EIN: 920094184
UEI: SD65DABQARQ1
Audited by: ALTMAN ROGERS & CO.
Oversight agency: 15 [Department of the Interior]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 1, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 1, 2026 (33 days from today).
What is a management decision? →FAC accepted this audit on March 31, 2025 — management decision was due October 1, 2025.
FAC accepted this audit on March 22, 2024 — management decision was due September 22, 2024.
FAC accepted this audit on March 30, 2023 — management decision was due September 30, 2023.
FAC accepted this audit on June 27, 2022 — management decision was due December 27, 2022.
Finding 2021-001 Approval of Payroll Transactions ? Significant Deficiency in Internal Controls Over Allowable Costs/Cost Principles Identification of the federal program U.S. Department of the Interior, Bureau of Indian Affairs ALN 15.U03 477 Cluster - 2019-2021 P.L. 102-477 Contract. Award No. A19AV00081. U.S. Department of Health and Human Services ALN 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award No. 2020-444. Direct and Passthrough Southcentral Foundation ALN 93.441 Indian Self-Determination Award No. 243130002. Criteria or specific requirement Management is responsible to provide reasonable assurance that the costs paid for by federal funds are allowable and in accordance with the types of activities allowed per the compliance supplement. Condition Evidence of review is not consistently maintained for manual journal entries made to record accrued leave for employees for the programs. Cause Turnover and staffing issues as a result of the COVID-19 pandemic resulted in gaps in oversight of the controls. Effect or potential effect Federal funds could be expended for unallowed activities and unallowed costs. Questioned costs None Context 11 of the 75 payroll items selected for testwork lacked evidence of journal entry review for accrued leave entries for the federal programs. Identification as a repeat finding None Recommendation We recommend the Council review and update its internal controls over journal entries. We also recommend periodic monitoring of the review internal controls in place. Views of Responsible Official and Planned Corrective Action Management agrees with this finding. Management has high level mitigating controls where all leave balances are reviewed periodically, such a review was completed in preparation for the audit and adjustment were posted as necessary. Additional reviews were done to verify the journal entries without review stamps were correct once discovered during the audit. The accounting system controls have been reconfigured to ensure the individual entering the entry cannot post the entry; thus implementing an electronic documentation of review by a secondary person.
Show full finding ▾Hide full finding ▴Finding 2021-001 Approval of Payroll Transactions ? Significant Deficiency in Internal Controls Over Allowable Costs/Cost Principles Identification of the federal program U.S. Department of the Interior, Bureau of Indian Affairs ALN 15.U03 477 Cluster - 2019-2021 P.L. 102-477 Contract. Award No. A19AV00081. U.S. Department of Health and Human Services ALN 93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance Award No. 2020-444. Direct and Passthrough Southcentral Foundation ALN 93.441 Indian Self-Determination Award No. 243130002. Criteria or specific requirement Management is responsible to provide reasonable assurance that the costs paid for by federal funds are allowable and in accordance with the types of activities allowed per the compliance supplement. Condition Evidence of review is not consistently maintained for manual journal entries made to record accrued leave for employees for the programs. Cause Turnover and staffing issues as a result of the COVID-19 pandemic resulted in gaps in oversight of the controls. Effect or potential effect Federal funds could be expended for unallowed activities and unallowed costs. Questioned costs None Context 11 of the 75 payroll items selected for testwork lacked evidence of journal entry review for accrued leave entries for the federal programs. Identification as a repeat finding None Recommendation We recommend the Council review and update its internal controls over journal entries. We also recommend periodic monitoring of the review internal controls in place. Views of Responsible Official and Planned Corrective Action Management agrees with this finding. Management has high level mitigating controls where all leave balances are reviewed periodically, such a review was completed in preparation for the audit and adjustment were posted as necessary. Additional reviews were done to verify the journal entries without review stamps were correct once discovered during the audit. The accounting system controls have been reconfigured to ensure the individual entering the entry cannot post the entry; thus implementing an electronic documentation of review by a secondary person.
Finding 2021-001: Approval of Payroll Transactions ? Significant Deficiency in Internal Controls Over Allowable Costs/Cost Principles Corrective Action: Management has high level mitigating controls where all leave balances are reviewed periodically, such a review was completed in preparation for the audit and adjustment were posted as necessary. Additional reviews were done to verify the journal entries without review stamps were correct once discovered during the audit. The accounting system controls have been reconfigured to ensure the individual entering the entry cannot post the entry; thus, implementing an electronic documentation of review by a secondary person. Person Responsible: Amy Fredeen, Chief Financial Officer, 907-793-3431 Completion Date: March 31, 2022
Finding 2021-002 Approval of Reporting ? Non-compliance and Significant Deficiency in Internal Controls Over Compliance - Reporting Identification of the federal program U.S. Department of the Interior, Bureau of Indian Affairs ALN 15.U03 477 Cluster - 2019-2021 P.L. 102-477 Contract. Award No. A19AV00081. Criteria or specific requirement Uniform Guidance requires nonfederal entities to establish and maintain effective internal controls over the reporting compliance requirement for federal awards. Condition The report generated for participant information did not provide the necessary data required for reporting to the granting agency. Cause Controls in place were not designed to check for relevant data to be used for reporting participant information. Effect or potential effect The report submitted to the granting agency did not have accurate information about the number of participants. Questioned costs None Context During our testwork over reporting related to 477, we noted the Council reported a significantly higher number of participants in the report submitted to the granting agency than the eligible participants served for the year. Identification as a repeat finding None Recommendation Management should review existing controls over reporting and make revisions to ascertain that control identify significant inaccuracies. Views of Responsible Official and Planned Corrective Action Management agrees with this finding. The original report was filed using data pulled with the wrong date range. While all participants received services, they did not all receive services during the fiscal year. An amended 477 report was filed and new systems are being put into place to review the underlying data prior to submission through a streamlined process.
Show full finding ▾Hide full finding ▴Finding 2021-002 Approval of Reporting ? Non-compliance and Significant Deficiency in Internal Controls Over Compliance - Reporting Identification of the federal program U.S. Department of the Interior, Bureau of Indian Affairs ALN 15.U03 477 Cluster - 2019-2021 P.L. 102-477 Contract. Award No. A19AV00081. Criteria or specific requirement Uniform Guidance requires nonfederal entities to establish and maintain effective internal controls over the reporting compliance requirement for federal awards. Condition The report generated for participant information did not provide the necessary data required for reporting to the granting agency. Cause Controls in place were not designed to check for relevant data to be used for reporting participant information. Effect or potential effect The report submitted to the granting agency did not have accurate information about the number of participants. Questioned costs None Context During our testwork over reporting related to 477, we noted the Council reported a significantly higher number of participants in the report submitted to the granting agency than the eligible participants served for the year. Identification as a repeat finding None Recommendation Management should review existing controls over reporting and make revisions to ascertain that control identify significant inaccuracies. Views of Responsible Official and Planned Corrective Action Management agrees with this finding. The original report was filed using data pulled with the wrong date range. While all participants received services, they did not all receive services during the fiscal year. An amended 477 report was filed and new systems are being put into place to review the underlying data prior to submission through a streamlined process.
Finding 2021-002: Approval of Reporting ? Non-compliance and Significant Deficiency in Internal Controls Over Compliance ? Reporting Corrective Action: The original report was filed using data pulled with the wrong date range. While all participants received services, they did not all receive services during the fiscal year. An amended 477 report was filed and new systems are being put into place to review the underlying data prior to submission through a streamlined process. Person Responsible: Amy Fredeen, Chief Financial Officer, 907-793-3431 Anticipated Completion Date: The revised report was submitted June 8, 2022. The new data system will be in place by April 30, 2023.
Finding 2021-003 Allowable Costs/Cost Principles ? Significant Deficiency in Internal Controls Over Compliance Identification of the federal program U.S. Department of Health and Human Services ALN 93.441 Indian Self-Determination Award No. 243130002. Criteria or specific requirement Management is responsible to provide reasonable assurance that the costs paid for by federal funds are allowable and in accordance with the types of activities allowed per the compliance supplement. Condition Internal control procedures failed to catch errors in update of Payroll Action Forms. Cause Turnover and staffing issues as a result of the COVID-19 pandemic resulted in gaps in oversight of the controls. Effect or potential effect Federal funds could be expended for unallowed activities and unallowed costs. Questioned costs None Context 1 of the 25 payroll items selected for selected for testwork did not have updated Payroll Action Form in the employee files. Identification as a repeat finding None Recommendation We recommend the Council review and update its internal controls over payroll transactions. We also recommend periodic monitoring of the review internal controls in place. Views of Responsible Official and Planned Corrective Action Management agrees with this finding. Management has performed a 100% review of data entry for personnel changes against the source documentation. Additionally, a full review process for personnel changes has been implemented to review the accuracy of the entry to the source documentation.
Show full finding ▾Hide full finding ▴Finding 2021-003 Allowable Costs/Cost Principles ? Significant Deficiency in Internal Controls Over Compliance Identification of the federal program U.S. Department of Health and Human Services ALN 93.441 Indian Self-Determination Award No. 243130002. Criteria or specific requirement Management is responsible to provide reasonable assurance that the costs paid for by federal funds are allowable and in accordance with the types of activities allowed per the compliance supplement. Condition Internal control procedures failed to catch errors in update of Payroll Action Forms. Cause Turnover and staffing issues as a result of the COVID-19 pandemic resulted in gaps in oversight of the controls. Effect or potential effect Federal funds could be expended for unallowed activities and unallowed costs. Questioned costs None Context 1 of the 25 payroll items selected for selected for testwork did not have updated Payroll Action Form in the employee files. Identification as a repeat finding None Recommendation We recommend the Council review and update its internal controls over payroll transactions. We also recommend periodic monitoring of the review internal controls in place. Views of Responsible Official and Planned Corrective Action Management agrees with this finding. Management has performed a 100% review of data entry for personnel changes against the source documentation. Additionally, a full review process for personnel changes has been implemented to review the accuracy of the entry to the source documentation.
Finding 2021-003: Allowable Costs/Cost Principles ? Significant Deficiency in Internal Controls Over Compliance Corrective Action: Management has performed a 100% review of data entry for personnel changes against the source documentation. Additionally, a full review process for personnel changes has been implemented to review the accuracy of the entry to the source documentation. Person Responsible: Amy Fredeen, Chief Financial Officer, 907-793-3431 Completion Date: May 31, 2022
Finding 2021-004 Allowable Costs/Cost Principles ? Significant Deficiency in Internal Controls Over Compliance Identification of the federal program U.S. Department of the Interior, Bureau of Indian Affairs ALN 15.U03 477 Cluster - 2019-2021 P.L. 102-477 Contract. Award No. A19AV00081. Criteria or specific requirement Management is responsible to provide reasonable assurance that the costs paid for by federal funds are allowable and in accordance with the types of activities allowed per the compliance supplement. Condition Internal control procedures failed to catch errors in calculation of payroll allocations. Cause Turnover and staffing issues as a result of the COVID-19 pandemic resulted in gaps in oversight of the controls. Effect or potential effect Federal funds could be expended for unallowed activities and unallowed costs. Questioned costs None Context 1 of the 25 payroll items selected for selected for testwork had errors in calculation of allocations. Identification as a repeat finding None Recommendation We recommend the Council review and update its internal controls over payroll transactions. We also recommend periodic monitoring of the review internal controls in place. Views of Responsible Official and Planned Corrective Action Management agrees with this finding. In FY22 management streamlined and improved the payroll allocation process by replacing service codes with project/grant codes. This removed the complexity of having to convert the service codes to project/grant codes.
Show full finding ▾Hide full finding ▴Finding 2021-004 Allowable Costs/Cost Principles ? Significant Deficiency in Internal Controls Over Compliance Identification of the federal program U.S. Department of the Interior, Bureau of Indian Affairs ALN 15.U03 477 Cluster - 2019-2021 P.L. 102-477 Contract. Award No. A19AV00081. Criteria or specific requirement Management is responsible to provide reasonable assurance that the costs paid for by federal funds are allowable and in accordance with the types of activities allowed per the compliance supplement. Condition Internal control procedures failed to catch errors in calculation of payroll allocations. Cause Turnover and staffing issues as a result of the COVID-19 pandemic resulted in gaps in oversight of the controls. Effect or potential effect Federal funds could be expended for unallowed activities and unallowed costs. Questioned costs None Context 1 of the 25 payroll items selected for selected for testwork had errors in calculation of allocations. Identification as a repeat finding None Recommendation We recommend the Council review and update its internal controls over payroll transactions. We also recommend periodic monitoring of the review internal controls in place. Views of Responsible Official and Planned Corrective Action Management agrees with this finding. In FY22 management streamlined and improved the payroll allocation process by replacing service codes with project/grant codes. This removed the complexity of having to convert the service codes to project/grant codes.
Finding 2021-004: Allowable Costs/Cost Principles ? Significant Deficiency in Internal Controls Over Compliance Corrective Action: In FY22 management streamlined and improved the payroll allocation process by replacing service codes with project/grant codes. This removed the complexity of having to convert the service codes to project/grant codes. Person Responsible: Amy Fredeen, Chief Financial Officer, 907-793-3431 Completion Date: April 8, 2022
FAC accepted this audit on August 16, 2021 — management decision was due February 16, 2022.
FAC accepted this audit on September 22, 2020 — management decision was due March 22, 2021.
FAC accepted this audit on April 21, 2019 — management decision was due October 21, 2019.
FAC accepted this audit on April 25, 2018 — management decision was due October 25, 2018.
FAC accepted this audit on April 5, 2017 — management decision was due October 5, 2017.
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