EIN: 850168672
UEI: N3N8W6JSCLN5
Audited by: Jaramillo Accounting Group
Oversight agency: 17 [Department of Labor]
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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 March 31, 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 October 1, 2026 (30 days from today).
What is a management decision? →FAC accepted this audit on June 12, 2025 — management decision was due December 12, 2025.
NIYC did not submit their Single Audit reporting package (financial statements, data collection form,and corrective action plan) within the required time period. Criteria: 2 CFR 200.512 stipulates the requirement that the Single Audit reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Effect: Late reporting could cause additional oversight or restriction by the U.S. Department of Labor. Cause: Due to turnover, internal controls were not properly designed, executed, and monitored to ensure a timely preparation of reports and records for audit purposes. As a result, management did not comply with the submission requirements of 2 CFR 200.512.
Show full finding ▾Hide full finding ▴2024-001 ( 2023-002) LATE FILING OF THE SINGLE AUDIT REPORTING PACKAGE WITH THE FEDERAL AUDIT CLEARINGHOUSE - REPEATED Federal Agency: U.S. Department of Labor Federal Program and Assistance Listing Number: WIOA Cluster 17.265 Native American Employment and Training Type of Finding: Significant Deficiency, Non-compliance Compliance Area: Reporting Award Period: FY24 Questioned Cost: None Condition: NIYC did not submit their Single Audit reporting package (financial statements, data collection form,and corrective action plan) within the required time period. Criteria: 2 CFR 200.512 stipulates the requirement that the Single Audit reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period. Effect: Late reporting could cause additional oversight or restriction by the U.S. Department of Labor. Cause: Due to turnover, internal controls were not properly designed, executed, and monitored to ensure a timely preparation of reports and records for audit purposes. As a result, management did not comply with the submission requirements of 2 CFR 200.512.
Recommendation We recommend that management enhance its internal control structure, including financial close and reporting, to ensure timely filing of future Single Audit reporting packages. Management Response Corrective Action: NIYC has been working towards getting caught up on the timely audit completion requirement as per the 2CFR 200.512, including the retention of a larger audit firm to schedule and complete the audit in a more timely manner. We have also implemented a monthly and year-end closing process to facilitate filing of future Single Audit reporting packages. Due Date of Completion:March 31, 2026 Responsible Person(s): NIYC Management
2023-002
1 out of 40 sampled applications lacked sufficient documentation to support eligibility under WIOA Section 166. Specifically, the file was missing verification of tribal affiliation, proof of residency, and documentation of public assistance status. Criteria: Per 2 CFR §200.303 and §200.430, recipients of federal funds must establish and maintain effective internal controls to ensure compliance with federal statutes, regulations, and the terms and conditions of the award. The NIYC-WIOA Policy Manual requires that eligibility determinations be supported by verifiable documentation, including tribal enrollment records, residency verification, and evidence of low-income or public assistance status. Effect: Failure to maintain complete eligibility documentation may result in noncompliance with federal program requirements, potential disallowed costs, and increased risk of audit findings or funding claw backs. Cause: The missing documentation was attributed to a participant file being misplaced during a staff transition, indicating a lack of centralized and secure file management protocols.
Show full finding ▾Hide full finding ▴2024-002 INSUFFICIENT WIOA ELIGIBILITY DOCUMENTATION Federal Agency: U.S. Department of Labor Federal Program and Assistance Listing Number: 17.265 Type of Finding: Significant Deficiency, Non-compliance Compliance Area: Eligibility Award Period: National Employment and Training (07/01/2022-06/30/2025) National Employment and Training (06/01/2023-06/30/2026) Questioned Costs: None Condition: 1 out of 40 sampled applications lacked sufficient documentation to support eligibility under WIOA Section 166. Specifically, the file was missing verification of tribal affiliation, proof of residency, and documentation of public assistance status. Criteria: Per 2 CFR §200.303 and §200.430, recipients of federal funds must establish and maintain effective internal controls to ensure compliance with federal statutes, regulations, and the terms and conditions of the award. The NIYC-WIOA Policy Manual requires that eligibility determinations be supported by verifiable documentation, including tribal enrollment records, residency verification, and evidence of low-income or public assistance status. Effect: Failure to maintain complete eligibility documentation may result in noncompliance with federal program requirements, potential disallowed costs, and increased risk of audit findings or funding claw backs. Cause: The missing documentation was attributed to a participant file being misplaced during a staff transition, indicating a lack of centralized and secure file management protocols.
Recommendation Implement a centralized, access-controlled digital system for participant file storage. Additionally, management should require the use of a standardized eligibility checklist and conduct periodic file audits to ensure documentation completeness and compliance with WIOA requirements. Management Response Corrective Action: In response to this incident, we have reinstated the Eligibility Determination and Intake (EDIR) Form. This form clearly states the participant identification information, the characteristics tracked by our program data management tool (GPMS), and states what has been provided by the participant to determine their eligibility for the program. Provided in a check list format, the form clearly demonstrates what makes the participant eligible for our program services. The form also lists the documentation included in the application that has been provided by the participant. This form added to the program application and maintained in the participant's official record will ensure that all WIOA eligibility documentation has been received, reviewed, and approved at the time of intake. Due Date of Completion: Completed as of May 31, 2025 Responsible Person(s):Director of Programs and Development is responsible for re-instating the use of the form and the Field Office Managers and Job Developers are responsible for filling out the form and including it in the participant's official record.
Our testing of payroll disbursements identified the following exceptions: -One (1) out of 45 payroll transactions lacked supporting documentation for an approved pay rate change. -One (1) out of 45 payroll transactions resulted in an overpayment for 52 hours instead of the authorized 20 hours. Criteria: Per 2 CFR §200.430 and NIYC's Fiscal Manual, all payroll transactions must be supported by appropriate documentation, including approved personnel action forms for rate changes and verified timesheets. Payroll must be reviewed and approved by designated personnel prior to processing. Effect: These deficiencies increase the risk of financial loss, inaccurate payroll reporting, and noncompliance with federal cost principles. They also undermine the reliability of internal controls over payroll processing. Cause: The overpayment was due to a clerical error in the Work Experience (WEX) timesheet process. The missing pay rate documentation was not retained during a period of organizational restructuring.
Show full finding ▾Hide full finding ▴2024-003 INSUFFICIENT PAYROLL AUTHORIZATION AND TIMESHEET CONTROLS Federal Agency: U.S. Department of Labor Federal Program and Assistance Listing Number: 17.265 Type of Finding: Significant Deficiency, Non-compliance Compliance Area: Allowable Costs (Payroll) Award Period: National Employment and Training (07/01/2022-06/30/2025) National Employment and Training (06/01/2023-06/30/2026) Questioned Costs: None Condition: Our testing of payroll disbursements identified the following exceptions: -One (1) out of 45 payroll transactions lacked supporting documentation for an approved pay rate change. -One (1) out of 45 payroll transactions resulted in an overpayment for 52 hours instead of the authorized 20 hours. Criteria: Per 2 CFR §200.430 and NIYC's Fiscal Manual, all payroll transactions must be supported by appropriate documentation, including approved personnel action forms for rate changes and verified timesheets. Payroll must be reviewed and approved by designated personnel prior to processing. Effect: These deficiencies increase the risk of financial loss, inaccurate payroll reporting, and noncompliance with federal cost principles. They also undermine the reliability of internal controls over payroll processing. Cause: The overpayment was due to a clerical error in the Work Experience (WEX) timesheet process. The missing pay rate documentation was not retained during a period of organizational restructuring.
Recommendation We recommend that NIYC strengthen its payroll controls by: Implementing a secondary review of WEX timesheets prior to payroll processing, - Requiring all pay rate changes to be documented using standardized personnel action forms, and -Conducting periodic payroll audits to verify compliance with documentation and approval requirements. Management Response Corrective Action: NIYC will strengthen internal controls over payroll by implementing additional monitoring and review processes. Going forward, the HR Accounting Coordinator will be responsible for an annual review of all staff employment files to ensure that all required documentation is present and up to date. Furthermore, no changes will be made to any employee pay rate without prior written approval and documentation using the standardized personnel action form. Once the change has been made in the payroll system, all approvals and documentation for the change in pay rate will be given to the HR Accounting Coordinator to include in the employee's file. We have also implemented a secondary review of WEX timesheets by the Accounting Manager during the payroll process. This should find and correct any errors in the spreadsheet used to summarize the timesheets and process WEX payroll. Due Date of Completion: Implementing new internal controls starting June 1, 2025 Responsible Person(s): Accounting Manager, HR Accounting Coordinator
FAC accepted this audit on May 21, 2025 — management decision was due November 21, 2025.
9 out of 30 requests for reimbursement from the federal grantor did not contain documented management review or approval.
Show full finding ▾Hide full finding ▴9 out of 30 requests for reimbursement from the federal grantor did not contain documented management review or approval.
NIYC has developed new policies and procedures around the requests for reimbursement from federal grantors. This will ensure that all requests for reimbursement are reviewed and approved before the request is submitted. It further requires sufficient supporting documentation for each request to be attached to aid in review and documentation.
2022-001
The single audit reporting package for the June 30, 2022 audit was submitted to the Federal Audit Clearinghouse after March 31, 2023.
Show full finding ▾Hide full finding ▴The single audit reporting package for the June 30, 2022 audit was submitted to the Federal Audit Clearinghouse after March 31, 2023.
NIYC has worked to get caught up with annual single audit submissions. Since developing the Accounting Manager position in 2022, NIYC has completed the single audit for 2021 and 2022. We are currently working with our auditor to start the 2023 audit in a timely manner so that it can be submitted on time. NIYC is committed to prioritizing our annual single audits to ensure that moving forward, they will be submitted on time.
2022-002
3 out of 50 eligibility determination applications were missing management approval. 1 out of 44 program participant check disbursements selected for testing did not contain the required dual signature.
Show full finding ▾Hide full finding ▴3 out of 50 eligibility determination applications were missing management approval. 1 out of 44 program participant check disbursements selected for testing did not contain the required dual signature.
NIYC has developed new policies and procedures that clearly state that two signers are required for each check and who is authorized to sign checks. Furthermore, NIYC has had a transition of leadership. During the transition, it was communicated the requirement of having two signatures for each check as well as any additional corrective action plans.
2022-003
FAC accepted this audit on March 19, 2025 — management decision was due September 19, 2025.
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See management’s response in in the schedule of findings and questioned costs
NIYC has developed new policies and procedures that clearly state that two signers are required for each check and who is authorized to sign checks. Furthermore, NIYC has had a transition of leadership. During the transition, it was communicated the requirement of having two signatures for each check as well as any additional corrective action plans.
Show full finding ▾Hide full finding ▴NIYC has developed new policies and procedures that clearly state that two signers are required for each check and who is authorized to sign checks. Furthermore, NIYC has had a transition of leadership. During the transition, it was communicated the requirement of having two signatures for each check as well as any additional corrective action plans.
See management’s response in in the schedule of findings and questioned costs
FAC accepted this audit on October 10, 2022 — management decision was due April 10, 2023.
2021-001 Federal Award Reporting Funding Agency: U.S. Department of Labor Title: Native American Employment and Training (WIOA) Assistance Listing#: 17.265 Award #: AB-34967-20-60-A-35 Award Period: 07/01/2020 ? 06/30/2023 Estimated Questioned Cost: N/A Statement of Condition ? Quarterly Federal reporting required on form ETA-9130 for the quarters ended September 30, 2020, and December 31, 2020, did not contain the required financial information. Criteria Grant conditions require the quarterly reporting of programmatic activities, cash receipts, and cash disbursements, no later than 45 days after the end of the quarter. Cause Unknown Effect Grant related financial transactions were not properly reported to the Department of Labor. Recommendation We recommend that management establish procedures to ensure the required federal reporting be made on a timely basis and be reconciled to the underlying financial statements prior to submission. Response Quarterly reporting is a more refined process. QuickBooks Office has significantly helped our reporting. The Executive Director, Director of Planning and Accounting Manager are each involved with the process to ensure that quality reports are submitted in a timely manner.
Show full finding ▾Hide full finding ▴2021-001 Federal Award Reporting Funding Agency: U.S. Department of Labor Title: Native American Employment and Training (WIOA) Assistance Listing#: 17.265 Award #: AB-34967-20-60-A-35 Award Period: 07/01/2020 ? 06/30/2023 Estimated Questioned Cost: N/A Statement of Condition ? Quarterly Federal reporting required on form ETA-9130 for the quarters ended September 30, 2020, and December 31, 2020, did not contain the required financial information. Criteria Grant conditions require the quarterly reporting of programmatic activities, cash receipts, and cash disbursements, no later than 45 days after the end of the quarter. Cause Unknown Effect Grant related financial transactions were not properly reported to the Department of Labor. Recommendation We recommend that management establish procedures to ensure the required federal reporting be made on a timely basis and be reconciled to the underlying financial statements prior to submission. Response Quarterly reporting is a more refined process. QuickBooks Office has significantly helped our reporting. The Executive Director, Director of Planning and Accounting Manager are each involved with the process to ensure that quality reports are submitted in a timely manner.
Response Quarterly reporting is a more refined process. QuickBooks Office has significantly helped our reporting. The Executive Director, Director of Planning and Accounting Manager are each involved with the process to ensure that quality reports are submitted in a timely manner.
FAC accepted this audit on August 29, 2021 — management decision was due March 1, 2022.
2020-003?TRACKING OF GRANT EXPENSES IN ACCOUNTING SOFTWARE Type of Finding: (B and E) Significant Deficiency in Internal Control Over Financial Reporting and Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: U.S. Department of Labor Title: Native American Employment and Training (WIOA) CFDA #: 17.265 Award #: AB-29301-16-55-A-35, AB-32434-18-60-A-35, AB-33924-19-60-A-35 Award Periods: Multiple Estimated Questioned Costs: N/A Statement of Condition NIYC changed accounting software in fiscal year 2021 and began assigning grant expenses to the class function in the software. However, it was not completely functional. Our audit of grant expenses revealed that NIYC provides adequate support to the grantor when submitting reports under the grant. In addition to tracking the federal expenses by grant year, NIYC uses the classes to differentiate expenses by each field offices. However, the accounting software classes were not consistently used during the fiscal year when expenses occurred. As a result, there was a fiscal year end class adjustment attempting to correct the class expenses. However, the class expenses did not match the federal expenses reported in the SEFA, due to additional journal entries required to present the financial statements materially correct. The SEFA expenses were reviewed during the drawdown testing and determined to be accurate. Criteria The accounting system is the foundation for maintaining proper documentation for costs incurred on grants and by the field offices. A well-designed class coding procedure is necessary for proper tracking of expenses by grant in order to properly maintain a Schedule of Expenditures of Federal Awards. Additionally, NIYC can prepare Statements of Activities by class to accurately time drawdowns of federal funds, ensure budge accuracy, and facilitate the operations and Board oversight of NIYC. Cause NIYC hired an external accounting firm to provide bookkeeping services and they did not consistently use the "class" costing module during the fiscal year. Effect NIYC could inaccurately present individual field office costs, that costs may be overstated/understated, or not capture all costs allocable to the grant. Recommendation We recommend that NIYC fully utilize the class coding system in their accounting software as a foundation for tracking costs associated with the federal and non-federal grants. Additionally, we recommend that the classes are reviewed on at least a monthly basis to ensure accuracy.
Show full finding ▾Hide full finding ▴2020-003?TRACKING OF GRANT EXPENSES IN ACCOUNTING SOFTWARE Type of Finding: (B and E) Significant Deficiency in Internal Control Over Financial Reporting and Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: U.S. Department of Labor Title: Native American Employment and Training (WIOA) CFDA #: 17.265 Award #: AB-29301-16-55-A-35, AB-32434-18-60-A-35, AB-33924-19-60-A-35 Award Periods: Multiple Estimated Questioned Costs: N/A Statement of Condition NIYC changed accounting software in fiscal year 2021 and began assigning grant expenses to the class function in the software. However, it was not completely functional. Our audit of grant expenses revealed that NIYC provides adequate support to the grantor when submitting reports under the grant. In addition to tracking the federal expenses by grant year, NIYC uses the classes to differentiate expenses by each field offices. However, the accounting software classes were not consistently used during the fiscal year when expenses occurred. As a result, there was a fiscal year end class adjustment attempting to correct the class expenses. However, the class expenses did not match the federal expenses reported in the SEFA, due to additional journal entries required to present the financial statements materially correct. The SEFA expenses were reviewed during the drawdown testing and determined to be accurate. Criteria The accounting system is the foundation for maintaining proper documentation for costs incurred on grants and by the field offices. A well-designed class coding procedure is necessary for proper tracking of expenses by grant in order to properly maintain a Schedule of Expenditures of Federal Awards. Additionally, NIYC can prepare Statements of Activities by class to accurately time drawdowns of federal funds, ensure budge accuracy, and facilitate the operations and Board oversight of NIYC. Cause NIYC hired an external accounting firm to provide bookkeeping services and they did not consistently use the "class" costing module during the fiscal year. Effect NIYC could inaccurately present individual field office costs, that costs may be overstated/understated, or not capture all costs allocable to the grant. Recommendation We recommend that NIYC fully utilize the class coding system in their accounting software as a foundation for tracking costs associated with the federal and non-federal grants. Additionally, we recommend that the classes are reviewed on at least a monthly basis to ensure accuracy.
2020-003?TRACKING OF GRANT EXPENSES IN ACCOUNTING SOFTWARE Type of Finding: (B and E) Significant Deficiency in Internal Control Over Financial Reporting and Significant Deficiency in Internal Control Over Compliance of Federal Awards Funding Agency: U.S. Department of Labor Title: Native American Employment and Training (WIOA) CFDA #: 17.265 Award #: AB-29301-16-55-A-35, AB-32434-18-60-A-35, AB-33924-19-60-A-35 Award Periods: Multiple Estimated Questioned Costs: N/A Corrective Action Plan NIYC plans to make full use of the class coding system in our accounting software. Our new accounting firm is working with our accounting technician to make sure that all of our FY 2020 numbers and beyond are classed properly in QuickBooks. Our accountant has assured us that for the current fiscal year going forward everything should be classed properly and she will work with us to try to get the FY2020 numbers as accurate as possible.
FAC accepted this audit on March 23, 2020 — management decision was due September 23, 2020.
2019-002 ?FEDERAL GRANT NON-COMPLIANCE AND SUSPECTED WORK EXPERIENCE FRAUD Type of Finding: E, F Funding Agency: U.S. Department of Labor Title: Native American Employment and Training (WIOA) CFDA #: 17.265 Award #: AB-29301-16-55-A-35, AB-32434-18-60-A-35 Award Periods: Fiscal Years 2016-2020 Estimated Questioned Costs: $14,574 Statement of Condition In October 2019 the Executive Director was made aware of allegations related to fraud being committed by the Field Office Manager and Job Developer of the Gallup Field Office (GFO). The Executive Director along with the Director of Programs and Development of NIYC conducted an internal investigation. The allegations were that employees of NIYC?s Gallup Field Office were certifying and compensating work experience (WEX) activities, which appear to not have taken place. The following summarizes results of the internal investigation and related findings: ? The Field Office Manager?s son was no longer working at the McKinley County Humane Society as a Work Experience (WEX) intern, after July 22, 2019, yet the GFO Field Office Manager and Job Developer continued to indicate in his case records and on his timesheets that he was placed and working there as an Animal Care Taker Intern until August 23, 2019. Both supervisors at the Humane Society indicated that the last entries on their sign in/sign out documents indicated that July 22, 2019, was the last sign in/sign out they had for the Field Office Manager?s son, yet, there are numerous entries in his case files signed by the GFO Job Developer that he was still there beyond that date and several entries stating that his supervisors said he was doing a good job. Both the GFO Field Office Manager and Job Developer signed off on timesheets, indicating he was working at the Humane Society, that continued until August 23, 2019, with him being paid for an average of 32 hours for each of those weeks. Total estimated WEX wages paid for the time period 7/23/19 to 8/23/19: $1,245.15. ? The Field Office Manager?s current husband was paid for working at the Southwest Indian Foundation as a WEX intern from 10/01/2018 to 1/25/2019. A visit and follow-up call to the Southwest Indian Foundation?s Housing Coordinator, indicated that she had no recollection of a Roland Begay working there and that the sign in/sign out sheets there for employees/volunteers/interns did not show him ever checking in and out during that timeframe. Both the GFO Field Office Manager and Job Developer signed off on timesheets indicating he was working there that entire time period. They both made entries and case notes throughout his ?participant enrollment and post-exit follow-ups? that stated he was working at the SW Foundation when he was not. Total estimated WEX wages paid for the time period: $4,126.11. ? The Job Developer?s boyfriend was paid for working at the Southwest Indian Foundation as a WEX intern from 11/14/2016 to April 2017, when he was not working there. A visit and followup call to the Southwest Indian Foundation?s Housing Coordinator, indicated that she had no recollection of the Job Developer?s boyfriend working there and that the sign in/sign out sheets there for employees/volunteers/interns did not show him ever checking in and out during that timeframe. Both the GFO Field Office Manager and Job Developer signed off on timesheets indicating he was working there the entire time period. They both made entries and case notes throughout his ?participant enrollment and post-exit follow-ups? that stated he was working at the SW Foundation when he was not. Total estimated WEX wages paid for the time period: $4,597.15. ? A friend of the Field Office Manager was paid for working at the Southwest Indian Foundation as a WEX intern from 02/13/2017 to 06/15/2017, when he had not worked there. A visit and follow-up call to the Southwest Indian Foundation?s Housing Coordinator, indicated that she had no recollection of the friend working there and that the sign in/sign out sheets there for employees/volunteers/interns did not show him ever checking in and out during that timeframe. Both the GFO Field Office Manager and Job Developer signed off on timesheets indicating he was working there the entire time period. They both signed case file records for follow-ups and case notes throughout his ?participant enrollment and post-exit follow-ups.? Total estimated WEX wages paid for the time period: $4,605.82. The findings of the internal investigation were reported to the Board of Directors on December 12, 2019 and subsequently terminated the two identified NIYC employees from the Gallup Field Office. There have been changes in procedure and corrective actions which are now being implemented. Criteria NIYC allows family members and significant others of its staff to be WIOA participants if they satisfy all relevant eligibility criteria. However, the standard practice has been that the related employee is not to directly supervise the participant or manage their case in the program. Further, other, non-related, staff are to approve and sign off on paperwork related to the participant. NIYC policies prohibit falsifying timesheet and records information. Per the NIYC Employee handbook, Section XVIII (C)(12). Under the Workforce Innovation Opportunity Act, Part 684 - Indian and Native American Programs, Section 684.340(b) states that INA grantee participants cannot be paid for training activities they do not participate in, unless for good cause. Cause Employees at the Gallup Field Office worked together to circumvent the controls. Effect The U.S. Department of Labor could request compensation for unallowed expenses. The U.S. Department of Labor could reduce or stop funding NIYC. Recommendation Management has identified changes in procedures and corrective actions, which we agree with and recommend. 1. NIYC will now require that MIS staff and the Director of Programs randomly pull files on a regular basis to verify WEX participant placements and worksite agreements, in addition to the monitoring and verifications that happen at the local field office levels. This basically adds another layer of review and oversight. 2. Additionally and more importantly, all NIYC staff family member/significant other participant activities and assistance such as Supportive Services, WEX/CT placements and case files/documents will be closely monitored by upper level NIYC administration and MIS department personnel throughout their enrollment period and post-exit follow-up periods to ensure that all NIYC and WIOA policies/regulations are being complied with on a regular basis as well.3. All staff will be counseled and reminded that any and all family member participant enrollments and services cannot be handled/managed/provided by them and that they will be closely monitored. Non-related staff and NIYC upper level administration must oversee those cases. View of Responsible Official 1. NIYC has implemented policies that now require that MIS staff and the Director of Programs randomly pull files on a regular basis to verify WEX participant placements and worksite agreements, in addition to the monitoring and verifications that happen at the local field office levels. This basically adds another layer of review and oversight. 2. Additionally, and more importantly, NIYC requires that its staff clearly identify and inform management of all participants who are immediate family members or significant others. NIYC staff are aware that ALL NIYC staff family member/significant other participant activities and assistance such as Supportive Services, WEX/CT placements and case files/documents will be closely monitored by upper level NIYC administration and MIS department personnel throughout their enrollment period and post-exit follow up periods to ensure that all NIYC and WIOA policies/regulations are being complied with on a regular basis as well. 3. All staff will be counseled and reminded that any and all family member participant enrollments and services cannot be handled/managed/provided by them and that they will be closely monitored. Non-related staff and NIYC upper level administration must oversee those cases and sign/initial all related program documents/forms for those participants.
Show full finding ▾Hide full finding ▴2019-002 ?FEDERAL GRANT NON-COMPLIANCE AND SUSPECTED WORK EXPERIENCE FRAUD Type of Finding: E, F Funding Agency: U.S. Department of Labor Title: Native American Employment and Training (WIOA) CFDA #: 17.265 Award #: AB-29301-16-55-A-35, AB-32434-18-60-A-35 Award Periods: Fiscal Years 2016-2020 Estimated Questioned Costs: $14,574 Statement of Condition In October 2019 the Executive Director was made aware of allegations related to fraud being committed by the Field Office Manager and Job Developer of the Gallup Field Office (GFO). The Executive Director along with the Director of Programs and Development of NIYC conducted an internal investigation. The allegations were that employees of NIYC?s Gallup Field Office were certifying and compensating work experience (WEX) activities, which appear to not have taken place. The following summarizes results of the internal investigation and related findings: ? The Field Office Manager?s son was no longer working at the McKinley County Humane Society as a Work Experience (WEX) intern, after July 22, 2019, yet the GFO Field Office Manager and Job Developer continued to indicate in his case records and on his timesheets that he was placed and working there as an Animal Care Taker Intern until August 23, 2019. Both supervisors at the Humane Society indicated that the last entries on their sign in/sign out documents indicated that July 22, 2019, was the last sign in/sign out they had for the Field Office Manager?s son, yet, there are numerous entries in his case files signed by the GFO Job Developer that he was still there beyond that date and several entries stating that his supervisors said he was doing a good job. Both the GFO Field Office Manager and Job Developer signed off on timesheets, indicating he was working at the Humane Society, that continued until August 23, 2019, with him being paid for an average of 32 hours for each of those weeks. Total estimated WEX wages paid for the time period 7/23/19 to 8/23/19: $1,245.15. ? The Field Office Manager?s current husband was paid for working at the Southwest Indian Foundation as a WEX intern from 10/01/2018 to 1/25/2019. A visit and follow-up call to the Southwest Indian Foundation?s Housing Coordinator, indicated that she had no recollection of a Roland Begay working there and that the sign in/sign out sheets there for employees/volunteers/interns did not show him ever checking in and out during that timeframe. Both the GFO Field Office Manager and Job Developer signed off on timesheets indicating he was working there that entire time period. They both made entries and case notes throughout his ?participant enrollment and post-exit follow-ups? that stated he was working at the SW Foundation when he was not. Total estimated WEX wages paid for the time period: $4,126.11. ? The Job Developer?s boyfriend was paid for working at the Southwest Indian Foundation as a WEX intern from 11/14/2016 to April 2017, when he was not working there. A visit and followup call to the Southwest Indian Foundation?s Housing Coordinator, indicated that she had no recollection of the Job Developer?s boyfriend working there and that the sign in/sign out sheets there for employees/volunteers/interns did not show him ever checking in and out during that timeframe. Both the GFO Field Office Manager and Job Developer signed off on timesheets indicating he was working there the entire time period. They both made entries and case notes throughout his ?participant enrollment and post-exit follow-ups? that stated he was working at the SW Foundation when he was not. Total estimated WEX wages paid for the time period: $4,597.15. ? A friend of the Field Office Manager was paid for working at the Southwest Indian Foundation as a WEX intern from 02/13/2017 to 06/15/2017, when he had not worked there. A visit and follow-up call to the Southwest Indian Foundation?s Housing Coordinator, indicated that she had no recollection of the friend working there and that the sign in/sign out sheets there for employees/volunteers/interns did not show him ever checking in and out during that timeframe. Both the GFO Field Office Manager and Job Developer signed off on timesheets indicating he was working there the entire time period. They both signed case file records for follow-ups and case notes throughout his ?participant enrollment and post-exit follow-ups.? Total estimated WEX wages paid for the time period: $4,605.82. The findings of the internal investigation were reported to the Board of Directors on December 12, 2019 and subsequently terminated the two identified NIYC employees from the Gallup Field Office. There have been changes in procedure and corrective actions which are now being implemented. Criteria NIYC allows family members and significant others of its staff to be WIOA participants if they satisfy all relevant eligibility criteria. However, the standard practice has been that the related employee is not to directly supervise the participant or manage their case in the program. Further, other, non-related, staff are to approve and sign off on paperwork related to the participant. NIYC policies prohibit falsifying timesheet and records information. Per the NIYC Employee handbook, Section XVIII (C)(12). Under the Workforce Innovation Opportunity Act, Part 684 - Indian and Native American Programs, Section 684.340(b) states that INA grantee participants cannot be paid for training activities they do not participate in, unless for good cause. Cause Employees at the Gallup Field Office worked together to circumvent the controls. Effect The U.S. Department of Labor could request compensation for unallowed expenses. The U.S. Department of Labor could reduce or stop funding NIYC. Recommendation Management has identified changes in procedures and corrective actions, which we agree with and recommend. 1. NIYC will now require that MIS staff and the Director of Programs randomly pull files on a regular basis to verify WEX participant placements and worksite agreements, in addition to the monitoring and verifications that happen at the local field office levels. This basically adds another layer of review and oversight. 2. Additionally and more importantly, all NIYC staff family member/significant other participant activities and assistance such as Supportive Services, WEX/CT placements and case files/documents will be closely monitored by upper level NIYC administration and MIS department personnel throughout their enrollment period and post-exit follow-up periods to ensure that all NIYC and WIOA policies/regulations are being complied with on a regular basis as well.3. All staff will be counseled and reminded that any and all family member participant enrollments and services cannot be handled/managed/provided by them and that they will be closely monitored. Non-related staff and NIYC upper level administration must oversee those cases. View of Responsible Official 1. NIYC has implemented policies that now require that MIS staff and the Director of Programs randomly pull files on a regular basis to verify WEX participant placements and worksite agreements, in addition to the monitoring and verifications that happen at the local field office levels. This basically adds another layer of review and oversight. 2. Additionally, and more importantly, NIYC requires that its staff clearly identify and inform management of all participants who are immediate family members or significant others. NIYC staff are aware that ALL NIYC staff family member/significant other participant activities and assistance such as Supportive Services, WEX/CT placements and case files/documents will be closely monitored by upper level NIYC administration and MIS department personnel throughout their enrollment period and post-exit follow up periods to ensure that all NIYC and WIOA policies/regulations are being complied with on a regular basis as well. 3. All staff will be counseled and reminded that any and all family member participant enrollments and services cannot be handled/managed/provided by them and that they will be closely monitored. Non-related staff and NIYC upper level administration must oversee those cases and sign/initial all related program documents/forms for those participants.
Corrective Action Plan: 1. Effective on January 2, 2020, NIYC?s Executive Director (Tina Farrenkopf) has implemented policies that now require that the MIS specialist (Valencia Tsosie) and the Director of Programs (Lorraine Edmo) randomly pull files on a regular basis to verify WEX participant placements and worksite agreements, in addition to the monitoring and verifications that happen at the local field office levels. This basically adds another layer of review and oversight. 2. Additionally, and more importantly, effective January 2, 2020, the NIYC Executive Director (Tina Farrenkopf) requires that its staff clearly identify and inform management of all participants who are immediate family members or significant others. Additionally, NIYC staff are aware that ALL NIYC staff family member/significant other participant activities and assistance such as Supportive Services, WEX/CT placements and case files/documents will be closely monitored by the MIS specialist (Valencia Tsosie) and the Director of Programs (Lorraine Edmo) throughout their enrollment period and post-exit follow up periods to ensure that all NIYC and WIOA policies/regulations are being complied with on a regular basis as well. 3. Effective January 2, 2020, all staff were and will be counseled and reminded that any and all family member participant enrollments and services cannot be handled/managed/provided by them and that they will be closely monitored. Non-related NIYC upper level administration must oversee those cases and sign/initial all related program documents/forms for those participants. 4. On or before July 1, 2020, the NIYC Executive Director (Tina Farrenkopf) and its Board of Directors will revise its personnel policies and procedures to include provisions that require (1) its employees to identify and inform management of all participants who are immediate family members or significant others, and (2) will state that family member participant enrollments and services cannot be handled/managed/provided by related employees and that they will be closely monitored throughout their tie with the WIOA program.
FAC accepted this audit on March 24, 2019 — management decision was due September 24, 2019.
FAC accepted this audit on June 27, 2018 — management decision was due December 27, 2018.
GSA_MIGRATION
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Show full finding ▾Hide full finding ▴FAC accepted this audit on March 14, 2017 — management decision was due September 14, 2017.
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