NULATO TRIBAL COUNCILTribal Government

Federal Agency: U.S. Department of the Treasury Federal Programs: Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Award Numbers: SLFRP3168/5205 Award Years: 2021 Type of Finding: Material weakness in internal control over compliance and material noncompliance Criteria: In accordance with 2 CFR Section 200.305, advanced federal funds held in depository institutions must be deposited and maintained in insured accounts. Condition and Context: Internal control procedures related to monitoring insured cash balances were inadequate. The Council had advanced federal funds (deferred revenue) of $10,512,764 as of September 30, 2022. Uninsured and uncollateralized cash balances were $9,328,634 as of September 30, 2022. Cause: Lack of internal controls over the monitoring of insured cash balances. Effect: Failure to follow granting agency requirements could result in loss of federal funding or at a minimum, the Council having to repay portions of the advanced federal funds. Questioned Costs: None. Repeat Finding: This is a repeat of Finding 2021-001, and since this is a repeat finding we believe it to be a systemic issue. Recommendation: We recommend that management that the Council establish policies and controls over special tests and provisions related to monitoring advanced funds to ensure federal funds are properly held in fully insured depository accounts. Management’s Response: Management concurs with this finding. See corrective action plan.

Federal Agency: U.S. Department of the Treasury Federal Programs: Coronavirus State and Local Fiscal Recovery Funds ALN: 21.027 Award Numbers: SLFRP3168/5205 Award Years: 2021 Type of Finding: Material weakness in internal control over compliance and material noncompliance Criteria: Uniform Guidance requires that the reporting package be submitted within the earlier of nine months after year end or 30 days after the report issuance in accordance with 2 CFR part 200, subpart F, section 200.512. Condition and Context: The Council did not adhere to the Uniform Guidance requirement of submitting the reporting package by the required deadline. Cause: Lack of internal controls over Uniform Guidance reporting requirements. Effect: The Council was not in compliance with reporting requirements. Questioned Costs: None. Repeat Finding: This is not a repeat finding and therefore we believe it to be an isolated instance. Recommendation: We recommend that the Council comply with Uniform Guidance reporting requirements. Management’s Response: Management concurs with this finding. See corrective action plan.

Finding 2019-003 Lack of Internal Control Over Administrative Requirements-Procurement Federal Agency: U.S. Department of the Interior and U.S. Environmental Protection Agency Federal Program: Tribal Self-Governance Compact and IGAP, respectively CFDA Number: 15.022 and 66.926, respectively Award Number: None and GA-01J43701, respectively Award Year: Tribal Self-Governance Compact: 2014, 2016, 2017, 2018, and 2019 IGAP: 2019 Type of Finding: Significant deficiency in internal control over compliance and noncompliance Criteria: Uniform Guidance requires that entities receiving federal funding must have written policies and procedures that meet the criteria listed in 2 CFR 200.318 to 200.326. Condition and Context: During our compliance testing of the programs it was determined that the Council had not updated their procurement policies and procedures to be in compliance with the Uniform Guidance. Cause: Lack of internal controls over procurement requirements. Effect: Failure to follow compliance requirements could result in the loss of federal funding. Questioned Costs: None noted. Repeat Finding: No, this is considered an isolated instance. Recommendation: The Council should update their procurement policies to meet the criteria listed in 2 CFR 200.318 and 200.326 and the Uniform Guidance. Management?s Response: Management concurs with this finding. See corrective action plan

Finding 2019-004 Lack of Internal Controls Over Payroll Transactions Federal Agency: U.S. Department of the Interior Federal Program: Tribal Self-Governance Compact CFDA Number: 15.022 Award Number: None Award Year: 2014, 2016, 2017, 2018, and 2019 Type of Finding: Significant deficiency in internal control over compliance and noncompliance Criteria: Proper internal controls over payroll require employees be paid for hours worked, vacation accruals be supported by an approved policy, and all payroll transactions be reviewed and approved. Condition and Context: During our testing of payroll transactions charged to the program we noted five employees who were not accruing vacation based on the approved policy. Council policies state that all employees with one year of service should accrue leave at a rate of .11359 per hour worked. Each of the five employees noted above were accruing a flat 9.23 hours per pay period, regardless of hours worked. We also noted four paychecks where the hours listed on the timecard did not match what was actually paid. Cause: Lack of internal controls over payroll transactions charged to the major program. Effect: Lack of internal controls over payroll transactions could lead to unallowed costs being charged to major programs. In this case, there is an overstatement of payroll expenses due to the over accrual of vacation hours available to employees. Questioned Costs: Actual and likely questioned costs are below the reporting threshold of $25,000. Repeat Finding: No, however, due to the number of errors we found we believe this to be a systemic issue. Recommendation: We recommend that the Council immediately review all payroll related policies and ensure that paychecks are following the approved policies to ensure that vacation accruals are being calculated properly. Management should also review and approve all paychecks to ensure they have been properly calculated. Management?s Response: Management concurs with this finding. See corrective action plan

GSA_MIGRATION