NATIVE VILLAGE OF TYONEK

CASH MANAGEMENT, I NOTED THAT THE NATIVE VILLAGE OF TYONEK (NVT) HAD AN EXCESS OF ACCOUNTS PAYABLE, ACCRUED PAYROLL LIABILITIES AND UNEARNED GRANT REVENUES AS COMPARED TO CASH ON HAND. TOTAL CASH ON HAND AT YEAR END WAS $5,810,414 AND TOTAL UNEARNED GRANT REVENUE WAS $6,181,944. PER 2 CFR, SECTION 200.302, THE NATIVE VILLAGE MUST COMPLY WITH THE REQUIREMENT THAT ANY AND ALL GRANT ADVANCES BE RETAINED WITHIN THE ORGANIZATION UNTIL EXPENDED ON ALLOWABLE GRANT EXPENDITURES. QUESTIONED COSTS NOT DETERMINED. IN PRIOR YEARS, THERE WAS AN OVEREXPENDITURE OF GENERAL AND ADMINISTRATIVE EXPENSES IN EXCESS OF REVENUES FOR THE YEAR. MOST OF THIS WAS BILLINGS FROM THE VILLAGES CONSULTANTS (6 AND 7 YEARS AGO) WHOSE BILLINGS WERE FAR IN EXCESS OF THE AVAILABLE UNRESTRICTED FUNDS WHICH THE VILLAGE HAD TO PAY THEM AS WELL AS LOSSES IN THE KALOA FUND. GRANTING AGENCIES COULD REQUEST REIMBURSEMENT OF THESE UNALLOWABLE ADVANCES CAUSING FINANCIAL HARDSHIP FOR THE NVT. MANAGEMENT NEEDS TO ENSURE THAT ALL NONGRANT EXPENSES NEED TO BE KEPT TO A MINIMUM TO ENSURE THAT ADVANCED GRANT FUNDS ARE NOT SPENT ON UNALLOWABLE ITEMS. IT IS IMPORTANT THAT THE NVT TRACK THROUGHOUT THE YEAR THE NET PROFIT OR LOSS IN THE GENERAL FUND AND IMMEDIATELY TAKE CORRECTIVE STEPS IF THE GENERAL FUND IS SHOWING A LOSS. IT IS ALSO IMPORTANT THAT CONTINUING RELATIONSHIPS WITH VENDORS ARE EVALUATED THROUGHOUT THE YEAR TO ENSURE REASONABLENESS OF PAYMENTS. IT IS ALSO IMPORTANT THAT LOSSES IN THE KALOA BUILDING FUND ARE ELIMINATED. THIS FINDING WAS ALSO NOTED AS FINDING 2021-001. IT HAS ALSO BEEN NOTED SINCE 2014.

REPORTING, I DID NOT NOTE ANY ANNUAL REPORTS FILED FOR THE ARP GRANT. PER 2 CFR, SECTION 200.328 AND 200.329, THE NVT MUST COMPLY WITH ANY FINANCIAL AND PROGRAMMATIC REPORTING REQUIREMENTS. NO QUESTIONED COSTS. MANAGEMENT DID NOT HAVE CONTROLS IN PLACE TO ENSURE THAT ALL GRANT REPORTS WERE FILED TIMELY. I WAS NOT ABLE TO REVIEW THE ANNUAL REQUIRED REPORT FOR THE ARP GRANT. THE NVT IS DELINQUENT IN ITS REPORTING FOR THIS GRANT. MANAGEMENT NEEDS TO ENSURE THAT ALL GRANT REPORTS ARE DONE AND SUBMITTED TIMELY AND RETAINED WITHIN THE GRANT FILES OF THE NVT. THIS FINDING WAS NOTED AS FINDING 2021-002.

OTHER, THE NVT DID NOT SUBMIT THE REPORTING PACKAGE TIMELY IN ACCORDANCE WITH THE UNIFORM GUIDANCE REQUIREMENT OF SUBMITTING THE AUDIT WITHIN THE EARLIER OF 30 DAYS AFTER RECEIPT OF THE AUDIT REPORT, OR NINE MONTHS AFTER THE END OF THE AUDIT PERIOD. PER 2 CFR, SECTION 200.328 AND 200.329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATTIC REPORTING REQUIREMENTS. PER SECTION 200.501, THE NVT MUST HAEV AN AUDIT PERFORMED AND SUBMITTED WITHIN 9 MONTHS OF YEAR END. NO QUESTIONED COSTS. MANAGEMENT DID NOT ENSURE THAT THE AUDITS WERE PERFORMED TIMELY. LATE REPORTING COULD JEOPARDIZE GRANT FUNDING. I RECOMMEND THAT THE COUNCIL ENSURE TIMELY AUDITS FOR FUTURE AUDITS. THIS FINDING WAS NOTED AS FINDING 2020-003 AND 2021-003.

SPECIAL TESTS AND PROVISIONS, MANAGEMENT DID NOT HAVE WRITTEN P&P OVER THEIR CONTROLS OVER THEIR COMPLIANCE WITH THE UNIFORM GUIDANCE AS REQUIRED BY 2 CFR, SUBPART D AND E. NO QUESTIONED COSTS. LACK OF WRITTEN CONTROLS TO IDENTIFY ALLOWABLE COSTS AND SPECIAL TESTS AND PROVISIONS. COSTS MAY BE DISALLOWED AND REQUIRED TO BE REPAID TO THE GRANTING AGENCY. COMPLIANCE REQUIREMENTS SET FORTH IN THE GRANT AGREEMENTS/UNIFORM GUIDANCE WERE NOT FOLLOWED. MANAGEMENT SHOULD DEVELOP WRITTEN INTERNAL CONTROL PROCEDURES IN ACCORDANCE WITH REQUIREMENTS OF THE UNIFORM GUIDANCE. THIS FINDING WAS NOTED IN PRIOR YEAR AS FINDING 2021-004.

PROCUREMENT, I NOTED THAT NVT DID NOT PROPERLY DOCUMENT THE PROCUREMENT OF SEVEN PURCHASES OVER $10,000 FOR THE DOT, COVID-19, CSLFRF PROGRAM. THE SEVEN PURCHASES TOTALED $2,644,121. PER 2 CFR, SECTION 200.320 NVT'S STAFF MUST FOLLOW PROCUREMENT POLICIES AND OBTAIN COMPETITIVE BIDS FOR SIGNIFICANT PURCHASES OF EQUIPMENT/MATERIALS/ AND/OR CONTRACTS AND DOCUMENT THE FINAL SELECTION PROCESS, INCLUDING VENDORS CONTRACTED, VARIOUS VENDOR QUOTES/BIDS, AND FINAL ANALYSIS OF WINNING BID. IN ADDITION, THE SAM WEBSITE SHOULD BE REVIEWED TO ENSURE THE WINNING VENDOR/CONTRACTOR HAS NOT BEEN SUSPENDED/DEBARRED. NO QUESTIONED COSTS DETERMINED. I TESTED THE ONLY SEVEN ITEMS IN EXCESS OF THE PROCUREMENT THRESHOLD FOR THE DOT, CSLFRF, 21.027 GRANT FOR PROPER PROCURMENT. ALL SEVEN OF THE ITEMS DID NOT CONTAIN PROPER PROCUREMENT DOCUMENTATION. THE SEVEN ITEMS TOTALED $2,644,121. INTERNAL CONTROLS WERE NOT IN PLACE TO ENSURE THAT PRIOR TO PURCHASE, PROPER PROCUREMENT PROCEDURES WERE FOLLOWED AND DOCUMENTED. MANAGEMENT SHOULD ENSURE THAT ALL STAFF KNOW THAT ALL MATERIAL PURCHASES MUST BE PROPERLY PROCURED, AND IF SOLE SOURCE, THAT MUST BE DOCUMENTED AS WELL. THIS WAS NOT A REPEAT FINDING.

CASH MANAGEMENT, I NOTED THAT THE NATIVE VILLAGE OF TYONEK (NVT) HAD AN EXCESS OF EARNED GRANT REVENUES AND RESTRICTED FUND BALANCE AS COMPARED TO CASH ON HAND. TOTAL CASH ON HAND AT YEAR END WAS $8,113,152 AND TOTAL UNEARNED GRANT REVENUE WAS $8,182,093. PER 2 CFR, SECTION 200.302, THE NATIVE VILLAGE MUST COMPLY WITH THE REQUIREMENT THAT ANY AND ALL GRANT ADVANCES BE RETAINED WITHIN THE ORGANIZATION UNTIL EXPENDED ON ALLOWABLE GRANT EXPENDITURES. QUESTIONED COSTS NOT DETERMINED. IN PRIOR YEARS, THERE WAS AN OVEREXPENDITURE OF GENERAL AND ADMINISTRATIVE EXPENSES IN EXCESS OF REVENUES FOR THE YEAR. MOST OF THIS WAS BILLINGS FROM THE VILLAGES CONSULTANTS (4 AND 5 YEARS AGO) WHOSE BILLINGS WERE FAR IN EXCESS OF THE AVAILABLE UNRESTRICTED FUNDS WHICH THE VILLAGE HAD TO PAY THEM. GRANTING AGENCIES COULD REQUEST REIMBURSEMENT OF THESE UNALLOWABLE ADVANCES CAUSING FINANCIAL HARDSHIP FOR THE NVT. MANAGEMENT NEEDS TO ENSURE THAT ALL NONGRANT EXPENSES NEED TO BE KEPT TO A MINIMUM TO ENSURE THAT ADVANCED GRANT FUNDS ARE NOT SPENT ON UNALLOWABLE ITEMS. IT IS IMPORTANT THAT THE NVT TRACK THROUGHOUT THE YEAR THE NET PROFIT OR LOSS IN THE GENERAL FUND AND IMMEDIATELY TAKE CORRECTIVE STEPS IF THE GENERAL FUND IS SHOWING A LOSS. IT IS ALSO IMPORTANT THAT CONTINUING RELATIONSHIPS WITH VENDORS ARE EVALUATED THROUGHOUT THE YEAR TO ENSURE REASONABLENESS OF PAYMENTS. THIS FINDING WAS ALSO NOTED AS FINDING 2020-001

REPORTING, I DID NOT NOTE ANY OF THE REQUIRED QUARTERLY REPORTING FOR THE CARES ACT GRANT. I ALSO DID NOT NOTE ANY INTERIM OR ANNUAL REPORTS FILED FOR THE ARP GRANT. PER 2 CFR, SECTION 200.328 AND 200.329, THE NVT MUST COMPLY WITH ANY FINANCIAL AND PROGRAMMATIC REPORTING REQUIREMENTS. NO QUESTIONED COSTS. MANAGEMENT DID NOT HAVE CONTROLS IN PLACE TO ENSURE THAT ALL GRANT REPORTS WERE FILED TIMELY. I WAS NOT ABLE TO REVIEW ANY OF THE 4 QUARTERLY FINANCIAL OR NARRATIVE REPORTS FOR THE CARES ACT GRANT. I WAS ALSO NOT ABLE TO REVIEW THE ANNUAL REQUIRED REPORT FOR THE ARP GRANT. THE NVT IS DELINQUENT IN ITS REPORTING FOR THESE TWO GRANTS. MANAGEMENT NEEDS TO ENSURE THAT ALL GRANT REPORTS ARE DONE AND SUBMITTED TIMELY AND RETAINED WITHIN THE GRANT FILES OF THE NVT. THIS FINDING WAS NOTED AS FINDING 2020-002.

OTHER, THE NVT DID NOT SUBMIT THE REPORTING PACKAGE TIMELY IN ACCORDANCE WITH THE UNIFORM GUIDANCE REQUIREMENT OF SUBMITTING THE AUDIT WITHIN THE EARLIER OF 30 DAYS AFTER RECEIPT OF THE AUDIT REPORT, OR NINE MONTHS AFTER THE END OF THE AUDIT PERIOD. PER 2 CFR, SECTION 200.328 AND 200.329, THE COUNCIL MUST COMPLY WITH ANY FINANCIAL AND PROGRAMATTIC REPORTING REQUIREMENTS. PER SECTION 200.501, THE NVT MUST HAEV AN AUDIT PERFORMED AND SUBMITTED WITHIN 9 MONTHS OF YEAR END. NO QUESTIONED COSTS. MANAGEMENT DID NOT ENSURE THAT THE AUDITS WERE PERFORMED TIMELY. LATE REPORTING COULD JEOPARDIZE GRANT FUNDING. I RECOMMEND THAT THE COUNCIL ENSURE TIMELY AUDITS FOR FUTURE AUDITS. THIS FINDING WAS NOTED AS FINDING 2020-003

SPECIAL TESTS AND PROVISIONS, MANAGEMENT DID NOT HAVE WRITTEN P&P OVER THEIR CONTROLS OVER THEIR COMPLIANCE WITH THE UNIFORM GUIDANCE AS REQUIRED BY 2 CFR, SUBPART D AND E. NO QUESTIONED COSTS. LACK OF WRITTEN CONTROLS TO IDENTIFY ALLOWABLE COSTS AND SPECIAL TESTS AND PROVISIONS. COSTS MAY BE DISALLOWED AND REQUIRED TO BE REPAID TO THE GRANTING AGENCY. COMPLIANCE REQUIREMENTS SET FORTH IN THE GRANT AGREEMENTS/UNIFORM GUIDANCE WERE NOT FOLLOWED. MANAGEMENT SHOULD DEVELOP WRITTEN INTERNAL CONTROL PROCEDURES IN ACCORDANCE WITH REQUIREMENTS OF THE UNIFORM GUIDANCE. THIS WAS NOT A REPEAT FINDING.