Cash Collateralization (Repeat Finding 2023-003) Condition: During our review of the Coalition’s cash, it was noted that as of September 30, 2024, they have. not collateralized cash balances more than the amounts insured by the Federal Despot Insurance Corporation. Cash balances of $7,596,383 were uninsured at September 30, 2024. Unearned revenue was reported at approximately $4,434,584 which includes advance payments of Federal Funds. Corrective Action Plan – Finding 2024-004 Corrective Action: In response to the finding regarding the lack of collateralization for cash balances exceeding the amounts insured by the Federal Deposit Insurance Corporation (FDIC), the Nebraska Urban Indian Health Coalition (NUIHC) acknowledges that corrective actions were initially delayed due to the illness and eventual retirement of the former CEO. However, under new leadership, these actions have since been fully implemented. As of April 2025, NUIHC is in full compliance with the cash collateralization requirements outlined in 2 CFR §200.305(b)(7). A formal cash collateralization agreement has been executed with our financial institutions, ensuring that all cash balances—including advanced federal funds—are now either insured or properly collateralized. In addition to entering into this agreement, the following measures are in the process to strengthen ongoing compliance: 1. Updated Cash Management Policies: Policies are being reviewed and revised to reflect current federal requirements and internal procedures regarding custodial credit risk and cash handling practices. 2. Monitoring and Compliance Controls: A monitoring system is in place to routinely review cash balances and coordinate with our financial institution to ensure all funds remain protected. 3. Staff Training: Targeted training was provided to financial and accounting staff to ensure continued understanding of cash collateralization requirements and the importance of ongoing compliance. Implementation Summary: • Cash Collateralization Agreement: Completed – April 2025 • Policy Revisions and Monitoring System: In process– July 2025 • Staff Training: Completed by – August 2025 Responsible Party: Chief Financial Officer, Carlett Gregory

2023-003

Finding 2024-005 – Procurement Policy (Repeat Finding 2023-004) Condition: During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327 In response to the finding related to non-compliance with procurement policies and procedures under Uniform Guidance 2 CFR §200.317 – §200.327, the Nebraska Urban Indian Health Coalition (NUIHC) is committed to ensuring full compliance with all applicable federal, state, local, and tribal procurement requirements. To address this finding and strengthen internal practices, the Coalition will implement the following corrective actions: 1. Procurement Policy Review with External Expertise: NUIHC has contracted with an external consultant with expertise in federal procurement regulations to assist in conducting a thorough review of the organization’s current procurement policies and procedures. This partnership will help ensure that all updates reflect the specific requirements of 2 CFR §200.317 – §200.327 and incorporate best practices in compliance, documentation, and oversight. 2. Update and Alignment of Procedures: With the support of the external contractor, NUIHC will update detailed procurement procedures to ensure they align with Uniform Guidance and any applicable state, local, or tribal procurement laws. Clear step-by-step procedures will be documented for each procurement method (e.g., micro-purchases, small purchases, sealed bids, competitive proposals, and non-competitive proposals). 3. Ongoing Education and Training: NUIHC will implement a continued education and training program for all staff involved in procurement activities. In addition to the initial training on updated policies, refresher training will be offered annually and included as part of new employee onboarding. This will ensure sustained awareness of procurement responsibilities and regulatory compliance. 4. Internal Controls and Review Process: A formal internal control process will be implemented to verify compliance with updated procurement policies. This includes a procurement checklist, mandatory pre-approval protocols, and supporting documentation requirements for every procurement action. 5. Monitoring and Quarterly Compliance Checks: The Coalition will continue conducting quarterly internal audits of procurement activities to ensure adherence to policy, detect potential issues early, and implement timely corrective actions. Findings will be reported to leadership and the Board of Directors as part of ongoing compliance oversight. Timeline for Implementation: • External Consultant Engagement: Completed – May 2025 • Policy and Procedure Review: To be completed by July 31, 2025 • Initial Staff Training: To be conducted by August 15, 2025 • Internal Controls & Monitoring: To be fully implemented by August 31, 2025 • Ongoing Training and Quarterly Reviews: Begin Q3 2025 and continue thereafter Anticipated Full Compliance Date: August 31, 2025 Corrective Action Plan Finding 2024-005 – procurement Policy (Repeat Finding 2023-004) Responsible Party: Chief Financial Officer, Carlett Gregory

2023-004

SECTION III – FINDINGS – FEDERAL AWARD FINDINGS Finding 2023-001 – Activities Allowed/Unallowed, Costs Principles, and Period of Performance (Internal Controls Over Compliance) Significant Deficiency Criteria: Uniform Guidance 2 CFR, Part §200.313(a) requires that non-federal entities must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our review of the Coalition’s disbursements related to the Title V major program, we examined 40 transactions for internal controls over compliance. 2 of the 40 transactions examined did not contain sufficient evidence that a review and approval process was completed prior to payment being processed. Questioned Costs: None Cause: The Coalition does not have sufficiently established control policies and procedures to ensure proper approvals are obtained prior to the disbursement transactions being processed. Effect: Disbursements are being processed without proper approval, resulting in the possibility of disallowed expenditures. SECTION III – FINDINGS – FEDERAL AWARD FINDINGS Finding 2023-001 – Activities Allowed/Unallowed, Costs Principles, and Period of Performance (Internal Controls Over Compliance), continued Recommendation: We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.313(a) and establishes appropriate internal control policies and procedures and that all staff be trained on those policies and procedures, so they are familiar with the requirements. We further recommend the Coalition does not process payment for disbursements that do not contain necessary approvals. Responsible Official: Carlett Gregory, CFO Corrective Action: In response to the finding regarding insufficient internal controls over compliance for disbursements related to the Title V major program, the Coalition will take the following corrective actions: 1. Review and Revise Policies and Procedures: o The Coalition will conduct a thorough review of our current internal control policies and procedures related to disbursements to ensure they align with the requirements of 2 CFR, Part §200.313(a). o We will revise and update our policies and procedures as necessary to ensure they are comprehensive and robust, providing clear guidelines for review and approval processes. 2. Training and Education: o We will provide additional training to all staff involved in the procurement process to ensure they are fully aware of the updated policies and procedures. o The training will cover the importance of obtaining proper approvals prior to processing payments and the specific requirements of 2 CFR, Part §200.313(a). 3. Implementation of Approval Controls: o We have implemented a standardized approval process for all disbursements, ensuring that each transaction is reviewed and approved by the designated authority before payment is processed. o We currently have in place a checklist to document the review and approval process for each transaction, ensuring that evidence of compliance is retained. 4. Monitoring and Compliance Checks: o We will establish regular monitoring and compliance checks to ensure adherence to the updated policies and procedures. o Quarterly internal audits will be conducted to verify that all disbursements are properly reviewed and approved according to the established guidelines. Timeline for Implementation: The corrective actions outlined above have been implemented. Training sessions will be part of the onboarding process and existing programs. It will also be reviewed as needed to address any changes.

Finding 2023-002 – Equipment and Real Property Management (Compliance; Internal Controls Over Compliance) Significant Deficiency Criteria: In accordance with FAR Contract Clause 52.245-1 "Government Property" the Contractor shall establish and maintain written procedures for the maintenance, repair, protection and preservation, control of, and accountability for Government property, consistent with the provisions of DHHS Publication (OS) 686, entitled "Contractor's Guide for Control of Government Property (1990)." Condition: During our review of the Coalition's internal controls over compliance related to the Title V major program, we noted that the Coalition does not have an adequate system of controls established to identify, mark, record, or maintain equipment that has been purchased with federal funds. In addition, no annual physical inventory of the Title V equipment is being performed. Questioned Costs: None Responsible Officials: Carlett Gregory CFO, Elizabeth Clifford Facilities Manager, Finance Department, Chantel Mosely Data Analyst. • In conjunction with our IT provider, NUIHC maintains an equipment list of computer equipment. NUIHC also updates the clinic inventory for our two clinics on a quarterly basis. Other equipment is maintained using the depreciation list as well as other equipment that does not meet the fixed asset criteria. The inventory identification is in process and NUIHC will update comprehensive written procedures for the maintenance, repair, protection, preservation, control of, and accountability for equipment purchased with federal funds. • Identification and Marking of Equipment: • We have continued to implement a system to properly identify and mark all equipment purchased with federal funds. This will include labeling each piece of equipment with a unique identifier and clearly indicating its association with the Title V program. This is currently in process. • Annual Physical Inventory: • We will update our procedure to conduct an annual physical inventory of all equipment purchased with federal funds. This inventory will be maintained with finance, HR, facilities and our IT vendor, and any discrepancies will be investigated and resolved promptly. • Training, Education and Timing: • All staff involved in equipment management will receive training on the updated procedures. This training will ensure that staff are fully aware of their responsibilities and the procedures for managing equipment in 45 days.

Finding 2023-003 – Cash Collateralization Criteria: Uniform Guidance 2 CFR, Part §200.305(b)(7) requires advance payments of Federal funds to be deposited and maintained in insured accounts whenever possible. Condition: During our review of the Coalition’s cash, it was noted that as of September 30, 2023, they have. not collateralized cash balances in excess of the amounts insured by the Federal Despot Insurance Corporation. Cash balances of $10,608,222 were uninsured at September 30, 2023. Unearned revenue was reported at approximately $5,389,532 which includes advance payments of Federal funds. Questioned Costs: None Cause: The Coalition has not entered into a cash collateralization agreement with their financial institution. Effect: The Coalition is not in compliance with Uniform Guidance 2 CFR, Part §200.305(b)(7) as not all cash balances received in advance from the funding agency were adequately insured or collateralized and were exposed to custodial credit risk in the event of a bank failure. Recommendation: We recommend the Coalition enter into a cash collateralization agreement with their financial institution to ensure that all amounts related to grant agreements and awards received in advance are not exposed to custodial credit risk in the event of a bank failure. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs. Responsible Officials; Dr. Donna L. Polk CEO, Carlett Gregory CFO, Anne Steinhoff Board Treasurer. Corrective Action: In response to the finding regarding the lack of collateralization for cash balances in excess of the amounts insured by the Federal Deposit Insurance Corporation (FDIC). NUIHC will get clarification from I.H.S. and our financial institution to address the best way to resolve this issue. Possible options are using the CDARS program or finding a local DIF member institution. The Coalition will take the following corrective actions: 1. Establish Cash Collateralization Agreement: o The Coalition will promptly enter into a cash collateralization agreement with our financial institution. This agreement will ensure that all cash balances, including those received in advance from federal funding agencies, are adequately insured or collateralized. 2. Review of Cash Management Policies: o We will review and update our cash management policies to ensure compliance with Uniform Guidance 2 CFR, Part §200.305(b)(7). This review will include assessing our current banking arrangements and making necessary adjustments to mitigate custodial credit risk. 3. Monitoring and Compliance: o The Coalition will implement a monitoring system to regularly review cash balances and ensure that they do not exceed insured limits without proper collateralization. This system will involve periodic checks and coordination with our financial institution to maintain compliance. 4. Training and Education: o We will provide training to our financial and accounting staff on the importance of cash collateralization and the requirements of Uniform Guidance 2 CFR, Part §200.305(b)(7). This training will ensure that all relevant personnel are aware of the new procedures and the need to maintain insured or collateralized cash balances. Timeline for Implementation: The corrective actions outlined above will be implemented within the next 30 days. The cash collateralization agreement will be established immediately, and updates to cash management policies will be completed within this period. Training sessions for relevant staff will be conducted promptly following the implementation of these changes.

Finding 2023-004 – Procurement Policy Criteria: In accordance with Uniform Guidance 2 CFR, Part §200.318 "General Procurement Standards", the non-federal entity must have and use documented procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a federal award or subaward. The non-federal entity's document procedures must conform to the procurement standards identified in 2 CFR, Part §200.317 - §200.327. Condition: During our review of the Coalition's Policies and Procedures, we determined that the Coalition's Procurement policy does not comply with 2 CFR, Part §200.317 - §200.327 Questioned Costs: None Cause: The Coalition was unaware of the changes in General Procurement Standards within Uniform Guidance and therefore does not have sufficiently established control policies and procedures to comply with 2 CFR, Part §200.317 - §200.327. Effect: The Coalition does not have the ability to determine if disbursements, projects, and bids comply with 2 CFR, Part §200.317 - §200.327. Recommendation: We recommend the Coalition becomes familiar with requirements of 2 CFR, Part §200.317 - §200.327. and establishes appropriate internal control policies and procedures related to procurement and that all staff be trained in those policies and procedures, so they are familiar with the requirements. We further recommend no contract or agreement be awarded by the Coalition in which appropriate procurement policies have not been followed Corrective Action: In response to the finding regarding non-compliance with procurement policies as outlined in 2 CFR, Part §200.317 - §200.327, the Coalition will take the following corrective actions: 1. Review and Update Procurement Policies: o The Coalition will conduct a comprehensive review of its current procurement policies and procedures. We will update these policies to ensure full compliance with Uniform Guidance 2 CFR, Part §200.317 - §200.327, as well as any relevant state, local, and tribal laws and regulations. o We will review and update detailed procedures. These procedures will be clearly aligned with the standards identified in 2 CFR, Part §200.317 - §200.327. 2. Training and Education: o All staff involved in the procurement process will receive training on the updated procurement policies and procedures. This training will ensure that all relevant personnel are familiar with the requirements of Uniform Guidance 2 CFR, Part §200.317 - §200.327, and understand their responsibilities in adhering to these standards. 3. Implementation of Internal Controls: o The Coalition will implement internal controls to ensure compliance with the updated procurement policies and procedures. This will include establishing a review and approval process for all procurements to verify adherence to the new standards. 4. Monitoring and Compliance Checks: o We will establish a system for ongoing monitoring and compliance checks to ensure that all disbursements, projects, and bids comply with 2 CFR, Part §200.317 - §200.327. Quarterly audits will be conducted to identify and address any deviations from the established policies and procedures. Timeline for Implementation: The corrective actions outlined above will be implemented within the next 30 days. The review and update of procurement policies and procedures will be completed within this period, and training sessions for relevant staff will be conducted immediately following the implementation of these changes. Internal controls and monitoring systems will be established concurrently. Contact Information: For further information or questions regarding this corrective action plan, please contact: Carlett Gregory, CFO, Email: cgregory@nuihc.com, 402-346-0902 x 204. Carlett Gregory Carlett Gregory CFO

Finding: 2021-001: Agency: Accounting Finance Donna L. Polk, CEO Anticipated Completion Date April 30, 2023 Agency?s response: Concur The Accounting Finance Office agrees with this finding and will implement the following: The Coalition will begin audit preparation work within 30 days in the new fiscal year for the previous fiscal year. The financial audit will be scheduled to commence within 90 days after the end of the previous fiscal year.

GSA_MIGRATION

2016-003

GSA_MIGRATION

2016-004

GSA_MIGRATION

2015-003

GSA_MIGRATION

2015-004