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U.S. Environmental Protection Agency	12-2-0072
November 10, 2011
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At a Glance
Why We Performed These
Agreed-Upon Procedures
The U.S. Environmental
Protection Agency (EPA),
Region 9, requested assistance
from the Office of Inspector
General due to concerns with
the Summit Lake Paiute Tribe's
financial practices and internal
controls.
Background
The tribe receives financial
assistance from EPA under
three programs—the Indian
Environmental General
Assistance Program, Water
Pollution Control State and
Interstate Program Support, and
Nonpoint Source
Implementation.
Agreed-Upon Procedures Applied to EPA
Grants Awarded to Summit Lake Paiute Tribe,
Sparks, Nevada
What We Found
Although our transaction tests showed that labor costs claimed by the Summit
Lake Paiute Tribe under the EPA grants were generally supported by timesheets,
the following timekeeping issues warrant attention:
•	The timekeeping process for the Indian Environmental General
Assistance Program grants did not comply with Code of Federal
Regulations (CFR) requirements in 2 CFR Part 225.
•	A third party did not consistently verify the chairman's consent to use
his signature stamp fortimesheet approval.
•	The tribe charged indirect labor costs as direct costs, contrary to its
accounting policy.
•	The tribe did not have policies and procedures for leave allocation.
As a result of the above issues, we questioned labor costs of $96,615.
We found that the tribe was addressing some of the issues raised in the 2008 and
2009 single audits. However, additional work remains to be done on issues
relating to deferred revenues and updating policies and procedures.
What We Recommend
For further information, contact
our Office of Congressional and
Public Affairs at (202) 566-2391.
The full report is at:
www.epa.aov/oia/reports/2012/
20111110-12-2-0072.pdf
We recommend that the Regional Administrator, EPA Region 9, disallow and
recover unallowable costs of $96,615. We also recommend that the Regional
Administrator require the tribe to implement certain internal controls related to
timekeeping. Finally, we recommend that the Regional Administrator require the
tribe to update its policies and procedures to ensure that they address all
accounting issues and reflect the tribe's actual accounting practices.
The region agreed with our recommendations. The tribe disagreed with the
recommendation to disallow the $96,615 in labor costs.

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