Sitka Tribe of AlaskaTribal Government

Federal agency: U.S. Department of Treasury Federal program title: COVID-19 - Coronavirus Relief Fund AL Number: 21.019 FAIN: SLT1295, SLT1853, SLT0686 Finding Type: Significant Deficiency in Internal Control over Compliance, Other Matter. Compliance Area: Reporting New or Repeat: New Criteria: Section 15011 of Division B of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, Reporting on Use of Funds, requires that not later than 10 days after the end of each calendar quarter, each covered recipient shall submit to the agency and the Committee a report that contains ? (A)the total amount of large covered funds received from the agency; (B)the amount of large covered funds received that were expended orobligated for each project or activity; (C)a detailed list of all projects or activities for which large coveredfunds were expended or obligated, including? (i)the name of the project or activity; (ii)a description of the project or activity; and (iii)the estimated number of jobs created or retained by theproject or activity, where applicable; and (D)detailed information on any level of subcontracts or subgrantsawarded by the covered recipient or its subcontractors or subgrantees,to include the data elements required to comply with the FederalFunding Accountability and Transparency Act of 2006 (31 U.S.C. 6101note) allowing aggregate reporting on awards below $50,000 or toindividuals, as prescribed by the Director of the Office of Managementand Budget Condition: Internal controls over compliance with reporting requirements were not sufficiently designed and implemented to ensure all quarterly reports were submitted as required. The report for the fourth quarter of calendar year 2020, due January 10, 2021, was not submitted. The data that was required to be reported in the fourth quarter of calendar year 2020 was reported in the report for the first quarter of 2021. Questioned costs: There are no questioned costs associated with this finding. Cause: Internal controls over compliance with reporting requirements were not sufficiently designed and implemented due to turnover in the finance department. Context and effect: One report, out of four reports required to be submitted during fiscal year 2021, was not submitted. Consequently, the Tribe is not in compliance with reporting requirements. Recommendation: We recommend management complete required reports. Further, we recommend management develop desk manuals outlining procedures for required reports so that in periods of turnover, required tasks can still be completed. We also recommend a comprehensive reporting schedule be completed so due dates are not overlooked. View of responsible officials: Management concurs with this finding, see corrective action plan.

Federal agency: U.S. Department of Justice Federal program title: Public Safety Partnership and Community Policing Grants AL Number: 16.710 FAIN: 2019HEWX0007 Finding Type: Significant Deficiency in Internal Control over Compliance, Other Matter. Compliance Area: Reporting under the Federal Funding Accountability and Transparency Act (FFATA) New or Repeat: New Criteria: Under the requirements of the Federal Funding Accountability and Transparency Act (Pub. L. No. 109-282), as amended by Section 6202 of Public Law 110-252, hereafter referred as the ?Transparency Act,? that are codified in 2 CFR Part 170, recipients (i.e., direct recipients) of grants or cooperative agreements are required to report first-tier subawards of $30,000 or more to the Federal Funding Accountability and Transparency Act Subaward Reporting System (FSRS). Condition: Internal controls over compliance with reporting requirements were not sufficiently designed and implemented to ensure FFATA reporting was performed as required. The Tribe provided one first-tier subaward in excess of $30,000 to a pass-through entity. This subaward was not reported in the FSRS as required. Questioned costs: There are no questioned costs associated with this finding. Cause: Internal controls over compliance with reporting requirements were not sufficiently designed and implemented due to turnover in the finance department. Context and effect: The Tribe provided one first-tier subaward in excess of $30,000 to a pass-through entity. The funds passed through to the first-tier subrecipient were subject to reporting under the Transparency Act based on the amount of the subaward. The subaward was not reported in FSRS as required. Consequently, the Tribe is not in compliance with reporting requirements. Recommendation: We recommend management complete required reports. Further, we recommend management develop desk manuals outlining procedures for required reports so that in periods of turnover, required tasks can still be completed. We also recommend a comprehensive reporting schedule be completed so due dates are not overlooked. View of responsible officials: Management concurs with this finding, see corrective action plan.

Federal agency: U.S. Department of the Interior Federal program title: Aid to Tribal Governments AL Number: 15.020 FAIN: A20AV00728 Finding Type: Significant Deficiency in Internal Control over Compliance, Other Matter. Compliance Area: Equipment and Real Property Management New or Repeat: New Criteria: Per 2 CFR section 200.313(d)(2), a physical inventory of equipment acquired under a federal award must be performed at least once every two years. Condition: Internal controls over compliance with equipment and real property management requirements were not sufficiently implemented due to turnover in the finance department. A physical inventory of equipment was not performed at least once in the past two years. Questioned costs: There are no questioned costs associated with this finding. Cause: Internal controls over compliance with equipment and real property management requirements were not sufficiently implemented due to turnover in the finance department. Context and effect: The fixed asset inventory scheduled to occur during fiscal year 2021 was not performed due to turnover in the finance department. Consequently, the Tribe is not in compliance with equipment and real property management requirements. Recommendation: We recommend management develop desk manuals outlining procedures and schedules for fixed assets inventories to ensure these inventories are being performed at least once every two years. View of responsible officials: Management concurs with this finding, see corrective action plan.

2019-001 Significant Deficiency in Internal Controls over Compliance ? Allowable Costs/Cost Principles Program: U.S. Department of the Interior, Tribal Self-Governance Program ? CFDA 15.022 Criteria: Per the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart E ? Cost Principles - ?200.430 (Compensation ? personal services) ?Charges to Federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated? and must ?Support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one Federal award; a Federal award and non-Federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity.? Condition: Internal controls over compliance are not sufficiently designed to ensure time distributed to a federal program was supported. Cause: Insufficient understanding of the time and effort support requirements of the Uniform Guidance for personal services. Context: Lack of a dedicated program manager for a specific funding allotment, under the Tribal Self Governance program, resulted in a salary transfer to use the remaining available budget. The transfer moved time, based on remaining available budget, for an employee who was coded to the indirect cost pool, rather than based on records showing work performed. Sufficient records, at the time of transfer, such as timesheet supporting hours worked, or other similar documentation, was not in place to support the amount transferred. Management was able to quantify hours after the fact, due to audit inquiries, from calendars and schedule notes, to support the amount transferred as allowable, therefor there are no questioned costs associated with this finding. Effect: Unallowable personal service costs could have been charged to a federal program. Recommendation: We recommend direct time charged to a federal program be tracked by timesheet or other equivalent method. Further, we recommend that only time that cannot be directly charged to another source be included in the indirect cost pool. View of responsible Officials: Management concurs with the finding; see corrective action plan.

2019-002 Significant Deficiency in Internal Controls over Compliance ? Procurement; Suspension and Debarment Program: U.S. Department of the Interior, Tribal Self-Governance Program ? CFDA 15.022 Criteria: Per auditee requirements of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Subpart C ? Pre-Federal Award Requirements and Contents of Federal Awards - ?200.213 (Suspension and debarment) ?Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities.? Condition: Internal controls over compliance are not sufficiently designed to include a review to ensure vendors paid with federal financial assistance are not suspended or debarred. Cause: Turnover in the position responsible for procurement compliance resulted in records not being centrally maintained or saved. Context: Documentation was not retained to evidence that vendors were checked for suspension or debarment prior to entering into a contract with them. Effect: The Tribe could have contracted with a suspended or debarred contractor which could have resulted in unallowed costs. Recommendation: We recommend management establish policies and procedures to ensure that the search for suspension and debarment is completed and documented during the procurement process. View of responsible Officials: Management concurs with the finding; see corrective action plan.

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