North Slope BoroughLocal Government

Inadequate Internal Controls over Grant-Funded Equipment Maintenance and Inventory and Noncompliance with Biennial Inventory Count Requirement Name of Federal agency: U.S. Department of the Interior Name of applicable pass-through entity: State of Alaska, Department of Community and Economic Development Federal program: National Petroleum Reserve – Alaska Assistance listing number: 15.439 Federal Award Number(s): Various Federal award period: July 1, 2024 - June 30, 2025 Criteria: According to 2 CFR 200.313(d)(2), a physical inventory of the property must be taken and the results reconciled with property records at least once every two years and 2 CFR 200.313(d)(4) states that adequate maintenance procedures must be developed to keep the property in good condition. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Condition Found: The Borough was unable to provide sufficient and appropriate evidence, including complete documentation, to demonstrate compliance with the biennial physical inventory requirement for grant funded equipment under the Equipment and Real Property Management compliance requirements. Specifically, no documentation was available to support whether a physical inventory was conducted in FY2024, and the FY2025 inventory was incomplete. Additionally, there was not a control designed to ensure equipment maintenance was performed as scheduled. Cause: While the Borough had an established general policy regarding physical inventory counts and equipment maintenance, the policy lacked sufficient detail to ensure consistent implementation. Specifically, the policy did not clearly define roles and responsibilities for conducting inventory counts, establish procedures for performing the inventory counts and the timing of such counts, or identify the individuals responsible for reviewing and approving inventory results and maintenance logs. In addition, organizational changes during FY2024, including the separation of the Administration and Finance departments, contributed to a breakdown in the continuity of inventory management functions. Staff turnover and a lack of training for new employees further contributed to the insufficient execution of required inventory management procedures. Possible Asserted Effect: Failure to establish effective internal controls over the biennial inventory count and maintenance requirements increases the risk that grant-funded equipment may be lost, misappropriated, or not properly accounted for, which could result in questioned costs, inaccurate financial reporting, and noncompliance with federal award requirements. Questioned Costs: None Repeat Finding: A similar finding was not reported in the prior year audit. Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the Borough establish internal controls to ensure biennial inventory counts for grant-funded equipment are properly conducted, documented, and formally reconciled with the property records and to ensure equipment is kept in good condition. Views of Responsible Officials: Management concurs with the finding. In response, management will continue to implement additional controls to strengthen compliance with equipment and real property management requirements, including improvements to inventory procedures, documentation practices, and oversight. The Department of Finance will work in coordination with the Department of Administration to provide training to all relevant departments on federal guidelines and compliance requirements related to assets purchased with federal grant funds. Management will continue to monitor these controls and take further corrective action, as necessary, to ensure ongoing compliance with applicable federal requirements.

Criteria: According to 2 CFR 200.510(b), a recipient of federal awards is required to prepare a schedule of expenditures of Federal awards (SEFA) for the period covered by the entity’s financial statements which must include the total Federal awards expended as determined in accordance with 2 CFR 200 502. Additionally, 2 CFR 200.303 requires non-Federal entities receiving Federal awards to establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure federal expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Condition Found: The Borough did not have adequate internal controls related to the reporting of expenditures on the SEFA for the Local Assistance and Tribal Consistency Fund. Specifically, the Borough’s did not have a control in place to review expenditures that were incurred, but not yet reported to the grantor, to ensure proper reporting on the SEFA. As a result, $4,187,325 of Local Assistance and Tribal Consistency Fund expenditures had been excluded from the SEFA for the year ended June 30, 2024. Cause: In discussing these conditions with the Borough, they stated that the Borough consistently followed a policy to report expenditures when expenditures are reported to the grantor. Management did not have a control in place to review the unreported expenditures for proper inclusion in the SEFA, if material. Possible Asserted Effect: Failure to establish effective internal controls regarding financial reporting for the preparation of the SEFA may result in inappropriate application of audit requirements. Repeat Finding: A similar finding was not reported in the prior year audit.Statistical Sampling: The sample was not intended to be, and was not, a statistically valid sample. Recommendation: We recommend the Borough establish internal controls to ensure expenditures are accurately reported on the SEFA and information provided for audit purposes is complete and accurate. Views of Responsible Officials: Management agrees with the finding. Management has implemented additional controls to ensure the completeness and accuracy of amounts reported in the schedule of federal awards.

Findings and Questioned Costs Relating to Federal Awards Finding: 2020?002 Indirect Cost Criteria: The Borough is required to submit an indirect cost allocation plan to its cognizant agency for indirect costs annually per CFR 2 part 200 appendix V. Condition found: The Borough uses an indirect cost rate to allocate to Federal programs a portion of the government administrative costs that indirectly benefit and support the programs being funded (as permitted). The Borough did not submit an indirect cost allocation plan to its cognizant agency prior to indirect cost being requested for reimbursement. Cause: Due to the turnover in the Administration and Finance Department there was unclear allocation of responsibilities resulting in the indirect cost allocation plan not being submitted timely to the cognizant agency prior to indirect costs being requested for reimbursement. Effect: Indirect costs submitted to the grantors may not be eligible for reimbursement.Questioned Costs: None noted. Context: During our audit procedures, we identified that an indirect cost allocation plan was not submitted to the cognizant agency. Repeat Finding: No Recommendation: The Borough should consider adding controls to ensure an indirect cost allocation plan is prepared timely. Views of Responsible Officials: The Administration and Finance Department has already been in contact with the current cognizant agency and is currently in the process of filing the FY21 Indirect Allocation Plan. The annual filing requirement has been added to the documentation of the annual audit plan and will be addressed in a timely fashion going forward on an annual basis.