Affiliated Tribes of Northwest Indians

2024 – 001 Federal Agency: Environmental Protection Agency Federal Program Name: Indian Environmental General Assistance Program (EPA-GAP) Assistance Listing Number: 66.926 Federal Award Identification Number and Year: 02J23001, 2024 Award Period: January 1, 2023 through December 31, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance – Reporting Criteria or specific requirement: This award is subject to Federal Financial Reports (SF-425) and MBE/WBE Reports (EPA Form 5700-52A). Federal regulations require a system of internal control over the preparation and review of financial and performance reports prior to submission to agency. Condition: ATNI submitted progress reports as required in the grant agreement. However, we were unable to verify documented review and approval process. Questioned costs: None. Context: ATNI submitted progress reports to the agency and were accepted by the agency. However, without adequate documentation, we were unable to verify ATNI’s review and approval process. Cause: ATNI did not have a process in place to adequately document reviews and approval of reports. Effect: Noncompliance with the reporting requirement may result in inaccurate or improper reports submitted to the agency. Repeat Finding: No Recommendation: We recommend ATNI implement a standardized methodology to document its internal control process over progress reporting. Views of responsible officials: Please see the attached Management’s Corrective Action Plan.

Environmental Protection Agency Affiliated Tribes of Northwest Indians (ATNI) respectfully submits the following corrective action plan for the year ended December 31, 2024. Audit period: January 1, 2024, to December 31, 2024 FINDINGS AND QUESTIONED COSTS—MAJOR FEDERAL PROGRAM 2024-001 – Significant Deficiency in Internal Control over Compliance – Reporting Recommendation: We recommend ATNI updates the grant policies and procedures to include a documented review procedure. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned in response to finding: Management has implemented new procedures to ensure the review of program reports are sufficiently documented. This included drafting a new Grant Management Policy and Grant Procedures Manual, which will be approved by the Board of Directors in September 2025. Name of person responsible for the corrective action plan: Amber Schultz-Oliver, Executive Director. Contact: ambers@atnitribes.org Planned completion date for the corrective action plan: New procedures have been implemented as of August 30, 2025.