TULE RIVER INDIAN HEALTH CENTER, INC.

EIN: 941669142

UEI: QS64UW13MQK1

Data as of August 22, 2026

TULE RIVER INDIAN HEALTH CENTER, INC.10 audit years23 findings15 repeat
10
Audit Years
23
Total Findings
15
Repeat Findings

FY 2025-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on May 26, 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 November 26, 2026 (95 days from today).

What is a management decision? →
2025-003
Eligibility
MATERIAL WEAKNESSREPEAT

Of the 60 participant files reviewed, the following was noted: • 5 samples out of 60 did not have proper documentation to receive medical services and/or renewed registration application to receive medical services. Context: The audit findings represent a systematic problem, see condition above. Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2022-004, 2023-001, and 2024-001. Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and that review of the online checklist is reviewed by someone other than the Patient Care Representative, and that this review is documented and maintained for review at a later date. Views of Responsible Officials: The Clinic will review all patient files to ensure all applicable documentation is located within each file. Any applicable documentation that is missing from the file will be requested from the patient to verify continued eligibility or services will be terminated. The Clinic will also implement an approval process for new patients to ensure patient eligibility is reviewed and approved prior to providing services.

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Full finding narrative

Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, “Contract Health Services” dated January 5, 1998. Condition: Of the 60 participant files reviewed, the following was noted: • 5 samples out of 60 did not have proper documentation to receive medical services and/or renewed registration application to receive medical services. Context: The audit findings represent a systematic problem, see condition above. Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2022-004, 2023-001, and 2024-001. Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and that review of the online checklist is reviewed by someone other than the Patient Care Representative, and that this review is documented and maintained for review at a later date. Views of Responsible Officials: The Clinic will review all patient files to ensure all applicable documentation is located within each file. Any applicable documentation that is missing from the file will be requested from the patient to verify continued eligibility or services will be terminated. The Clinic will also implement an approval process for new patients to ensure patient eligibility is reviewed and approved prior to providing services.

Corrective Action Plan

The supervisor of registration employees will oversee quarterly patient file reviews of patients registered as beneficiaries to ensure that the required documentation is acquired from the patients. Patient files that lack the required documentation, will be flagged in a way that will be noticeable by anyone that has access to the files. The clinic will also consider an outside department like PRC which also validates beneficiary information could get involved in a mid-fiscal year review of the beneficiary patient files to provide a secondary review of the files. The anticipated completion date will be 9/30/2026.

Prior Finding References

2024-001

About Eligibility →
2025-004
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEATQUESTIONED COSTS

During transactional testing, the following was noted: • 4 out of 8 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no consistent processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. • 4 out of 8 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. None of the 6 vendors were suspended or debarred. Context: The audit findings represent a systematic problem, see condition above. Cause: There were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $60,729 Repeat Finding: Yes, 2022-007, 2023-004, and 2024-002. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic’s procurement and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials: The Clinic will review the procurement standards set forth at 2 CFR part 200 and will update the procurement and purchasing policies to comply with all required purchasing standards. All vendors will be required to submit and certify a statement regarding debarment and suspension prior to contract award.

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Full finding narrative

Criteria: Nonfederal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR Part 200. Nonfederal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension and debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension,” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition: During transactional testing, the following was noted: • 4 out of 8 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no consistent processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. • 4 out of 8 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. None of the 6 vendors were suspended or debarred. Context: The audit findings represent a systematic problem, see condition above. Cause: There were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $60,729 Repeat Finding: Yes, 2022-007, 2023-004, and 2024-002. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic’s procurement and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials: The Clinic will review the procurement standards set forth at 2 CFR part 200 and will update the procurement and purchasing policies to comply with all required purchasing standards. All vendors will be required to submit and certify a statement regarding debarment and suspension prior to contract award.

Corrective Action Plan

A procurement checklist will be developed to require proper documentation if utilizing Federal Funds. The checklist will list specific thresholds for procurement based on funding type, and whether the procurement is construction related and list requirements and thresholds for the construction activity. A new vendor checklist will also be developed to ensure that the vendor is not debarred and/or suspended prior to conducting business with them. The checklist will also list other relevant documents that will be needed prior to first payment. The anticipated completion date will be 9/30/2026.

Prior Finding References

2024-002

About Procurement and Suspension and Debarment →

FY 2024-06-30

FAC accepted this audit on February 17, 2025 — management decision was due August 17, 2025.

2024-001
Eligibility
MATERIAL WEAKNESSREPEAT

Of the 60 participant files reviewed, the following was noted: • 60 samples out of 60 did not have record of review and approval separate from the person entering the information. • 6 samples out of 60 did not have proper proof of tribal membership to receive medical services and/or proper proof of residence covering the testing period to receive medical services. Context: The audit findings represent a systematic problem, see condition above. Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2022-004 and 2023-001. Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and that review of the online checklist is reviewed by someone other than the Patient Care Representative, and that this review is documented and maintained for review at a later date. Views of Responsible Officials and Planned Corrective Action: The Clinic will review all patient files to ensure all applicable documentation is located within each file. Any applicable documentation that is missing from the file will be requested from the patient to verify continued eligibility or services will be terminated. The Clinic will also implement an approval process for new patients to ensure patient eligibility is reviewed and approved prior to providing services.

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Full finding narrative

Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, “Contract Health Services” dated January 5, 1998. Condition: Of the 60 participant files reviewed, the following was noted: • 60 samples out of 60 did not have record of review and approval separate from the person entering the information. • 6 samples out of 60 did not have proper proof of tribal membership to receive medical services and/or proper proof of residence covering the testing period to receive medical services. Context: The audit findings represent a systematic problem, see condition above. Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2022-004 and 2023-001. Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and that review of the online checklist is reviewed by someone other than the Patient Care Representative, and that this review is documented and maintained for review at a later date. Views of Responsible Officials and Planned Corrective Action: The Clinic will review all patient files to ensure all applicable documentation is located within each file. Any applicable documentation that is missing from the file will be requested from the patient to verify continued eligibility or services will be terminated. The Clinic will also implement an approval process for new patients to ensure patient eligibility is reviewed and approved prior to providing services.

Corrective Action Plan

The Clinic will review all patient files to ensure all applicable documentation is located within each file. Any applicable documentation that is missing from the file will be requested from the patient to verify continued eligibility or services will be terminated. The Clinic will also implement an approval process for new patients to ensure patient eligibility is reviewed and approved prior to providing services. The anticipated completion date is 09/30/2025.

Prior Finding References

2023-001

About Eligibility →
2024-002
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT

During transactional testing, the following was noted: • 93.441 – 4 out of 6 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no consistent processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. • 93.441 – 4 out of 6 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. None of the 6 vendors were suspended of debarred. Context: The audit findings represent a systematic problem, see condition above. Cause: There were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $71,963. Repeat Finding: Yes, 2022-007 and 2023-004. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic’s procurement and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: The Clinic will review the procurement standards set forth at 2 CFR part 200 and will update the procurement and purchasing policies to comply with all required purchasing standards. All vendors will be required to submit and certify a statement regarding debarment and suspension prior to contract award.

Show full finding ▾
Full finding narrative

Criteria: Nonfederal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR Sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR Part 200. Nonfederal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension and debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension,” federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition: During transactional testing, the following was noted: • 93.441 – 4 out of 6 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no consistent processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. • 93.441 – 4 out of 6 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. None of the 6 vendors were suspended of debarred. Context: The audit findings represent a systematic problem, see condition above. Cause: There were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $71,963. Repeat Finding: Yes, 2022-007 and 2023-004. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic’s procurement and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: The Clinic will review the procurement standards set forth at 2 CFR part 200 and will update the procurement and purchasing policies to comply with all required purchasing standards. All vendors will be required to submit and certify a statement regarding debarment and suspension prior to contract award.

Corrective Action Plan

The Clinic will review the procurement standards set forth at 2 CFR part 200 and has updated our procurement and purchasing policies to comply with all required purchasing standards. All vendors will be required to submit and certify a statement regarding debarment and suspension prior to contract award. The anticipated completion date is 09/30/2025.

Prior Finding References

2023-004

About Procurement and Suspension and Debarment →

FY 2023-06-30

FAC accepted this audit on March 29, 2024 — management decision was due September 29, 2024.

2023-001
Eligibility
MATERIAL WEAKNESSREPEAT
Show full finding ▾
Prior Finding References

2022-004

About Eligibility →
2023-002
Eligibility
REPEAT
Show full finding ▾
Prior Finding References

2022-005

About Eligibility →
2023-003
Matching, Level of Effort, Earmarking
MATERIAL WEAKNESSREPEAT
Show full finding ▾
Prior Finding References

2022-006

About Matching, Level of Effort, Earmarking →
2023-004
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT
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2023-005
Reporting
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2022-008

About Reporting →

FY 2022-06-30

FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.

2022-003
Activities Allowed or Unallowed / Cost Allowability

Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: 2 CFR ?200.403(h) states: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: (g) be adequately documented." Condition/Context: During transactional testing the following was noted: ? 1 out of 1 IDC journal entry selection was lacking proper documented approvals of an authorized individual other than the preparer. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: Without additional review and approval, entries being made may have errors. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that management establish controls and implement policies to ensure that support of approval is obtained and maintained for all expenditure transactions including journal entries. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

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Full finding narrative

Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: 2 CFR ?200.403(h) states: "Except where otherwise authorized by statute, costs must meet the following general criteria in order to be allowable under federal awards: (g) be adequately documented." Condition/Context: During transactional testing the following was noted: ? 1 out of 1 IDC journal entry selection was lacking proper documented approvals of an authorized individual other than the preparer. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: Without additional review and approval, entries being made may have errors. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that management establish controls and implement policies to ensure that support of approval is obtained and maintained for all expenditure transactions including journal entries. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Corrective Action Plan

Persons responsible for corrective action plan: Resty Rios, Staff Accountant Resty.rios@crihb.org Adrianna Davisson, Grants Manager Adrianna.davisson@crihb.org It is the standard practice for all IDC Entries to be reviewed and approved prior to posting. However, due to employee turnover the review and approval process lacked sufficient documentation. The Clinic will ensure that all IDC Entries will be clearly documented with the appropriate review and approval signatures prior to posting to the financial records. The anticipated completion date is 6/30/2023.

About Activities Allowed or Unallowed, Allowable Costs / Cost Principles →
2022-004
Eligibility
MATERIAL WEAKNESSREPEAT

Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 60 participant files reviewed, the following was noted: ? 32 samples out of 60 did not have record of review and approval separate from the person entering the information. ? 2 samples out of 60 did not have proper proof of tribal membership to receive medical services. ? 2 samples out of 60 did not have proper proof of residence covering the testing period to receive medical services. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001. Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and that review of the online checklist is reviewed by someone other than the Patient Care Representative, and that this review is documented and maintained for review at a later date. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

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Full finding narrative

Program Information: AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 60 participant files reviewed, the following was noted: ? 32 samples out of 60 did not have record of review and approval separate from the person entering the information. ? 2 samples out of 60 did not have proper proof of tribal membership to receive medical services. ? 2 samples out of 60 did not have proper proof of residence covering the testing period to receive medical services. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001. Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and that review of the online checklist is reviewed by someone other than the Patient Care Representative, and that this review is documented and maintained for review at a later date. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Corrective Action Plan

Persons responsible for corrective action plan: Resty Rios, Staff Accountant Resty.rios@crihb.org Adrianna Davisson, Grants Manager Adrianna.davisson@crihb.org The Clinic will review all patient files to ensure all applicable documentation is located within each file. Any applicable documentation that is missing from the file will be requested from the patient to verify continued eligibility or services will be terminated. The Clinic will also implement an approval process for new patients to ensure patient eligibility is reviewed and approved prior to providing services. The anticipated completion date is 6/30/2023.

Prior Finding References

2021-001

About Eligibility →
2022-005
Eligibility
MATERIAL WEAKNESSREPEAT

Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 16 participant files reviewed, the following was noted: ? None of the 16 files had record of review and approval separate from the person entering the information. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and document the various levels of review that occur. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

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Full finding narrative

Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: An individual must meet the eligibility requirements as defined by Federal regulations published in Code of Federal Regulations (CFR), at Title 42, Section 136.21 through 136.25, and Indian Health Services, Part 2, Chapter 3, "Contract Health Services" dated January 5, 1998. Condition/Context: Of the 16 participant files reviewed, the following was noted: ? None of the 16 files had record of review and approval separate from the person entering the information. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period, along with lack of management oversight. Effect: By not ensuring proper reviews are occurring by a supervisor or other authorized individual, inaccurate information may have been entered into the online system, and ineligible participants could be receiving benefits. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-001 Recommendation: We recommend that the Clinic adhere to program policies and procedures as documented and the files are reviewed annually for completeness, and document the various levels of review that occur. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Corrective Action Plan

Persons responsible for corrective action plan: Resty Rios, Staff Accountant Resty.rios@crihb.org Adrianna Davisson, Grants Manager Adrianna.davisson@crihb.org The Clinic will review all participant files to ensure all applicable documentation is located within each file. The Clinic will also implement an approval process for new participants to ensure participant eligibility is reviewed and approved prior to providing services. The anticipated completion date is 6/30/2023.

Prior Finding References

2021-001

About Eligibility →
2022-006
Matching, Level of Effort, Earmarking
MATERIAL WEAKNESSREPEAT

Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: The requirements for matching are contained in 2 CFR section 200.306, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. The requirements for level of effort and earmarking are contained in program legislation, Federal awarding agency regulations, and the terms and conditions of the award. Per review of the award documents for Youth Tree, Youth Connections, and Youth Suicide Prevention, key staff have identified the following level of effort requirements: Youth Tree - ? Project Director @ 12.5% ? Youth Services/Recovery Support Coordinator @ 100% ? Lead Evaluator @ contractor level of efforts ? Family Coordinator @ 100% Youth Suicide Prevention- ? Project Director @ 100% Youth Connections Project- ? Project Director @ 100% Any changes in the key staff including level of effort, involving separation from the projects for 3 or more months, or a 25% reduction in time dedicated to the projects requires prior approval from SAMHSA. Condition/Context: During the audit, we noted that for the Youth Tree Program, a different individual was the project director during 2022; this key staff change was not previously approved by the funding agency as required in the grant agreement. Approval was received by the funding agency on May 25, 2022. During the audit, we noted that for the Youth Connections Project a different individual was the project director during 2022 and at a different level of effort than noted in the award; this key staff change was not previously approved by the funding agency as required in the grant agreement. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure level of effort changes for key staff were approved prior to the change taking place. Effect: By not obtaining prior approval from the funding agency of key staff changes, the Clinic may have someone in the key role not approved for the position. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-002. Recommendation: We recommend that the Clinic work to obtain prior approval for any key staff changes for the program, and ensure that written approval is received from the funding agency before implementing staffing changes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

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Full finding narrative

Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: The requirements for matching are contained in 2 CFR section 200.306, program legislation, Federal awarding agency regulations, and the terms and conditions of the award. The requirements for level of effort and earmarking are contained in program legislation, Federal awarding agency regulations, and the terms and conditions of the award. Per review of the award documents for Youth Tree, Youth Connections, and Youth Suicide Prevention, key staff have identified the following level of effort requirements: Youth Tree - ? Project Director @ 12.5% ? Youth Services/Recovery Support Coordinator @ 100% ? Lead Evaluator @ contractor level of efforts ? Family Coordinator @ 100% Youth Suicide Prevention- ? Project Director @ 100% Youth Connections Project- ? Project Director @ 100% Any changes in the key staff including level of effort, involving separation from the projects for 3 or more months, or a 25% reduction in time dedicated to the projects requires prior approval from SAMHSA. Condition/Context: During the audit, we noted that for the Youth Tree Program, a different individual was the project director during 2022; this key staff change was not previously approved by the funding agency as required in the grant agreement. Approval was received by the funding agency on May 25, 2022. During the audit, we noted that for the Youth Connections Project a different individual was the project director during 2022 and at a different level of effort than noted in the award; this key staff change was not previously approved by the funding agency as required in the grant agreement. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure level of effort changes for key staff were approved prior to the change taking place. Effect: By not obtaining prior approval from the funding agency of key staff changes, the Clinic may have someone in the key role not approved for the position. Questioned Costs: Not applicable. Repeat Finding: Yes, 2021-002. Recommendation: We recommend that the Clinic work to obtain prior approval for any key staff changes for the program, and ensure that written approval is received from the funding agency before implementing staffing changes. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Corrective Action Plan

Persons responsible for corrective action plan: Resty Rios, Staff Accountant Resty.rios@crihb.org Adrianna Davisson, Grants Manager Adrianna.davisson@crihb.org The Clinic has recently hired a Grant Manager whose responsibility will be to ensure to receive Agency approval in regards to any key staff changes including level effort, prior to implementation. The anticipated completion date is 6/30/2023.

Prior Finding References

2021-002

About Matching, Level of Effort, Earmarking →
2022-007
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEATQUESTIONED COSTS

Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

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Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 AL #: 93.441 U.S. Department of Health and Human Services Passed through California Rural Indian Health Board, Inc. Indian Health Services ? CRIHB 22, Indian Health Services ? CRIHB 21, COVID-19 Indian Health Services ? CRIHB 21 Award Numbers: 235-18-0004 Award Periods: 4/1/18-3/31/24 Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension & debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, ?Debarment and Suspension?, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Condition/Context: During transactional testing, the following was noted: ? 93.441 ? 4 out of 5 vendors reviewed did not have evidence of multiple competitive bids being obtained. ? 93.243 ? 2 out of 2 vendors reviewed did not have evidence of multiple competitive bids being obtained. Additionally, there are no processes in place to check to ensure vendors are not suspended or debarred prior to conducting business. ? 93.441 - 4 out of 5 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. ? 93.243 - 2 out of 2 vendors reviewed did not have evidence or processes in place to check to ensure vendors were not suspended or debarred prior to conducting business. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The Clinic was unaware of the requirement to check vendors for suspension and debarment prior to conducting business with vendors, and there were ineffective controls in place during the period over procurement, along with lack of management oversight. Effect: The Clinic is not enacting fair competition in the procurement process nor are they following their policies by making sure bidding support is provided before the appropriate officials sign the Purchase Order. Additionally, the Clinic may be paying vendors that are suspended and debarred which would be an unallowable cost. Questioned Costs: AL#: 93.441 Known: Procurement- $42,903 AL#: 93.243 Known: Procurement- $15,380 Repeat Finding: Yes, 2021-003. Recommendation: We recommend the Clinic conduct training for staff and program managers to review the Clinic?s procurement, and suspension and debarment policies and procedures along with federal regulations. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Corrective Action Plan

Persons responsible for corrective action plan: Resty Rios, Staff Accountant Resty.rios@crihb.org Adrianna Davisson, Grants Manager Adrianna.davisson@crihb.org The Clinic will review the procurement standards set forth at 2 CFR part 200 and update our procurement and purchasing policies to include all required purchasing standards as required. All vendors will be required to submit and certify a statement regarding debarment and suspension prior to contract award. The anticipated completion date is 6/30/2023.

Prior Finding References

2021-003

About Procurement and Suspension and Debarment →
2022-008
Reporting
MATERIAL WEAKNESS

Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: Internal control is a process, effected by an entity?s?[governing body], management and other personnel, designed to provide reasonable assurance regarding the achievement of objectives related to operations, reporting, and compliance. (Internal Control ? Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission, May 2013, p. 1) Monitoring and reporting program performance, 2 CFR section 200.328. The following reports are required to be submitted for this program: ? Annual Programmatic Progress Report for each award ? Annual SF-425 Report for each award Condition/Context: During testing of internal controls over the Annual Progress reports, 2 of 3 reports did not have documentation of review and approval. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure reports were documented as being approved prior to submission, along with lack of management oversight. Effect: Without effective internal controls over reporting, information reported to federal agencies may be inaccurate. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that the Clinic improve controls over the reporting function, which includes the documentation, review and approval of all required reports. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

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Program Information: AL #: 93.243 U.S. Department of Health and Human Services SAMHSA Youth Programs ? Youth Tree, Youth Suicide Prevention, Youth Connections Project Award Numbers: 6H79TI081193-01, 1H79SM082124-01, 1H79SM081540-01 Award Periods: 9/30/18-9/29/23, 6/30/19-6/29/24, 9/30/18-9/29/23 Criteria: Internal control is a process, effected by an entity?s?[governing body], management and other personnel, designed to provide reasonable assurance regarding the achievement of objectives related to operations, reporting, and compliance. (Internal Control ? Integrated Framework, Committee of Sponsoring Organizations of the Treadway Commission, May 2013, p. 1) Monitoring and reporting program performance, 2 CFR section 200.328. The following reports are required to be submitted for this program: ? Annual Programmatic Progress Report for each award ? Annual SF-425 Report for each award Condition/Context: During testing of internal controls over the Annual Progress reports, 2 of 3 reports did not have documentation of review and approval. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There were ineffective controls in place during the period to ensure reports were documented as being approved prior to submission, along with lack of management oversight. Effect: Without effective internal controls over reporting, information reported to federal agencies may be inaccurate. Questioned Costs: Not applicable. Repeat Finding: No. Recommendation: We recommend that the Clinic improve controls over the reporting function, which includes the documentation, review and approval of all required reports. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Corrective Action Plan

Persons responsible for corrective action plan: Resty Rios, Staff Accountant Resty.rios@crihb.org Adrianna Davisson, Grants Manager Adrianna.davisson@crihb.org It is the standard practice for all financial and programmatic reporting to be reviewed and approved prior to submission to the funding agency. The Clinic will ensure that all financial and programmatic reports will be clearly documented with the appopriate review and approval signatures prior to submission to the funding agency. The anticipated completion date is 6/30/2023.

About Reporting →

FY 2021-06-30

FAC accepted this audit on June 22, 2022 — management decision was due December 22, 2022.

2021-001
Eligibility
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2020-007

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2021-002
Matching, Level of Effort, Earmarking
MATERIAL WEAKNESS
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2021-003
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT
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FY 2020-06-30

FAC accepted this audit on July 15, 2021 — management decision was due January 15, 2022.

2020-004
Activities Allowed or Unallowed / Cost Allowability
MATERIAL WEAKNESS
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2020-005
Equipment & Real Property
MATERIAL WEAKNESS
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2020-006
Procurement & Suspension/Debarment
MATERIAL WEAKNESS
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2020-007
Eligibility
MATERIAL WEAKNESS
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FY 2019-06-30

FAC accepted this audit on March 18, 2020 — management decision was due September 18, 2020.

2019-001
Other
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