Native Villlage of SelawikTribal Government

2022-003 Allowable Costs/Cost Principles - Significant Deficiency in Internal Control over Compliance Identification of federal programs: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: Title 2 U.S. Code Part 200.403(g) requires that for costs charged to a federal program to be allowable, they must be adequately documented. Condition: Payroll related costs charged to the program did not have Personal Action Forms to document the rate of pay for the employee in accordance with the IRA Council?s own Finance Policies & Procedures Manual Chapter 7.1. Additionally, major procurements did not have the proper procurement authority approval and support in accordance with the IRA Council?s own Finance Policies & Procedures Manual Chapter 6.7 ? 6.10. Cause: The IRA Council was adjusting to challenges created by the COVID-19 pandemic. Effect or potential effect: Although charges were still approved and supported, not following established financial policies and procedures increases the risk that internal control failures, questioned costs and noncompliance could arise in the future over major federal programs. Questioned Costs: None Context: During our sample testing for allowable costs in 2022 as a major program, we identified 17 payroll transactions in our random allowable cost sample of 40 that did not have approved payrate support in the form of a Personal Action Form as required by the IRA Council?s own financial policies and procedures. Additionally, although no individual transaction exceeded program materiality were identified in our major program testwork, 2 vendors identified during capital additions testwork for both 2021 and 2022 were noted not to have additional quotes for supplies and services provided that were charged to the program, which exceeded the micropurchase threshold. Identification of Repeat Finding: Repeated for 21.027 Coronavirus State and Local Fiscal Recovery Funds. Recommendations: We recommend the IRA Council review its financial policies and procedures and implement and/or revise accordingly to ensure the conform to both uniform guidance and internal policies and procedures to satisfy adequate internal controls. Views of Responsible Officials: See Corrective Action Plan

2022-004 Reporting - Significant Deficiency in Internal Control over Compliance and Noncompliance Identification of federal programs: 21.027 Coronavirus State and Local Fiscal Recovery Funds Criteria: For the 2022 period under audit, the IRA Council was required to submit an annual Project and Expenditure Report for the period March 3, 2021 ? March 31, 2022 by the due date April 30, 2022. Condition: The report was prepared in draft form but was not ever submitted by the April 30, 2022 deadline as required. Cause: The IRA Council was adjusting to challenges created by the COVID-19 pandemic. Effect or potential effect: Information desired by Treasury for collection, information and reporting purposes was not provided as required through timely filing of the annual report. Questioned Costs: None Context: It was noted from the compliance report information provided by the Tribal Administrator on the Treasury Covid-19 Relief Hub, that the required report was still in draft form in the status section. Identification of Repeat Finding: Not applicable Recommendations: We recommend the IRA Council review its financial policies and procedures over grant reporting requirements and implement accordingly to conform to both the uniform guidance and its own internal controls. Views of Responsible Officials: See Corrective Action Plan

2021-003 Allowable Costs/Cost Principles - Significant Deficiency in Internal Control over Compliance. Identification of federal programs: 21.019 Coronavirus Relief Fund and 21.027 Coronavirus State and Local Fiscal Recovery Funds. Criteria: Title 2 U.S. Code Part 200.403(g) requires that for costs charged to a federal program to be allowable, they must be adequately documented. Condition: Payroll related costs charged to the program did not have Personal Action Forms to document the rate of pay for the employee in accordance with the IRA Council?s own Finance Policies & Procedures Manual Chapter 7.1. Additionally, major procurements did not have the proper procurement authority approval and support in accordance with the IRA Council?s own Finance Policies & Procedures Manual Chapter 6.7 ? 6.10. Cause: The IRA Council was adjusting to challenges created by the COVID-19 pandemic. Effect or potential effect: Although charges were still approved and supported, not following established financial policies and procedures increases the risk that internal control failures, questioned costs and noncompliance could arise in the future over major federal programs. Questioned Costs: None. Context: 21.019 Coronavirus Relief Fund - During our sample testing for allowable costs in 2020 as a major program, we identified 24 payroll transactions in our random allowable cost sample of 40 that did not have approved payrate support in the form of a Personal Action Form as required by the IRA Council?s own financial policies and procedures. Additionally, 3 transactions judgmentally selected for their relative significance in size did not follow financial policies and procedures either. Corrective action did not start until 2022 when the issues were identified.21.027 Coronavirus State and Local Fiscal Recovery Funds - During our sample testing for allowable costs in 2021 as a major program, we identified 11 payroll transactions in our random allowable cost sample of 40 that did not have approved payrate support in the form of a Personal Action Form as required by the IRA Council?s own financial policies and procedures. Additionally, no individual transaction exceeded program materiality or identified in our major program testwork, 2 vendors identified during capital additions testwork were noted not to have additional quotes for supplies and services provided that were charged to the program, which exceeded the micro-purchase thereshold. Identification of Repeat Finding: Repeat for 21.019 Coronavirus Relief Fund only. Recommendations: We recommend the IRA Council review its financial policies and procedures and implement and/or revise accordingly to ensure the conform to both uniform guidance and internal policies and procedures to satisfy adequate internal controls.Views of Responsible Officials: See Corrective Action Plan

2020-003 Allowable Costs/Cost Principles - Significant Deficiency in Internal Control over Compliance Identification of federal programs: 21.019 Coronavirus Relief Fund Criteria: Title 2 U.S. Code Part 200.403(g) requires that for costs charged to a federal program to be allowable, they must be adequately documented. Condition: Payroll related costs charged to the program did not have Personal Action Forms to document the rate of pay for the employee in accordance with the IRA Council?s own Finance Policies & Procedures Manual Chapter 7.1. Additionally, major procurements did not have the proper procurement authority approval and support in accordance with the IRA Council?s own Finance Policies & Procedures Manual Chapter 6.7 ? 6.10. Cause: The IRA Council was adjusting to the challenges brought about by the COVID-19 pandemic. Effect or potential effect: Although charges were still approved and supported, not following established financial policies and procedures increases the risk that internal control failures, questioned costs and noncompliance could arise in the future over major federal programs. Questioned Costs: None Context: During our sample testing for allowable costs, we identified 24 payroll transactions in our random allowable cost sample of 40 that did not have approved payrate support in the form of a Personal Action Form as required by the IRA Council?s own financial policies and procedures. Additionally, 3 transactions judgmentally selected for their relative significance in size were did not follow financial policies and procedures either. Identification of Repeat Finding: Not applicable. Recommendations: We recommend the IRA Council review its financial policies and procedures and implement and/or revise accordingly to ensure the conform to both uniform guidance and internal policies and procedures to satisfy adequate internal controls. Views of Responsible Officials: See Corrective Action Plan

19-006 Financial Reporting, Material Weakness and Noncompliance Federal Program - CFDA # 15.020, 15.024, 15.040 and 20.205 Criteria ? Grant agreements and contract stipulate reporting requirements for each grant and requires that reports be based upon records supported by the accounting system. Additionally, the Single Audit requires that audits be performed and submitted timely if federal expenditures exceed the threshold stipulated. Condition ? No Quick Books reports were attached to the reports submitted and I was unable to recreate the exact numbers through the accounting software. Additionally, their reports appear to be submitted past due. The Single Audit reports were not completed timely. Questioned costs ? None. Context ? Most of the reports submitted to oversight agencies. Effect ? The accuracy of the reports could be questioned. Cause ? Insufficient internal controls are in place to ensure that reports are accurate and complete. Recommendation - I recommend that these reports should be completed, reviewed and retained by either the Accounting Department or by the Program Directors with supporting Quick Books reports attached and that the Tribal Administrator review the reports with supporting documentation before signing. Copies of these reports should be retained by the Program Directors and the Accounting Department. Views of responsible officials - Management concurs with the finding. Also see corrective action plan.

19-007 Allowable Costs, Material Weakness and Noncompliance Federal Program - CFDA # 15.020, 15.024, 15.40 and 20.205 Criteria ? Uniform Guidance requires that personnel costs be documented with an after the fact time report. Additionally, Uniform Guidance requires that costs be reasonable, necessary and well documented. Condition ? Some transactions were missing sufficient supporting documentation. Questioned costs ? Any questioned costs in total are less than what is required to be reported. Context ? After initial sampling resulted in errors resulting in a material weakness, we expanded our sample. We tested a total of 85 transactions including payroll, credit card transaction, randomly selected transactions and all transactions in excess of $3,000 within the major programs. We had the following exceptions of the 25 payroll checks selected 3 were paid 2 hours in excess of what the timesheet indicated. Of the 60 additional nonpayroll transactions tested 3 were missing supporting documentation and 1 was missing a supervisor?s review signature. Effect ? Costs could be disallowed and required to be paid back. Cause ? Insufficient internal controls are in place to ensure that supporting documentation is retained. Recommendation - I recommend that internal controls be reviewed to ensure that costs are allowable and that proper documentation is retained in the files. Views of responsible officials - Management concurs with the finding. Also see corrective action plan.