x,^osr%
•o
I " \
s a
Office of Inspector General
% * Audit Report
%
*4 PHCrte
EPA Grants Awarded to the
Rosebud Sioux Tribe
Report No. 1000370-2002-1-00096 March 19, 2002
-------
Inspector General Resource Center
Conducting the Audit: Central Audit and Evaluation Resource Center
Denver, Colorado Office
EPA Region Covered:
Program Offices Involved:
Audit Conducted by:
Region 8
Tribal Assistance Program
Grants, Audits, and Procurement Program
Larry Dare
Chris Dunlap
Thomas Herrod
Cover: The illustration is part of an EPA poster that depicts Tribes' sovereign right to protect the
water, land, and air. The cover illustration represents air.
-------
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
OFFICE OF INSPECTOR GENERAL
CENTRAL AUDIT AND EVALUATION RESOURCE CENTER branch offices:
901 NORTH 5TH STREET 1445 Ross Avenue, Suite 1200
KANSAS CITY, KANSAS 66101 Dallas, Texas 75202-2733
913-551-7878 214-665-6621
FAX: 913-551-7837 FAX: 214-665-6589
April 11, 2002 999 18th Street Suite 300
Denver, Colorado 80202-2405
303-312-6872
FAX: 303-312-6063
MEMORANDUM
SUBJECT: EPA Grants Awarded to the Rosebud Sioux Tribe
Report No. 1000370-2002-1-00096
FROM: Jeff Hart
Branch Manager
Denver Office
TO: J ack McGraw
Acting Regional Administrator
Region 8
Attached is our report, EPA Grants Awarded to the Rosebud Sioux Tribe. This report includes
our independent assessment of four Rosebud Sioux environmental grants and Rosebud Sioux's general
management of its environmental program.
ACTION REQUIRED
In accordance with EPA Order 2750, you, as the action official, are required to provide our
office with a proposed draft management decision specifying the Agency's position on our
recommendation on costs questioned and other recommendations in this report. The draft management
decision is due within 120 calendar days of the date of this transmittal memorandum.
Our report includes an assessment of your draft report comments. We also included your
written comments as Appendix I.
If you have any questions, please call me at (303) 312-6169 or Larry Dare at (303) 312-6969.
Please refer to report number 1000370-2002-1-00096 on any related correspondence.
Attachment
-------
(this page intentionally left blank)
-------
Table of Contents
Independent Auditor's Report 1
Audit Results 2
Objective 2
Scope and Methodology 2
Findings 3
Recommendations 5
Agency Comments and OIG Evaluation 5
Exhibits
A: Summary of Balance Due EPA 7
B: Summary of Audit Results for Water Grant 1008541970 8
C: Summary of Audit Results for General Assistance Program
Grant NI998457010 10
D: Summary of Audit Results for Pesticides Grant E00827198 12
E: Summary of Audit Results for Pesticides Grant E00827199 14
Appendices
I: Region 8 Response 17
II: Distribution 19
Report No. 1000370-2002-1-00096
-------
(this page intentionally left blank)
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
Independent Auditor's Report
We have examined the costs claimed on the final Financial Status Report (Form 269A) and Request for
Advance or Reimbursement (Form 270) for each of the grants listed in the Scope and Methodology
section submitted by the Rosebud Sioux Tribe, Rosebud, South Dakota (grantee). The preparation and
certification of the claims are the responsibility of the grantee. Our responsibility was to express an
opinion on the claims.
We conducted our examination in accordance with Government Auditing Standards, issued by the
Comptroller General of the United States. Those standards require that we plan and perform the audit
to obtain reasonable assurance about whether the claims submitted by the grantee are free of material
misstatement and are eligible under the grant agreements. An audit includes examining, on a test basis,
evidence supporting the amounts and disclosures in the final claims. An audit also includes assessing
the accounting principles used and significant estimates made by management in preparing the claims.
We believe that our audit provides a reasonable basis for our opinion.
As discussed in Exhibits A through E, the grantee received reimbursement for costs not adequately
supported in the accounting records, ineligible under Environmental Protection Agency (EPA)
regulations and grant requirements, or unreasonable. In most instances, the grantee inadequately
supported costs because it did not properly document payroll.
In our opinion, because of the effects of the matters discussed in the preceding paragraph, the claimed
costs referred to above and presented in Exhibits A through E do not present fairly costs claimed
according to the law, regulations, grant requirements, and other applicable Federal guidance.
Jeff Hart
Branch Manager
Denver Office
Central Audit and Evaluation Resource Center
Office of Inspector General
Fieldwork End: March 5, 2002
1
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
Audit Results
In response to a December 7, 1999 allegation letter, we reviewed: (1) the legality of EPA Region 8's
Tribal Assistance Program grants, (2) the Tribal Assistance Program's internal management, and
(3) grantee management of environmental programs and expenditure of grant funds. We reported on
the first two issues in our September 29, 2000 report, Increased Focus on Grant Management and
Internal Relationships Would Improve Region 8's Tribal Assistance Program. To address the third
issue, we conducted financial audits of four grantees. We judgmentally selected the four grantees
based on their significant involvement with EPA programs, past performance, and the fact that each
had several recently closed grants for which we expected to find complete financial records. This
report provides our findings at one of those grantees - the Rosebud Sioux Tribe, Rosebud, South
Dakota.
Objective
Our overall objective was to determine whether the grantee effectively managed its environmental
grants. To accomplish this objective, we asked the following question: Were costs claimed for grants
eligible, reasonable, and supported, and were the costs in compliance with grant terms and conditions
as well as applicable Federal statutes and regulations? We did not determine whether the grantee
accomplished all the objectives of the grants.
Scope and Methodology
EPA paid the grantee $452,175 under the following assistance agreements:
Program
Grant No.
Financial Status
Report Form 269A
Amount
Water Section 106
1008541970
February 6, 2001
$175,746
General Assistance Program
NI998457010
August 17, 2000
199,429
Pesticides
E00827198
November 30, 1998
38,500
Pesticides
E00827199
December 16, 1999
38,500
Total
$452,175
We selected these four grants to obtain a cross-section of the grantee's environmental program
and because the grantee had received final payment from EPA for each grant. Grant 1008541970
involved water quality projects from April 1997 through March 2000. Grant NI998457010
involved activities from August 1996 through March 2000 for increasing tribal capacity and
2
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
management capabilities. Grants E00827198 and E00827199 were for developing and enhancing
comprehensive toxic substance enforcement programs during fiscal years 1998 and 1999,
respectively. EPA was responsible for 100 percent of eligible costs associated with the
NI998457010 grant and 95 percent of eligible costs for the other three grants. For those three
grants, the grantee funded the remaining five percent. The cost for the four projects totaled
$468,287, which included EPA payments of $452,175.
For each grant, the grantee certified on Standard Form 270, Request for Advance or
Reimbursement, that the costs complied with grant terms. Subsequently, the grantee certified on
Standard Form 269A, Financial Status Report, that all outlays and unliquidated obligations were
for the purposes set forth in the grant documents.
We visited the Rosebud Sioux Reservation during the week of April 30, 2001. We reviewed the
four grants, detailed expense ledgers, and accompanying receipts and other supporting
documentation.
Findings
We Questioned 86 Percent of Costs Claimed
We questioned 86 percent, or $401,527, of all costs claimed under the four grants we audited.
EPA's share of questioned costs is $387,621. The questioned costs primarily consist of
unsupported payroll costs (salaries and fringe benefits) and related indirect costs. Specifically:
We questioned $320,185 in payroll costs1 because the grantee's documentation of payroll
disbursements did not meet Office of Management and Budget Circular A-87 requirements.
Because the grantee used payroll costs as the basis for indirect costs and, as noted, the method
of charging salaries did not meet Office of Management and Budget requirements, we
questioned $64,603 in indirect costs2.
The remaining questioned costs of $16,739 involved travel, vehicle expense, supplies,
equipment, contracts, utilities, and match.
1 The $320,185 in questioned payroll costs represents the sum of all four grants' payroll costs: $112,909
from the Water Grant (Exhibit B); $146,436 from the General Assistance Program Grant (Exhibit C); $29,312
from the 1998 Pesticides Grant (Exhibit D); and $31,528 from the 1999 Pesticides Grant (Exhibit E).
2 The $64,603 in questioned indirect costs represents the sum of all four grants' indirect costs: $22,774
from the Water Grant (Exhibit B); $29,539 from the General Assistance Program Grant (Exhibit C); $5,921 from
the 1998 Pesticides Grant (Exhibit D); and $6,369 from the 1999 Pesticides Grant (Exhibit E).
3
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
Exhibit A shows overall costs claimed and questioned while Exhibits B through E provide detailed
summaries for each of the four grants.
Internal Controls Did Not Support Good Grant Management
The General Accounting Office's November 1999 Standards for Internal Control in the Federal
Government (Standards) establish standards that should be part of any organization's management.
According to the Standards, sufficient internal control helps provide reasonable assurance that an
organization's operations are effective and efficient, financial reporting is reliable, and applicable
laws and regulations are followed. A strong internal control structure includes five components:
(1) control environment, (2) risk assessment, (3) control activities, (4) information and
communications, and (5) monitoring.
Even though our audit did not include a comprehensive review of the grantee's internal controls for
managing its Federal grants, we observed two material weaknesses during our audit that raised
serious concerns about the ability of the Rosebud Sioux Tribe to adequately manage environmental
grants. Tribal leadership, management, and staff did not emphasize the importance of good
internal controls and did not adequately communicate program or financial information.
Control Environment: Rosebud Sioux Tribe's leadership did not emphasize and, as a
result, management and staff did not establish a positive control environment, the
foundation for all other internal control standards. The Standards state that a positive
control environment includes competent staff with high integrity and ethical values, strong
management oversight of staff, clearly defined staff authority and responsibility, and strong
human capital policies and practices. Management provided neither the discipline and
structure nor the climate to positively influence the quality of internal controls. For
example, management did not require staff to charge time to individual projects, nor did
management ensure environmental staff complied with grant provisions. In addition,
management did not establish an effective organizational structure and management did not
implement effective oversight practices.
Information and Communications: Rosebud Sioux Tribe management did not
adequately communicate program or financial information with either EPA or Tribal
management. The Standards require pertinent information to be, " identified, captured, and
distributed to the right people in sufficient detail and at the appropriate time to enable them
to carry out their duties and responsibilities efficiently and effectively." Timely information
should be available and in a form that allows Rosebud management and staff as well as
EPA staff to ensure programs operate effectively and efficiently. Timely Financial Status
Reports help EPA and Tribal managers determine whether funds are sufficient to complete
required tasks and program progress reports highlight accomplishments and areas that need
extra attention. However, Rosebud Sioux Tribe staff submitted Financial Status Reports
and quarterly status reports late or not at all and, in many cases, could not locate
accounting records necessary to support claimed costs.
4
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
Recommendations
We recommend that the Acting Regional Administrator, Region 8:
1. Recover $387,621 in payments made to the grantee for which we questioned costs.
2. Designate the grantee as high risk until the grantee develops and implements written
procedures and controls to ensure that its:
(a) financial management system can adequately account for and support all claimed costs;
and
(b) payroll system meets Office of Management and Budget Circular A-87 requirements.
3. Suspend all current and new grants if, after 6 months, the grantee has not made substantial
progress toward meeting the requirements of recommendation 2.
4. Discuss the importance of strong internal controls including meaningful, timely program
performance reporting with Rosebud Sioux Tribe managers.
Agency Comments and OIG Evaluation
Region 8 officials generally agreed with the findings and recommendations. Regional staff
provided comments to clarify portions of the report and we have incorporated these comments and
modified the report as appropriate. We have included the Region's complete response in Appendix
I.
We reviewed the documentation the grantee sent to the Region regarding questioned costs and
agree with the Region that the materials the grantee provided support $12,413 of the costs
questioned in our draft report. As a result we have changed recommendation 1 to read: "Recover
$387,621 in payments made to the grantee for which we questioned costs."
The Region agreed to designate the grantee as high risk and noted that the grantee has already
made significant timekeeping changes to its payroll system that, if executed, will bring the grantee
into compliance with Office of Management and Budget Circular A-87. However, in order to fully
comply with EPA Order 2750, the Region must request from the grantee a corrective action plan
describing how it will comply with recommendation 2. The grantee's corrective action plan should
include milestone dates and specific actions it will take in order to correct the issues noted in
recommendation 2.
5
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
The Region substantially agreed with recommendation 3. We agree that the Region should
reevaluate the grantee's financial management system after 6 months to determine whether the
grantee has made substantial progress correcting deficiencies. We also agree that if the grantee
has fully complied the Region should remove the grantee's high risk designation. We believe
however, that the Region should recognize that if the grantee has made little or no progress, the
Region should withhold future grants until the grantee complies with Office of Management and
Budget Circular A-87.
The Region did not agree that establishing a strategic or action plan to ensure future costs claimed
are eligible, reasonable, and supported is practical. The Region pointed out that short of
demanding full documentation for all future costs claimed, it could not ensure all costs were
legitimately reimbursable. Because that recommendation applied to other Tribes in the Region as
well, we removed that recommendation from this report and will include a similar recommendation
in our report on Region 8 program performance issues.
The Region agreed that it would emphasize the importance of strong internal controls during its
next visit to the Tribe.
6
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
Exhibit A
Summary of Balance Due EPA
Water Grant 1008541970
(See Exhibit B)
$187,806 Claimed
$150,965 Questioned
$36,841 Total Allowable
EPA Payments as of 9/6/2000
$175,746
EPA Share (95% of allowable)1
$34,999
Balance Due EPA
$140,747
General Assistance Program Grant
NI998457010 (See Exhibit C)
$199,429 Claimed
$176,783 Questioned
$22,646 Total Allowable
EPA Payments as of 4/25/2000
$199,429
EPA Share (100% of allowable)
$22,646
Balance Due EPA
$176,783
1998 Pesticides Grant E00827198
(See Exhibit D)
$40,526 Claimed
$36,018 Questioned
$4,508 Total Allowable
EPA Payments as of 6/28/1999
$38,500
EPA Share (95% of allowable)
$4,282
Balance Due EPA
$34,218
1999 Pesticides Grant E00827199
(See Exhibit E)
$40,526 Claimed
$37,761 Questioned
$2,765 Total Allowable
EPA Payments as of 3/27/2001
$38,500
EPA Share (95% of allowable)
$2,627
Balance Due EPA
$35,873
Total Costs Claimed:
$468,287
Total Costs Questioned:
$401,527
Total Allowable:
$ 66,760
Total EPA Payments Made:
$452,175
Total EPA Share Allowable:
$ 64,554
Balance Due EPA:
$387,621
Note
1. EPA share represents EPA's portion of allowable project cost.
7
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
Exhibit B
Summary of Audit Results for Water Grant 1008541970
Costs Questioned As:
Categories
Costs
Claimed
Ineligible
Unreasonable
Unsupported
Total
Payroll
$112,909
$112,909
$112,9091
Travel
9,806
1,038
1,038 2
Vehicle Expense
4,594
Supplies
9,561
$1,171
1,1713
Contractual
11,615
Equipment
1,624
Utilities
2,862
1,011
1,011 4
Indirect Costs
22,774
22,774
22,774 5
Recipient Match
12,061
12,061
12,061 6
Total
$187,806
$1,171
$149,793
$150,965 7
Total Allowable (Claimed less Questioned)
$36,841
Summary of Balance Due EPA
EPA Payments as of 9/6/2000
$175,746
EPA Share (95% of allowable)
34,999
Balance Due EPA
$140,747
Notes
1. We questioned $112,909 of salaries and related fringe benefit costs as unsupported
because the grantee did not use an acceptable basis for charging salaries. The grantee
neither maintained an after-the-fact accounting of time charges nor certified that any
employees worked solely on the water grant. Office of Management and Budget
Circular A-87 requires that when employees work on more than one activity or cost
objective, their salary or wage distribution must be supported by documentation that
reflects an after-the-fact distribution of the actual activity of each employee.
Specifically, Office of Management and Budget Circular A-87 provides that, "Budget
8
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
estimates or other distribution percentages determined before the services are performed
do not qualify as support for charges to Federal awards . . " The Circular further
requires that when employees expect to work solely on a single Federal award, "charges
for their salaries and wages will be supported by periodic certifications that the
employees worked solely on that program for the period covered by the certification . .
" Certifications must be prepared at least semi-annually and signed by the employee or
a supervisor having first-hand knowledge of the work performed. Office of
Management and Budget Circular A-87 provides that "substitute systems," such as
quantifiable measures of employee effort, may be used instead of an after-the-fact
distribution of an employee's actual activity.
We questioned $1,038 of travel costs as unsupported because of insufficient information
provided to evaluate the eligibility of reimbursed costs.
We questioned $1,171 of supply costs as ineligible because the grantee incurred the
costs before the beginning of the grant period. 40 CFR §30.28 provides that where a
funding period is specified, a recipient may charge to the grant only allowable costs
resulting from obligations incurred during the funding period and any pre-award costs
specifically authorized by EPA.
We questioned $1,011 of utility costs as unsupported because of insufficient information
provided to evaluate eligibility. Specifically, the grantee did not provide us a copy of
either a vendor's invoice or evidence of disbursement made to a vendor.
We questioned $22,774 of indirect costs as unsupported because we questioned all of
the payroll costs (salary and fringe benefits), as discussed in Note 1, and because the
grantee used salaries as the basis for indirect costs. Even if the grantee supported all
salaries and fringe benefits, we would still question the eligibility of $1,329 of indirect
costs because the grantee did not apply the indirect cost rate in effect during the
applicable time period. Had the grantee applied the correct rate, it would have claimed
$1,329 less than it did under this grant.
We questioned $12,061 of recipient match costs as unsupported because the grantee
provided inadequate documentation to support the match amount to enable the auditors
to determine cost eligibility.
Does not add due to rounding.
9
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
Exhibit C
Summary of Audit Results for
General Assistance Program Grant NI998457010
Costs Questioned As:
Categories
Costs
Claimed
Ineligible
Unreasonable
Unsupported
Total
Payroll
$146,436
$7,607
$138,829
$146,436 1
Travel
11,299
$64
100
164 2
Vehicle Expense
603
289
289 3
Supplies
6,190
85
00
cn
Contractual
1,993
270
270 5
Utilities
3,369
Indirect Costs
29,539
3,015
26,524
29,539 6
Total
$199,429
$10,977
$64
$165,742
$176,783
Total Allowable (Claimed less Questioned)
$22,646
Summary of Balance Due EPA
EPA Payments as of 04/25/2000
$199,429
EPA Share (100% of allowable)
22,646
Balance Due EPA
$176,783
Notes
1. We questioned $138,829 of salaries and related fringe benefit costs as unsupported because the
grantee did not use an acceptable basis (as outlined in Office of Management and Budget
Circular A-87) for charging salaries. See Exhibit B, Note 1. In addition, we questioned $7,607
in salary and related fringe costs as ineligible. The grantee's requisition/order form stated that
the $7,607 was part of a charge to the grant, "To cover amount over expended as (the Lead)
Grant ended 9/30/98 and the Water Res Secy did not submit a Personnel Action to end . . .
salary and supplement resulting in an over expended of Sal/Frng & Indirect Cost = $9,144.20."
The program monitor explained that this charge resulted from cuts in the lead program's
funding and compensation owed the director of the lead program for work done after that grant
10 Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
expired. Office of Management and Budget Circular A-87 requires that, "Any cost allocable to
a particular Federal award or cost objective under the principles provided for in this Circular
may not be charged to other Federal awards to overcome fund deficiencies (emphasis added),
to avoid restrictions imposed by law or terms of the Federal awards, or for other reasons."
2. We questioned $164 of travel costs. Specifically, we questioned $100 as unsupported.
We questioned $64 as unreasonable because the traveler stayed an extra 2 days at the
destination with no justification.
3. We questioned $289 of vehicle costs as unsupported because the documentation did not relate
vehicle usage to the purpose of the grant.
4. We questioned $85 of supply costs as ineligible because the purchases (a $25 charge for
business cards and $60 for a beaded nameplate and matching pen) did not support the purpose
of the grant.
5. We questioned $270 of contractual costs to pay for water samples due to the ineligibility of
implementation activities under the General Assistance Program. Water sample costs should be
paid from the grantee's water grant.
6. We questioned $26,524 of indirect costs as unsupported because we questioned $138,829 of
salaries, as discussed in Note 1, and the grantee used salaries and fringe benefits as the basis for
indirect costs. In addition, even if the grantee supported all salaries, we would still question the
eligibility of $3,015. Specifically, we questioned $1,537 based on ineligible payroll and fringe
benefit costs (see Note 1), and $1,478 because the grantee did not apply the correct indirect
cost rate in effect during the grant period.
11
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
Exhibit D
Summary of Audit Results for Pesticides Grant E00827198
Costs Questioned As:
Categories
Costs
Claimed
Ineligible
Unreasonable
Unsupporte
d
Total
Payroll
$29,312
$29,312
$29,312 1
Travel
1,516
(3)2
Vehicle Expense
1,377
Supplies
744
Utilities
908
40
CO
O
Indirect Costs
5,921
5,921
5,921 4
Unidentified
748
748
748 5
Total
$40,526
$36,018
$36,018
Total Allowable (Claimed less Questioned)
$4,508
Summary of Balance Due EPA
EPA Payments as of 06/28/1999
$38,500
EPA Share (95% of allowable)
4,282
Balance Due EPA
$34,218
Notes
1. We questioned $29,312 of salaries and related fringe benefit costs as unsupported because the
grantee did not use an acceptable basis (as outlined in Office of Management and Budget
Circular A-87) for charging salaries. See Exhibit B, Note 1.
2. The grantee expended $3 more than it claimed for travel. As a result, we added $3 to its
reimbursable amount.
3. We questioned $40 of utility costs as unsupported because the grantee provided insufficient
documentation to evaluate the eligibility of costs.
12
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
4. Because we questioned all salary and fringe benefits, as discussed in Note 1, and the grantee
used salaries and fringe benefits as the basis for indirect costs, we questioned $5,921 of indirect
costs as unsupported.
5. This $748 represents the difference between total outlays reported on the final Financial Status
Report and the grantee's accounting records. Therefore, since the grantee could not account
for this amount, we questioned the $748 as unsupported.
13
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
Exhibit E
Summary of Audit Results for Pesticides Grant E00827199
Costs Questioned As:
Categories
Costs
Claimed
Ineligible
Unreasonable
Unsupporte
d
Total
Payroll
$31,528
$31,528
$31,528 1
Travel
546
Vehicle Expense
1,286
Supplies
784
Equipment
99
Utilities
51
Indirect Costs
6,369
6,369
6,369 2
Unclaimed Cost
(136)
(136)
(136)3
Total
$40,5264
$37,761
$37,761
Total Allowable (Claimed less Questioned)
$2,765
Summary of Balance Due EPA
EPA Payments as of 03/27/2001
$38,500
EPA Share (95% of allowable)
2,627
Balance Due EPA
$35,873
Notes
1. We questioned $31,528 of salaries and related fringe benefit costs as unsupported because
the grantee did not use an acceptable basis (as outlined in Office of Management and Budget
Circular A-87) for charging salaries. See Exhibit B, Note 1.
2. We questioned $6,369 of indirect costs as unsupported because we questioned all of the
salary and fringe benefits, as discussed in Note 1, and the grantee used salaries as the basis
for indirect costs.
14
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
3. This amount represents the difference between total outlays reported on the final Financial
Status Report of $40,526 and the grantee's accounting records in the amount of $40,662.
Since the grantee expended $136 more in allowable unclaimed costs than it reported on its
Financial Status Report, this amount should be added to the grantee's reimbursable costs.
4. Total does not add due to rounding.
15
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
(this page intentionally left blank)
16
Report No. 1000370-2002-1-00096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
Appendix I
Region 8 Response
UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
RESBM a
999 15™ STREET - SUHTE 8#9
DENVER, CO
ttione
http:0vrwwvpa.oOv/rvgionW
L'EC i 7 2001
Rel"; STMN-Ci
MHMORANDrM
St'HJI'Cr:
I WiM;
i'hi^ draft -lodit report nf f-nur Kosc^ul Slow frihc grants [ceamircctrch dtsaitowire u
Uitjtff atiR'unl ut Msls. !"ht "Intr lus pnnkkd nniMtata it' «.<< f:i;it %• hiu rcvicv»vd. .ind »-lich
.ipp«jr ,(i iiirqtti'tlv document §3 1,359.91 of casts qutritwned iti the draft report We wiJI
prm rJo these 'tiK.u*ncni<; m ycm for your f-nnsutefatioii. A> a result, we hcticvc ftsxiffiirtyiitltitioa
£1 wlnjcid reiid: Recove.- S38S.245 nf tjuesiiDficd cpms.
The Rcpi>n agrees wuh 'lie r«MtmientL«icm ft) doi^msfu the HitAcfrul Smux bribe as a
"hiph nsk" jrrantcc. We have pjeviousty jncJ vjcIi a dusi^iiation tor <1 gras'.tt thai hiid serkmx
problems complying with cwnt rcquiTTTOcnlN. The Tribe wi'i need to take strong action tc-
suIJiins thetr !ir;VK-i"il Diy.n.fcgemisft'tf mid payroll sysi«t» iL-lkisitMeik, tncludirig the deveKijuiien:
rfpnvcdiirc*. t<> tnii'l a,n: Mtppurt alt cusij clumit'd wul ensure Koserad'i tki>roll system
iiieeis OMB icguiitrrvicrs RuiftaiJ ItJts ulfeudv made .sign ilk mi* umekLvi'iflc Uiaagts ".«»
ri pay mil system thrt. if carried out, will bring it ks'.n compliance with OMfV Circular A-8?
RqMKKKTItis
Wlulc wc .lutwiifteiftlly ;ifcc with rewnimraiuukra wt would prefer Lit recvaiuuie
RuMdHid'h r,a.V'tiil maiMgetneut voters after .six jr.iHiths suid, if iliey are nuking ^tib.iUniiai
progress to corr.pJy with rsvormncitdwioRS *J<») and V2(b), continue Ko work with tfrem to tnsufj
compliance. K they Have fully complied, we would remove dicir "high ri-.k" dc.iSOiatwn.
i i>e Rcckw di«i Bui afttff With the netjd U>r Recwnmendation 4(4, "Requite R«itw S
stuff, ft£i:UiiL» w,illi Lin* ^ruiHee aiKi EPA headtjiiarini staff. to develop u strategic, dciMm plan to
A
** Prtmtf m RocyeHxi Papar
.er, r#^.
,ff
¦i'
Audit of RswebuiJ Sioux Iiibe
Audit No ;ntti-eg-fjo03?o
Juck Mel i raw
, Anting Kegian.il Adminis-timicr '
ietV Hurt
Hranch Manager
Dtmver Otlief
Keport ino. iuuuj /u-zuuz-i-uu096
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
Appendix I
Region 8 Response (continued)
imure- future comb daunec are eligible, «asi*naMe. and supported, uiid tlisit the grantee c:iraplici
wilh mil gnwi n.\)uir«-rnrrxs;mil sijiplhuhle Federal gMi;tw and regulsstiorw." Hex* J'ribc h:in
H"iisHis tiiuiMcii arid poyrdl s>stem itelkicrwio. fh.tl irust aidrwed, tuuJ mjr
to pro\ idiitg the "Irtbi: with teduitefd ifeMikiiHX' Oouv thu i rtbe's sy^iais. I»jvl- been
udequa'clv tp^cadtxL wc will jxnodk«ilh ask iur dm.ums<.;Ution that «il! sallow- u.i !u as>e>.i how
ciTcilivcfy the miprweTHrnis have t*cn ransfc We m.w also uorrskkr 3 site \ i«?it at wmr ftiHir,'
date to review tlieir record's, and uc Tribe wi'l have to continue to perform annual sinole audits
Yuw recammencLiricm tmpkes NOmethitip Kut-'Slaruiai.lv pra'.er than this, as far as "so ensure
fisHst: costs elu tikJ sitv eligible, rcawns'hie r«t -supported .. " ^ticri nf rtcnwndwig full
dL'cwiiL'iiiijSivit for Ji'l the ToK-s eos!,< unto FPA gtaws ws dwifl not ^^tttc.siwft 6 result
A rain fte isgrec w.th > ouf other rrcoii«iienifaiit>tli, thu-, lite Tiibe he dcsii!flali"d "high risk,*" tlscl
thi:y wpg-nrie thrir pnKrcd-,jn;,s sind controls, rind 1l1.1t lbc\ piU mpkre finiEnci.'ji management and
payroll system; the, meet Federal grant ncqmrrmcnts. By agreeing to take the steps wutiincd in
ysmr reawriOTcndalifliS!- we beiieve we have, in essicnce. Uiinx-J :« an articn plan in help
Rosebud comply wilh F.PA mil other Ftxfcra hjmwi.ii manani-nenr rcquwmcnU.
RcuumuieaciErjMS M h u.-xleur ami unnecessary, in our viewpoint
Finally, we agree with ReeommeirfatlouiS and will tdleate lite importance of strong
taitfiiai control* during
-------
EPA Grants Awarded to
the Rosebud Sioux Tribe
Appendix II
Distribution
Office of Inspector General
Inspector General
EPA Headquarters Office
Comptroller (2731 A)
Director, Grants Administration Division (3903R)
Agency Audit Followup Coordinator (2724A)
Associate Administrator for Congressional and Intergovernmental Relations
(1301A)
Associate Administrator for Communications, Education, and Media Relations
(1101 A)
Region 8 Office
Regional Counsel
Assistant Regional Administrator, Office of Partnerships and Regulatory
Assistance
Associate Assistant Regional Administrator, Office of Partnerships and
Regulatory Assistance
Director, Tribal Assistance Program
Assistant Regional Administrator, Office of Technical and Management Services
Director, Grants, Audits, and Procurement Program
Director, Financial Management Program
Audit Followup Coordinator
Director, Office of Communication and Public Involvement
Rosebud Sioux Tribe Project Officer, Tribal Assistance Program
Rosebud Sioux Tribe
President
19
Report No. 1000370-2002-1-00096
------- |