Cheyenne and Arapaho TribesTribal Government

2024-003 – Single Audit Report Submission – Material Weakness Federal program information: Funding agency: All Major Programs Title: All Major Programs Assistance listing number: All Major Programs Award year: All Major Programs Award number: All Major Programs Criteria: The Uniform Guidance requires that the Single Audit reporting package be submitted within nine months after the end of the audit period. Condition/Context: The Department’s fiscal year ended December 31, 2024; the Single Audit reporting package was not submitted to the Federal Audit Clearinghouse within nine months after the end of the audit period as required. Cause and Effect: The Department did not have appropriate internal control policies and procedures in place to ensure accounting records and financial statements were reconciled timely and the audit was conducted in time to meet compliance requirements. As a result, the Single Audit reporting package was submitted well after the required reporting period, which may result in the potential suspension of funding provided by federal agencies. Questioned Costs: None. Identification as a Repeat Finding: This is a repeat finding from the prior year. This finding was reported as financial statement finding 2023-002 in the 2023 report. Recommendations: To ensure compliance with Uniform Guidance requirements, the Department should prepare accurate, complete, and timely financial statements to ensure an audit is performed timely and the Single Audit reporting package is submitted by the required deadline. Views of Responsible Officials: Management concurs with the finding. Management is continuing efforts to improve the timeliness of the year-end close process, strengthen financial reporting procedures, and enhance audit preparation and coordination to support timely completion and submission of future Single Audit reporting packages..

2024-004 – Reporting – Significant Deficiency Federal program information: Funding agency: U.S. Department of Treasury Title: Local Assistance and Tribal Consistency Funds Assistance listing number: 21.032 Award year: December 31, 2024 Award number: COVID-19 Funding Funding agency: U.S. Department of Health and Human Services Title: Head Start Cluster Assistance listing number: 93.600 Award year: December 31, 2024 Award number: 90CI010014-05-04 Criteria: In accordance with the program’s contract provisions, the federal programs are required to submit financial information and applicable narrative reports to the funding agencies using standard financial reporting forms. These reports are to be submitted by the required due date, be accurately completed and supported by the underlying accounting and operational records. Condition/Context: Internal control processes were not sufficient to ensure timely and accurate submission of reports. As a result, two of two sampled SF-425 reports and an annual Expenditure and Obligation Report were not submitted on time. Additionally, management was unable to reconcile one of the two SF-425 reports and the Project and Obligation Report was not properly prepared. Cause and Effect: The Department did not have appropriate controls in place to monitor reporting deadlines. As a result, the Department was not submitting required reports to each respective federal agency in a timely manner. Questioned Costs: None. Identification as a Repeat Finding: This is a repeat finding from the prior year. This finding was reported as finding 2023-004 and 2023-006 in the 2023 report. Recommendations: We recommend that the Finance Department develop and implement internal control policies and procedures that ensure required reports are filed timely. We further recommend that the Department implement a monitoring process to ensure that the reporting information is accurate and complete and filed by the required due date.. Views of Responsible Officials: Management concurs with the finding. The Department is continuing efforts to strengthen internal controls over the preparation, review, and timely submission of required federal reports. Management will continue to monitor the reporting process and implement procedures to support accurate, complete, and timely filing of required reports.

2024-005 – Procurement, Suspension, and Debarment – Significant Deficiency Federal program information: Funding agency: U.S. Department of Treasury Title: Coronavirus State and Local Fiscal Recovery Funds Assistance listing number: 21.027 Award year: December 31, 2024 Award number: COVID-19 Funding Criteria: In accordance with the program’s contract provisions, recipients may use award funds to enter into contracts to procure goods and services necessary to implement the eligible purposes outlined by the treasury. Recipients are expected to follow procurement policies and procedures in place that comply with the procurement standards outlined in the Uniform Guidance. Condition/Context: For two of five procurements tested, the Department could not provide evidence that procedures were performed to ensure vendors were not suspended or debarred from receiving federal funding for services rendered. In addition, for two of five procurements tested, sole source justifications were identified that did not meet the Department’s policy requirements. Cause and Effect: The Department did not have appropriate internal control policies and procedures in place to ensure selected vendors were not suspended or debarred and that sole source procurements were adequately justified in accordance with the Department’s policy. As a result, federal funding could be awarded to vendors not entitled to receive federal funds. Questioned Costs: None. Identification as a Repeat Finding: This is a repeat finding from the prior year. This finding was reported as finding 2023-005 in the 2023 report. Recommendations: We recommend revising the Department’s procedures to ensure vendors with which the Department procures goods and services are not federally suspended or debarred. We also recommend revising the Department strengthen procedures over sole source procurements to ensure justifications are prepared, reviewed, and maintained in accordance with Department policy and the Uniform Guidance.. Views of Responsible Officials: Management concurs with the finding. Procurement, Grants, and Contracts has developed updated policies and procedures intended to strengthen procurement controls and support compliance with applicable federal requirements, including vendor suspension and debarment verification. These policies and procedures have been submitted for approval but have not yet been formally adopted. In the interim, management will continue working with the responsible departments to support implementation efforts and strengthen procurement practices while formal approval is pending.

2024-006 – Special Tests and Provisions – Character Investigations – Significant Deficiency Federal program information: Funding agency: U.S. Department of Health and Human Services Title: Indian Self-Determination and Education Assistance Act Assistance listing number: 93.441 Award year: December 31, 2024 Award number: 246202400013 Criteria: In accordance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards at 2 CFR Part 200, Subpart F, the auditee is required to comply with all federal statutes, regulations, and the terms and conditions of the federal award, including background investigation requirements, such as conducting fingerprinting and background checks of employees in accordance with the Department’s policies and procedures. Condition/Context: The Department was unable to provide complete background checks and suitability determination/adjudication documentation for two of two employees sampled. Cause and Effect: The Department did not have appropriate internal control policies and procedures in place to ensure compliance with background check requirements. Questioned Costs: None. Recommendations: The Department should comply with established policies and procedures related to background investigations. Views of Responsible Officials: Management concurs with the finding. The Department is in the process of strengthening controls and procedures related to background check and suitability determination requirements. Oversight of corrective action will be coordinated through the Human Resources function and related administrative leadership until staffing is fully in place. Management is working to improve documentation, compliance monitoring, and consistency in applying established requirements.

Finding: Allowable Costs/Cost Principles (Material Noncompliance; Material Weakness) Federal Assistance Listing Number 93.600 – Head Start Cluster Award Number – 90CI01001401C3, 90CI010014-02-02, 90HA0008601C6, 90HA00008601C5, 90C101001403, & 90C101001404; Award Year 2020, 2021, & 2022 Criteria: According to 45 CFR sections 75.403, 75.404, and 75.405 costs must meet general allowability criteria, including being necessary and reasonable for the performance of the federal award, allocable thereto and adequately documented. Condition: The Department did not have adequate documentation to support the recoding of certain expenditures from a nonfederal fund to the Headstart program. Questioned Costs: None Context: The Department was unable to provide supporting documentation for $25,467 for one of 25 items sampled. Further review by the Department identified similar unsupported expenditures for a total of $169,339. While these expenditures were included in the original schedule of expenditure of federal awards and expenditure population for the program, they had not been drawn down or reported to the federal agency. Therefore, no questioned costs are being reported. A non-statistical sampling methodology was used to select the sample. Effect: Without the appropriate supporting documentation, the Department is unable to ensure the expenditure is coded to the proper Federal award or fund and the Department was not in compliance with the Uniform Guidance. Further, adjustments to the program's financial records and the schedule of expenditures of federal awards were required. Cause: The Department attempted to reallocate expenditures based on allowable and available funding sources but failed to maintain an adequate audit trail. Identification as a Repeat Finding: N/A Recommendation: We recommend the Department implement a control to ensure adequate supporting documentation exists for any reallocation of expenditures impacting federal funding. Viewed of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.

Finding: Reporting (Significant Deficiency) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Numbers – B-18-SR-40-0584, B-19-SR-40-0584; Award Years 2018, 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Numbers – 8L-SS-2021-0901-001; Award Year 2021 Federal Assistance Listing Number 93.600 - Head Start Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Award Numbers - 90CI010014-03-00 & 90CI010014-03-02; Award Year 2022 Federal Assistance Listing Numbers 93.575 and 93.596 - CCDF Cluster Award Numbers - 21PBOKCSC6, 21POOKCDC6, 21PBOKCCC5, 21PBOKCCDF, 20PBOKCCDD, 20PBOKCCDF, 22PBOKCCDD, 22PBOKCCDF; Award Years 2020, 2021, 2022 Criteria or Specific Requirement: Management is responsible for establishing and maintaining effective internal controls over financial reporting. Effective internal controls are an important component of a system that helps ensure transactions are recorded timely and in the proper reporting period, thereby providing accurate financial data. Condition: The review of SF-425 reports was not supported by reviewer signature and date. Questioned Costs: None. Context: One quarterly SF-425 was reviewed from each of the five major programs. A non-statistical sampling methodology was used to select the samples. Effect: Failure to properly review SF-425 reports could result in inaccuracies going undetected and incorrect information being submitted to awarding agencies. Cause: The Department was not consistently documenting the review the SF-425 reports before submission. Identification as a Repeat Finding: N/A Recommendation: The Department should continue to develop and implement policies and procedures to ensure all SF-425 reports have been reviewed and such review is documented to ensure accuracy. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.

Finding: Procurement, Suspension and Debarment (Significant Deficiency; Other Matter) Federal Assistance Listing Number 14.862 – Indian Community Development Block Grant Award Number – B-18-SR-40-0584 & B-19-SR-40-0584; Award Year 2018 & 2019 Federal Assistance Listing Number 21.027 – Coronavirus State and Local Fiscal Recovery Funds Award Number – 8L-SS-2021-0901-001; Award Year 2021 Suspension and Debarment Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart C, 200.214 - Recipients and subrecipients are subject to the procurement, debarment and suspension regulations implementing Executive Orders 12549 and 12689, as well as 2 CFR part 180. The regulations in 2 CFR Part 180 restrict making Federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal awards. Procurement Criteria or Specific Requirement: According to 2 CFR Part 200, Subpart D, 200.321 - When possible, the recipient or subrecipient should ensure there is open competition for non-micro purchases and an equitable distribution among suppliers for micro purchases. Condition: The Tribe was unable to provide supporting documentation showing that a verification had been performed to ensure vendors were not suspended or debarred. Several large purchases were sole sourced without adequate documentation. A high volume of micro purchases were made from the same vendor rather than being distributed equitably amount a variety of vendors. Questioned Costs: None. Context: 14.862 - Three procurements were tested noting two in which suspension and debarment checks were not performed. A high volume of micro purchases ($148,908) were made from the same vendor rather than an equitable distribution of vendors. 21.027 - 14 procurements were tested. Ten procurements tested were subject to suspension and debarment of which checks were not performed on nine. All 14 procurements tested were subject to non-micro purchase requirements. Six procurements were sole sourced without adequate supporting documentation to support this method of purchase. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe's inability to furnish supporting documentation showing that a check to ensure vendors were not suspended or debarred on SAM.gov could result in the use of ineligible vendors. The Tribe's failure to provide for open competition or provide for an equitable distribution of vendors on purchases could result in the Tribe paying more for services than is reasonable or necessary. Cause: Tribal policies were not followed surrounding the requirement of suspension and debarment checks and documentation of sole source procurements. Due to the Tribal location, there may be some limitation of available vendors for consideration to ensure an equitable distribution. Identification as a Repeat Finding: 2021-005 (same issue in different program) Recommendation: We recommend the Department ensure existing procurement, suspension and debarment policies are understood throughout the Tribe and supporting documentation is adequate and maintained for all procurement decisions. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.

Finding: Equipment and Real Property Management (Other Matter) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Criteria: According to 48 CFR 52.245-1, a system of internal controls to manage federal property and a process to enable the prompt recognition, investigation, disclosure and reporting of loss of federal government property should be in place. Condition: An item paid for with federal funding was not identified as federal in the inventory listing. Questioned Costs: None. Context: One of five equipment items tested was not properly identified as federal in the inventory listing. A non-statistical sampling methodology was used to select the sample. Effect: Failure to properly identify federally funded equipment in the inventory listings could result in failure to disclose loss of property to the federal government if such should occur or in the inappropriate handling of proceeds should the property be sold. Cause: The funding source for the equipment in question was changed from nonfederal to federal and the inventory listing was inadvertently not updated. Identification as a Repeat Finding: N/A Recommendation: We recommend the Department ensure procedures are in place to ensure that all equipment funded with federal funds is properly identified in the inventory listings and that any changes in funding after the initial purchase are also properly reflected. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.

Finding: Reporting (Other Matter) Federal Assistance Listing Number 10.567 – Food Distribution Program on Indian Reservations Award Number – 202020Q900346, 202120Q900346, 202121Q520646, 202222Q520646, & 202323Q520646; Award Year 2020, 2021, & 2022 Criteria or Specific Requirement: According to Chapter I Section 5 - Records and Reporting of the FNS Handbook 501, the Tribe is required to mail, fax, or electronically transmit a completed copy of form FNS-101, Participation in Food Programs - By Race, to be received by the appropriate FNS Regional Office by September 15 of each year. Further, the FNS-152, Monthly Distribution of Donated Foods to Family Units, must be received in the appropriate FNS Regional Office by the 15th date of the month following the month in which the USDA foods were distributed. Condition: Both the FNS-101 form and the FMS-152 form were submitted subsequent to the required deadlines. Questioned Costs: None. Context: The FNS-101 form required to be received by September 15, 2022 was not submitted until September 21, 2022. The FNS-152 required to be submitted by February 15, 2022 was not submitted until March 24, 2022. A non-statistical sampling methodology was used to select the samples. Effect: The Tribe is out of compliance with federal requirements and the awarding agency does not have timely information for evaluating programmatic results. Identification as a Repeat Finding: N/A Cause: Additional responsibilities absorbed by program director resulted in shifting priorities away from reporting deadline. Recommendation: We recommend that program personnel continue to implement policies and procedures that prioritize the federal reporting functions as needed in order to submit reports within the required timelines. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.

Finding: Procurement, Suspension and Debarment Federal Assistance Listing Number 20.205 – Highway Planning and Construction (Federal-Aid Highway Program) Award Number – A17AP00029; Award Year 2017 Criteria: According to 2 CFR Part 180.300 – The non-federal entity must establish procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Such procedures can include (a) reviewing SAM.gov for exclusions, (b) collecting a certification from the entity, (c) adding a clause or condition to the covered transaction. Condition: The Department did not have documentation that the internal controls in place over suspension and debarment were followed. Questioned Costs: None. Context: The Department was unable to provide supporting documentation that the internal controls in place over suspension and debarment regarding entering into covered transactions were followed during 2021, which include reviewing the entity’s status in SAM.gov. Effect: Without the appropriate supporting documentation, the Department is unable to ensure it has not entered into a transaction with a suspended or debarred party. Cause: The Department experienced turnover during fiscal year 2021 and supporting documentation could not be located. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend the Department ensure suspension and debarment status is verified in accordance with Department policy. Additionally, supporting documentation should be maintained within the contracting file. Views of Responsible Officials: The Department agrees with the finding. See separate report for planned corrective actions.

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