EIN: 860817608
UEI: T9NZBMMWEQJ3
Audited by: SJT GROUP LLC
Oversight agency: 21 [Department of the Treasury]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on September 28, 2023. 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 March 28, 2024 (885 days ago).
What is a management decision? →NPH did not maintain cash and cash equivalents at least equal to the amount of unspent grant funds advanced from federal agencies at year-end. At September 30, 2022, NPH?s unrestricted cash and cash equivalents and unearned grant revenue (grants received in advance) totaled $380,195 and $1,321,280, respectively. As a result, unspent grant funds held by NPH exceeded the amount of available cash and cash equivalents by $941,085.
Show full finding ▾Hide full finding ▴NPH did not maintain cash and cash equivalents at least equal to the amount of unspent grant funds advanced from federal agencies at year-end. At September 30, 2022, NPH?s unrestricted cash and cash equivalents and unearned grant revenue (grants received in advance) totaled $380,195 and $1,321,280, respectively. As a result, unspent grant funds held by NPH exceeded the amount of available cash and cash equivalents by $941,085.
NPH made the decision to utilize CDFI funds to ensure seamless operations after considerable thought and extensive discussions with experts in the use of CDFI funds. We would not take such action without input from industry experts that NPH could lend CDFI funds to itself to continue its mission of providing education, lending and development/construction services to its clients. NPH made the decision to utilize CDFI funds to ensure seamless operations after considerable thought and extensive discussions with experts in the use of CDFI funds. We would not take such action without input from industry experts that NPH could lend CDFI funds to itself to continue its mission of providing education, lending and development/construction services to its clients. The reason NPH was placed in this unfortunate situation was the unprecedented inflationary period our nation has faced over the past 2 ? years. One impact was a 40% increase in the average cost of home construction. An additional impact was the unparalleled rise in home mortgage rates caused delays in closing homes constructed. This generated extensive carrying costs which NPH had to endure while homebuyers struggled to qualify and close on the homes they were purchasing. NPH believed its course of action would be supported by the following opportunities it was pursuing. NPH had been informed by Oweesta that it would be receiving a low interest (1.9%) only loan of $1.35 million combined with a $150,000 grant. In addition, NPH had received notice of a $1.55 million-dollar NACA grant, of which 15% could be used for operations. Furthermore, NPH had pre-qualified for a $1.55 million-dollar CDFI ERP grant of which 20% could be used for operations. Unfortunately, the NACA Grant came in over 1.5 years late, the Oweesta funds and the ERP grant did not materialize at all. NPH has reason to believe these last two funding sources did not come to fruition due to the 2021 Audit by Walker and Armstrong. On the positive side NPH has finally received its NACA Grant of $1.3 million dollars of which $225,000 can be used for operations. NPH has applied for a $400,000 grant from Wells Fargo Bank. Unfortunately, NPH has been placed in the position of moving away from its historical commitment of being chiefly focused on its mission to serve and has been forced into being more heavily focused on building its balance sheet first, mission second. With that, NPH has ceased its home construction operations at Karigan Estates to reduce risk and conserve financial capital. NPH and CWCP are only pursing construction opportunities that have a very high probability of providing substantial positive cash flow required to build its balance sheet. Construction opportunities that may provide significant positive cash flow are, but not limited to, are restroom additions approved by the Navajo Nation, the remodeling of restrooms for Navajo Nation administration buildings to become ADA compliant and providing construction services for the Navajo Nation Presidential Home.
NPH did not submit the annual federal reporting package within nine months after September 30, 2022.
Show full finding ▾Hide full finding ▴NPH did not submit the annual federal reporting package within nine months after September 30, 2022.
NPH is aware the implementation of outsourcing the accounting department required an extensive period of time to fully transition to the outsourced CPA firm. NPH has completed the transition and is now in a position to ensure the annual federal reporting package is submitted in a timely manner in the future.
FAC accepted this audit on October 25, 2022 — management decision was due April 25, 2023.
Criteria: 2 CFR ?200.303, Internal Controls, requires that non-federal entities establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and the conditions of the federal awards. These internal controls should follow 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). Condition and Context: As noted in findings 2021-001 through 2021-006, NPH?s internal control over financial reporting was insufficient to provide the level of assurance on compliance necessary to comply with Federal regulations. Cause: The cause is turnover, inadequate resources devoted to the accounting function, noncompliance with established policies and procedures and insufficient oversight by governance. Effect: The effect is that NPH?s financial management system was insufficient for managing its awards in compliance with Federal statutes, regulations and terms and conditions of Federal awards. Recommendation: We recommend that NPH implement the recommendations noted in findings 2021-001 through 2021-006.
Show full finding ▾Hide full finding ▴Criteria: 2 CFR ?200.303, Internal Controls, requires that non-federal entities establish and maintain effective internal control over the Federal awards that provides reasonable assurance that the non-federal entity is managing the Federal awards in compliance with Federal statutes, regulations, and the terms and the conditions of the federal awards. These internal controls should follow 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). Condition and Context: As noted in findings 2021-001 through 2021-006, NPH?s internal control over financial reporting was insufficient to provide the level of assurance on compliance necessary to comply with Federal regulations. Cause: The cause is turnover, inadequate resources devoted to the accounting function, noncompliance with established policies and procedures and insufficient oversight by governance. Effect: The effect is that NPH?s financial management system was insufficient for managing its awards in compliance with Federal statutes, regulations and terms and conditions of Federal awards. Recommendation: We recommend that NPH implement the recommendations noted in findings 2021-001 through 2021-006.
Assistance Listings Numbers: 21.012 and 21.024 Program Titles: Community Development Financial Institutions, Native Initiatives COVID-19 - Community Development Financial Institutions, Rapid Response Program Condition and Context: As noted in findings 2021-001 through 2021-006, NPH?s internal control over financial reporting was insufficient to provide the level of assurance on compliance necessary to comply with Federal regulations. Recommendation: The auditors recommended that NPH implement the recommendations noted in findings 2021-001 through 2021-006. Contact Name: Rollin Wood, Executive Director Corrective Action Planned: See NPH?s Corrective Action Plan to Findings 2021-001 through 2021-006 above. Anticipated Completion Date: December 31, 2022
Criteria: As a recipient of Community Development Financial Institutions Fund funding, NPH was required to submit its audited financial statements by March 31, 2022. In addition, the annual audit was required to be submitted to the Federal Single Audit Clearinghouse by June 30, 2022. Condition and Context: The weaknesses in internal control noted in finding 2021-001 resulted in unreliable accounting records that required significant analysis and correction. This resulted in the delay of the audit?s completion. Cause: The cause is turnover, inadequate resources devoted to the accounting function, noncompliance with established policies and procedures and insufficient oversight by governance. Effect: The effect is that NPH?s financial management system was insufficient to allow it to meet its reporting obligations. Recommendation: We recommend that NPH implement the recommendation noted in finding 2021-001.
Show full finding ▾Hide full finding ▴Criteria: As a recipient of Community Development Financial Institutions Fund funding, NPH was required to submit its audited financial statements by March 31, 2022. In addition, the annual audit was required to be submitted to the Federal Single Audit Clearinghouse by June 30, 2022. Condition and Context: The weaknesses in internal control noted in finding 2021-001 resulted in unreliable accounting records that required significant analysis and correction. This resulted in the delay of the audit?s completion. Cause: The cause is turnover, inadequate resources devoted to the accounting function, noncompliance with established policies and procedures and insufficient oversight by governance. Effect: The effect is that NPH?s financial management system was insufficient to allow it to meet its reporting obligations. Recommendation: We recommend that NPH implement the recommendation noted in finding 2021-001.
Assistance Listings Numbers: 21.012 and 21.024 Program Titles: Community Development Financial Institutions, Native Initiatives COVID-19 - Community Development Financial Institutions, Rapid Response Program Condition and Context: The weaknesses in internal control noted in finding 2021-001 resulted in unreliable accounting records that required significant analysis and correction. This resulted in the delay of the audit?s completion. Recommendation: The auditors recommended that NPH implement the recommendation noted in finding 2021-001. Contact Name: Rollin Wood, Executive Director Corrective Action Planned: See NPH?s Corrective Action Plan to Finding 2021-001 above. NPH has implemented a new financial management system and is utilizing an outside accounting firm to ensure that the NPH?s financial system is accurate and complete. Anticipated Completion Date: September 30, 2022
Criteria: CFR ?200.510(b) states that ?the auditee must also prepare the schedule of expenditures of federal awards for the period covered by the auditee?s financial statements?? The schedule of expenditures of federal awards (SEFA) should be complete and accurate in its reporting of expenditures of federal awards including the Federal Assistance Listing numbers, contract numbers and expenditures. Condition and context: NPH did not prepare an accurate SEFA for the fiscal year ended September 30, 2021. Expenditures for the Community Development Financial Institutions Program were overstated by $720,931. Cause: The cause was a lack of training on Federal compliance and reporting requirements. Effect: The effect was a schedule of expenditures of federal awards as received from NPH that was materially incorrect which delayed the audit?s issuance. Recommendation: We recommend that NPH either outsource the preparation of the schedule of expenditures of federal award to qualified organization or receive additional training on the reporting requirements.
Show full finding ▾Hide full finding ▴Criteria: CFR ?200.510(b) states that ?the auditee must also prepare the schedule of expenditures of federal awards for the period covered by the auditee?s financial statements?? The schedule of expenditures of federal awards (SEFA) should be complete and accurate in its reporting of expenditures of federal awards including the Federal Assistance Listing numbers, contract numbers and expenditures. Condition and context: NPH did not prepare an accurate SEFA for the fiscal year ended September 30, 2021. Expenditures for the Community Development Financial Institutions Program were overstated by $720,931. Cause: The cause was a lack of training on Federal compliance and reporting requirements. Effect: The effect was a schedule of expenditures of federal awards as received from NPH that was materially incorrect which delayed the audit?s issuance. Recommendation: We recommend that NPH either outsource the preparation of the schedule of expenditures of federal award to qualified organization or receive additional training on the reporting requirements.
Assistance Listing Numbers: 21.012 and 21.024 Program Titles Community Development Financial Institutions, Native Initiatives COVID-19 - Community Development Financial Institutions, Rapid Response Program Condition and context: NPH did not prepare an accurate SEFA for the fiscal year ended September 30, 2021. Expenditures for the Community Development Financial Institutions Program were overstated by $720,931. Recommendation: The auditors recommended that NPH either outsource the preparation of the schedule of expenditures of federal award to qualified organization or receive additional training on the reporting requirements. Contact Name: Rollin Wood, Executive Director Corrective Action Planned: The $720,931 in overstated expenditures relates to NPH?s implementation of the Paycheck Protection Program (PPP), which was an expedited deployment of federal funds to assist businesses in addressing the early and most immediate effects of the Covid-19 pandemic. NPH was one of only two Native CDFI?s in the country to become and authorized PPP lender. For reporting, NPH utilizes a third-party expert, Fund Consulting, who assists NPH in the preparation and submittal of its financial reports pursuant to its grant contracts with the CDFI Fund. Due to some confusion over how the PPP loan funds were to be classified, NPH had misclassified the funds on the schedule of expenditures of federal awards (SEFA). As part of the audit process wherein the auditors consulted directly with Fund Consulting regarding the SEFA, the PPP loan funds were reclassified to the proper category. Anticipated Completion Date: September 30, 2022
FAC accepted this audit on June 6, 2021 — management decision was due December 6, 2021.
FAC accepted this audit on May 12, 2020 — management decision was due November 12, 2020.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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