Inter-Tribal Council of Nevada, Inc.Non-Profit

Condition and Context: As noted in findings 2022-001, 2022-003, 2022-004, 2022-005, 2022-006 and 2022-007, ITCN’s internal control over financial reporting and grants management was insufficient to provide the level of assurance necessary to demonstrate compliance with the federal awards. Criteria: 2 CFR §200.303 and 45 CFR §75.303, Internal Controls, requires that non-federal entities 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 comply 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). Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is that ITCN’s financial management system was insufficient to provide accurate financial information with reasonable assurance that ITCN is managing its awards in compliance with federal statutes, regulations and terms and conditions of its federal awards. Recommendation: We recommend that ITCN implement the recommendations noted in findings 2022-001, 2022-003, 2022-004, 2022-005, 2022-006 and 2022-007. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.

Condition and Context: ITCN did not file Form ACF-696T reports, required by the Child Care and Development Block Grant within the required timeframe. ITCN also did not file Form SF-429(A), required by the Head Start program within the required timeframe. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2022, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.328 and 45 CFR §75.341, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end and the annual single audit reporting package within 9 months of the fiscal year-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A) within the required timeframe. Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.

Condition and Context: As noted in finding 2022-002, ITCN had cash deficit in the amount of $35,398, while also reporting a total deferred revenue of $1,187,084 and a due to grantor agency of $269,375. At September 30, 2022, the WIC program is reporting deferred revenues of $289,963 while reflecting an amount loaned to other funds relating to these restricted sources totaling $60,455. Also, at September 30, 2022, the Child Care and Development Block Grant program is reporting deferred revenues of $198,541 while reflecting an amount loaned to other funds relating to these restricted sources totaling $828,529. As a result, ITCN is not in compliance with their contracts governing the use of these restricted funds. Criteria: 2 CFR §200.305 and 45 CFR §75.305, Federal Payment, requires that non-federal entities establish written policies so that advance payments are as close as administratively feasible to the actual disbursements for direct program or project costs. Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is the use of restricted cash to fund other expenses not related to the restricted purpose. Recommendation: We recommend that ITCN implement the recommendations noted in finding 2022-002. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.

Condition and Context: For FAL 10.557, the program guidelines require each agency to provide nutrition education to each participant and document nutritional risk of each participant. For FAL 93.575, the program guidelines require ITCN to create a sliding scale of copayments and establish a payment rate schedule for parents. Context Condition For FAL 10.557: 2 out of 40 participants tested Documentation was not available to evidence that a participant had received the required nutrition education. 1 out of 40 participants tested Documentation was not available to evidence that the participant had nutritional risk For FAL 93.575: 2 out of 40 participants tested Participants were charged a co-payment which was inconsistent with the sliding scale policy. Criteria: 7 CFR §246.11, Nutrition education, requires agencies to provide nutrition education, including breastfeeding promotion and support, as a benefit of the program at no cost to the participant. 7 CFR §246.7, Nutritional Risk, requires a competent professional authority to determine that an applicant is at nutritional risk. 45 CFR §98.45(b)(5), Equal access, requires the agency to create a sliding fee scale that is affordable and does not exceed 7 percent of income for all families. Cause and Effect: The cause is due to lack of resources and oversight at ITCN’s offices. The effect is potentially providing benefits to participants that are not eligible under the WIC and CCDF guidelines. Recommendation: We recommend that ITCN adhere to its policy of providing nutritional education to each participant. We also recommend that ITCN charges participants the correct amount according to the sliding scale of fees. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.

Condition and Context: The program guidelines require ITCN to verify the safety of all providers who receive subsidies from the program. For one of 14 providers tested, ITCN did not obtain evidence that the provider was licensed in the State of Nevada to provide day care services. Criteria: 45 CFR §98.41, Health and Safety Requirements, requires agencies to certify that providers and their employees meet certain health and safety requirements. ITCN utilizes the State of Nevada’s child care center license to indicate compliance with these requirements. Cause and Effect: The cause is due to lack of resources and oversight. The effect is potentially providing subsidies to providers not in compliance with health and safety requirements. Recommendation: We recommend that ITCN adhere to its policy of only providing subsidies to State of Nevada licensed child care centers. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.

Condition and Context: As noted in findings 2021-001, 2021-003, and 2021-004, ITCN’s internal control over financial reporting and grants management was insufficient to provide the level of assurance necessary to demonstrate compliance with the federal awards. Criteria: 2 CFR §200.303, Internal Controls, requires that non-federal entities 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 comply 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). Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is that ITCN’s financial management system was insufficient to provide accurate financial information with reasonable assurance that ITCN is managing its awards in compliance with federal statutes, regulations and terms and conditions of its federal awards. Recommendation: We recommend that ITCN implement the recommendations noted in findings 2021-001, 2021-003, and 2021-004. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.

Condition and Context: ITCN filed the final amended report for grant no. 90CI010041-01 outside the required timeframe under the Head Start grant. ITCN also did not file Form SF-429(A), required by the Head Start program. Also, ITCN’s single audit reporting package for the fiscal year ended September 30, 2021, was not submitted to the Federal Audit Clearinghouse within nine months after ITCN’s year-end. Criteria: According to 2 CFR §200.327, Financial Reporting, information must be collected with the frequency required by the terms and conditions of the Federal award. The grants require the filing of quarterly reports within 30 days after the quarter-end. Cause and Effect: The cause is the lack of resources and turnover in personnel at ITCN. The effect is the late filing of the quarterly reports and the annual single audit reporting package, and, for Head Start, not reporting the real property status on the Form SF-429(A). Recommendation: We recommend that ITCN devote the necessary resources to the financial reporting process and establish a system of monitoring for the filing of all required reporting and that the executive director review the monitoring list on a regular basis consistent with the timing of report filings. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.

Condition and Context: As noted in finding 2021-002, ITCN had cash balances in the amount of $470,318, while also reporting a total deferred revenue of $1,377,071 and a due to grantor agency of $269,375. At September 30, 2021, the WIC program is reporting deferred revenues of $292,379 while reflecting an amount loaned to other funds relating to these restricted sources totaling $227,217. Also, at September 30, 2021, the Child Care and Development Block Grant program is reporting deferred revenues of $416,668 while reflecting an amount loaned to other funds relating to these restricted sources totaling $889,729. As a result, ITCN is not in compliance with their contracts governing the use of these restricted funds. Criteria: 2 CFR §200.305, Federal Payment, requires that non-federal entities establish written policies so that advance payments are as close as administratively feasible to the actual disbursements for direct program or project costs. Cause and Effect: The cause is a lack of resources and oversight of the accounting and financial reporting process. The effect is the use of restricted cash to fund other expenses not related to the restricted purpose. Recommendation: We recommend that ITCN implement the recommendations noted in finding 2021-002. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.

Condition and Context: The program guidelines require each agency to provide nutrition education to each participant. For one of forty participants tested, documentation was not available to evidence that a participant had received the required nutrition education. Criteria: 7 CFR §246.11, Nutrition education, requires agencies to provide nutrition education, including breastfeeding promotion and support, as a benefit of the program at no cost to the participant. Cause and Effect: The cause is due to lack of resources and oversight at ITCN’s offices. The effect is potentially providing benefits to participants that are not eligible under the WIC guidelines. Recommendation: We recommend that ITCN adhere to its policy of providing nutrition education to each participant. Management’s Response: ITCN’s responsible officials’ views and planned corrective action are in its corrective action plan at the end of the report.