Big Valley Rancheria Band of Pomo IndiansTribal Government

Program Information: U.S. Department of the Interior BIA Consolidated Tribal Government/ COVID-19 - ARPA ATTG & HIP Assistance Listing #: 15.021 Award Number: A20AV00601, A17AV00362, A20AV00601 Award Period: 1/1/2020-12/31/2023 Criteria: 2 CFR § 200.303 - Internal controls states, the recipient and subrecipient must: (a) 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). The cost principles in 2 CFR Part 200, subpart E (Cost Principles), prescribe the cost accounting requirements associated with the administration of Federal awards by: a. States, local governments, and Indian tribes. Except where otherwise authorized by statute, cost must meet the following general criteria in order to be allowable under Federal awards: 7. Be adequately documented. Condition/Context: During testing of non-payroll transactions, the following was noted: • For 4 of 23 non-payroll transactions (3 of 4 Individually Important Item (III) transactions tested and 1 of 19 samples tested), supporting documentation was insufficient to determine whether the gift cards purchased were spent properly for allowable costs. • For 1 of 23 non-payroll transactions, the expenditure tested represented an unallowable cost. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Department did not have adequate internal controls in place to ensure that gift card purchases and other expense were sufficiently supported and restricted to allowable program purposes. Effect: As a result, there is an increased risk that Federal funds were used for unallowable purposes. Questioned Costs: Known – $48,929 Repeat Finding: No. Recommendation: We recommend the Department strengthen controls over the purchase and distribution of gift cards and require documentation demonstrating the business purpose and allowable use of all gift card expenditures. Additionally, the Department should review and approve all non-payroll expenditures for allowability prior to charging them to the Program. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Program Information: U.S. Department of the Treasury COVID-19 - American Rescue Plan Act Assistance Listing #: 21.027 Award Number: SLFRP1559, SLFRP5012 Award Period: 5/19/2021-12/31/2026 Criteria: 2 CFR § 200.303 - Internal controls states, the recipient and subrecipient must: (a) 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). The Tribe’s procurement policy requires that purchases above certain thresholds be supported by evidence of competitive bids or quotes to ensure fair and open competition. For revenue loss eligible use category expenditures under CSLFRF, the May 2024 OMB Compliance Supplement and Treasury Final Rule FAQ 13.15 clarify that federal procurement requirements in 2 CFR 200.318–200.327 do not apply. Condition/Context: During testing of procurement transactions charged to the program under the revenue loss eligible use category, 3 of 6 Individually Important Item procurement samples selected for review did not contain documentation of competitive bids or quotes as required by the Tribe’s procurement policy. These transactions were not subject to federal procurement requirements. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: The deficiency appears to be the result of staff not consistently following the Tribe’s established procurement procedures and a lack of management oversight to ensure compliance with local procurement requirements. Effect: Failure to obtain and document competitive bids or quotes increases the risk that the Tribe may not obtain goods and services at the best value and may not provide for full and open competition, as required by its own policy. Questioned Costs: N/A - as the compliance attribute does not apply for revenue loss transactions. Repeat Finding: No. Recommendation: We recommend that management reinforce and monitor compliance with the Tribe’s procurement procedures, including obtaining and retaining documentation of competitive bids or quotes for all purchases above the micro-purchase threshold, and provide training to staff responsible for procurement. Management should also implement periodic reviews of procurement files to ensure compliance with the Tribe’s procurement requirements. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.