United Keetoowah Band of Cherokee Indians in OklahomaTribal Government

2021-003 Criteria: Uniform Guidance requires that costs must be adequately documented and retained to demonstrate that only costs for allowable activities or allowable costs are charged to federal programs. Documentation should also support that expenditures are incurred during the period of availability and prior to submission for reimbursement. Condition: For the Child Care Development Fund (CCDF) program, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Out of the ten transactions tested for this program, adequate supporting documentation could not be provided for six transactions. For the Self-Governance program, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Out of the ten transactions tested for this program, adequate supporting documentation could not be provided for five transactions. For the Relief Fund COVID19 program, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Out of the 25 transactions tested for this program, adequate supporting documentation could not be provided for 14 transactions. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to federal programs. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to federal programs. Questioned Costs: Known questioned costs were $29,104 for the CCDF program, $54,254 the Self-Governance program, $137,575 for the Relief Fund COVID19. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.

2021-004 Criteria: Uniform Guidance requires that charges to cost pools that are allocated wholly or partially to Federal awards or used in formulating indirect cost rates used for recovering indirect costs under Federal Awards are in conformance with 2 CFR sections 200.402 through 200.411. Condition: For the Department’s indirect cost pool, support could not be provided for costs charged to the program to support the allowability of costs and activities and whether the charges were incurred during the appropriate period of performance. Due to the allowability testing issues documented in the findings above, testing over the indirect cost pool was not able to be completed. Cause: The Department did not have adequate internal controls to ensure documentation was maintained to support costs charged to the Department’s indirect cost pool. Effect: Certain costs could not be supported as allowable, incurred during the appropriate period of performance, or incurred prior to submission for reimbursement were charged to the indirect cost pool. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.

2021-005 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Condition: The Department was able to provide a procurement policy, but it was dated in 2003 and not updated for the latest federal guidelines noted in the criteria paragraph. Cause: The Department does not have internal controls in place surrounding procurement policies and procedures. Effect: The lack of internal controls surrounding the procurement policies and procedures could lead to potential funding issues in the future. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.

2021-006 Criteria: For the Public Law 102-477 requires an annual financial expenditure report (version 2) (OMB Control No. 1076-0135) to be submitted for each plan period until all funds available for the plan period have been fully expended and reported. Condition: For the CCDF program, the annual financial expenditure report was not made available for audit testing. Cause: The CCDF program needs to increase internal controls surrounding the reporting process. Effect: The lack of filing of required reports could lead to questioned costs and potential issues with future grant funding. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.

2021-007 Criteria: Each prime recipient of the Fund shall provide a quarterly financial progress report that contains COVID-19 related costs incurred during the covered period (the beginning on March 1, 2020; and ending on December 31, 2021) to Treasury OIG. Each prime recipient shall report this quarterly information mentioned above into the GrantSolutions Portal. The prime recipient’s quarterly Financial Progress Report submissions should be supported by the data in the prime recipient’s accounting system. Condition: Coronavirus Relief Fund program, the quarterly financial progress reports were not made available for audit testing. Cause: The Coronavirus Relief Fund program needs to increase internal controls surrounding the reporting process. Effect: The lack of filing of required reports could lead to questioned costs and potential issues with future grant funding. Questioned Costs: None. Recommendation: We recommend that management continue to implement additional control processes in order to ensure proper controls are in place and followed. Tribal Response: Management agrees with this finding.