Chippewa Cree Tribe Final CRF Desk Review Memo 06.26.23

Summary

A Department of the Treasury Office of Inspector General memorandum dated June 26, 2023, OIG-CA-23-018, signed /s/ by Deborah L. Harker, Assistant Inspector General for Audit, to Acting Chief Recovery Officer Jessica Milano, transmitting a desk review of the Chippewa Cree Tribe's use of Coronavirus Relief Fund proceeds. The memorandum states that Castro & Company, LLC performed the desk review and was unable to determine if certain expenditures were allowable because of a lack of supporting documentation. It states that Treasury OIG is questioning unsupported expenditures of $75,090.88 of the tested $5,215,029.79 related to Grants greater than or equal to $50,000, and that Castro determined the tribe's risk of unallowable use of funds is high.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

DEPARTM ENT OF THE TREASURY
WASHINGTON, D.C.  20220
OFFICE OF
June 26, 2023
INSPECTOR GENERAL
MEMORANDUM FOR JESSICA MILANO, ACTING CHIEF RECOVERY OFFICER,
DEPARTMENT OF THE TREASURY
FROM:
Deborah L. Harker /s/
Assistant Inspector General for Audit
SUBJECT:
Desk Review of Chippewa Cree Tribe’s Use of
Coronavirus Relief Fund Proceeds (OIG-CA-23-018)
Please find the attached desk review memorandum1 on Chippewa Cree Tribe’s
(CCT) use of Coronavirus Relief Fund (CRF) proceeds. The CRF is authorized under
Title VI of the Social Security Act, as amended by Title V, Division A of the
Coronavirus Aid, Relief, and Economic Security Act (CARES Act). Under a contract
monitored by our office, Castro & Company, LLC (Castro), a certified independent
public accounting firm, performed the desk review. Castro performed the desk
review in accordance with the Council of the Inspectors General on Integrity and
Efficiency, Quality Standards for Federal Offices of Inspector General standards of
independence, due professional care, and quality assurance.
In its desk review, Castro personnel found that CCT was not compliant with the
quarterly Financial Progress Reports (FPR) reporting timeline as required under
Department of the Treasury’s (Treasury) guidance for cycles 12, 23, 44 and 55.
Castro personnel reviewed documentation for a selection of 21 transactions
reported in the quarterly reports and was unable to determine if certain
expenditures were allowable in accordance with the CARES Act and Treasury’s
guidance because of the lack of supporting documentation. Based on the results
of its desk review, Castro determined that the expenditures related to Grants
greater than or equal to $50,000 did not comply with the CARES Act and
Treasury’s Guidance. Based on Castro’s desk review, Treasury Office of Inspector
General is questioning unsupported expenditures of $75,090.88 of the tested
$5,215,029.79 in expenditures related to Grants greater than or equal to $50,000.
1 The Coronavirus Aid, Relief, and Economic Security Act (CARES Act) assigned the Department of
the Treasury Office of Inspector General with responsibility for compliance monitoring and
oversight of the receipt, disbursement, and use of Coronavirus Relief Fund (CRF) payments. The
purpose of the desk review is to perform monitoring procedures of the prime recipient’s receipt,
disbursement, and use of CRF proceeds as reported in the grants portal on a quarterly basis.
2 Calendar quarter ending June 30, 2020.
3 Calendar quarter ending September 30, 2020.
4 Calendar quarter ending March 31, 2021.
5 Calendar quarter ending June 30, 2021.

Page 2
See the attachment to this transmittal for the definition of a questioned cost
included as part of the schedule of questioned cost.
In addition, Castro found that CCT personnel incorrectly classified the tribe’s
obligations and expenditures for Direct Payments in the grants portal in the
amount of $7,080,546.87 and $6,836,895.66, respectively, for all eight transactions
selected for testing.
Castro found that uses of CRF proceeds for Aggregate Reporting for transactions
less than $50,000,6 and Aggregate Payments to Individuals7 complied with the
CARES Act and Treasury’s Guidance. Additionally, Castro determined that CCT’s
risk of unallowable use of funds is high. As such, Castro is recommending that
Treasury Office of Inspector General follow-up on all CCT’s corrections and
reclassification entries and then perform audit work on those related transactions.
Castro and Treasury Office of Inspector General met with CCT management to
discuss the questioned costs, corrections, and reclassification entries.
In connection with the contract, we reviewed Castro’s desk review memorandum
and related documentation and inquired of its representatives. Our review, as
differentiated from an audit performed in accordance with generally accepted
government auditing standards, was not intended to enable us to express an
opinion on CCT’s use of the CRF proceeds. Castro is responsible for the attached
desk review memorandum and the conclusions expressed therein. Our review
found no instances in which Castro did not comply in all material respects with
the Quality Standards for Federal Offices of Inspector General.
We appreciate the courtesies and cooperation provided to Castro and our staff
during the desk review. Castro and the Treasury OIG held an Exit Conference with
the Chippewa Cree Tribe on June 23, 2023. If you have any questions or require
further information, please contact me at (202) 486-1420, or a member of your
staff may contact Lisa DeAngelis, Deputy Assistant Inspector General for Audit, at
(202) 487-8371.
6 Recipients are required to report CRF transactions greater than or equal to $50,000 in detail in the
grants portal. Transactions less than $50,000 can be reported as an aggregate lump-sum amount
by type (contracts, grants, loans, direct payments, and transfers to other government entities).
7 Obligations and expenditures for payments made to individuals, regardless of amount, are
required to be reported in the aggregate in the grants portal to prevent inappropriate disclosure of
personally identifiable information.

Page 3
cc:
Michelle. A. Dickerman, Deputy Assistant General Counsel, Department of
the Treasury
Victoria Collin, Chief Compliance & Finance Officer, Office of Recovery
Programs, Department of the Treasury
Ms. Chassidy Parisian, Chippewa Cree Tribe Secretary/Treasury
Ms. Tanya Schmockel, Chippewa Cree Tribe Comptroller
Wayne Ference, Partner, Castro & Company, LLC

Page 4
Attachment
Schedule of Questioned Cost
According to the Code of Federal Regulations,8 a questioned cost is a cost that is
questioned because of a finding:
(a) which resulted from a violation or possible violation of a statute,
regulation, or the terms and conditions of a Federal award, including for
funds used to match Federal funds;
(b) where the costs, at the time of the review, are not supported by
adequate documentation; or
(c) where the costs incurred appear unreasonable and do not reflect the
actions a prudent person would take in the circumstances.
Questioned costs are to be recorded in the Department of the Treasury’s
(Treasury) Joint Audit Management Enterprise System (JAMES).9 The amount will
also be included in the Office of Inspector General (OIG) Semiannual Report to
Congress. It is Treasury management's responsibility to report to Congress on the
status of the agreed to recommendations with monetary benefits in accordance
with USC 5 Section 405(b) of the Inspector General Act of 1978.
Recommendation
Questioned Costs
Recommendation No. 1
$75,090.88
The questioned cost represents amounts provided by Treasury under the
Coronavirus Relief Fund. As discussed in the attached desk review, $75,090.88 is
Chippewa Cree Tribe’s expenditures reported in the grants reporting portal that
lacked supporting documentation.
8 2 CFR § 200.84 – Questioned Cost
9 JAMES is Treasury’s audit recommendation tracking system.

Castro Company
Auditors ✓
Advisors
1635 King Street
Alexandria, VA 22314
Phone: 703.229.4440
Fax: 703.859.7603
www.castroco.com
Desk Review of the Chippewa Cree Tribe
June 26, 2023
OIG-CA-23-018
MEMORANDUM FOR DEBORAH L. HARKER,
ASSISTANT INSPECTOR GENERAL FOR AUDIT
FROM:
Wayne Ference
Partner, Castro & Company, LLC
SUBJECT:
Desk Review of the Chippewa Cree Tribe
On August 10, 2021, we initiated a desk review of the Chippewa Cree Tribe’s (CCT)
use of the Coronavirus Relief Fund (CRF) authorized under Title VI of the Social
Security Act, as amended by Title V Division A of the Coronavirus Aid, Relief, and
Economic Security Act (CARES Act).1 The objective of our desk review was to
evaluate CCT’s documentation supporting its uses of CRF proceeds as reported in
the GrantSolutions2 portal and to assess the risk of unallowable use of funds. The
scope of our desk review was limited to obligation and expenditure data for the
period of March 1, 2020 through September 30, 2021 as reported in Cycles 13
through 64 in the GrantSolutions portal.
As part of our desk review, we performed the following:
1) reviewed CCT’s quarterly Financial Progress Reports (FPRs) submitted in
the GrantSolutions portal through September 30, 2021;
2) reviewed the Department of the Treasury’s (Treasury) Coronavirus Relief
Fund Guidance as published in the Federal Register on January 15, 2021;5
1 P.L. 116-136 (March 27, 2020)
2 GrantSolutions, a grant and program management Federal shared service provider under the
U.S. Department of Health and Human Services, developed a customized and user-friendly
reporting solution to capture the use of CRF payments from recipients.
3 Calendar quarter ending June 30, 2020.
4 Calendar quarter ending September 30, 2021.
5 Coronavirus Relief Fund Guidance as published in the Federal Register (January 15, 2021)
https://home.treasury.gov/system/files/136/CRF-Guidance-Federal-Register_2021-00827.pdf
1

Desk Review of the Chippewa Cree Tribe
3) reviewed Treasury’s Office of Inspector General (OIG) Coronavirus Relief
Fund Frequently Asked Questions Related to Reporting and
Recordkeeping;6
4) reviewed Treasury OIG’s monitoring checklists7 of CCT’s quarterly FPR
submissions for reporting deficiencies;
5) reviewed other audit reports issued, such as Single Audit reports,8 and
those issued by the Government Accountability Office and other applicable
Federal agency OIGs for internal control or other deficiencies that may
pose risk or impact the CCT’s uses of CRF proceeds;
6) reviewed Treasury OIG Office of Investigations (OI), the Council of the
Inspectors General on Integrity and Efficiency Pandemic Response
Accountability Committee (PRAC),9 and Treasury OIG Office of Counsel
input on issues that may pose risk or impact CCT’s uses of CRF proceeds;
7) interviewed key personnel responsible for preparing and certifying CCT’s
GrantSolutions portal quarterly FPR submissions, as well as officials
responsible for obligating and expending CRF proceeds;
8) made a non-statistical selection of Grants, Direct Payments, Aggregate
Reporting,10 and Aggregate Payments to Individuals11 data identified
through GrantSolutions reporting; and
9) evaluated documentation and records used to support CCT’s quarterly
FPRs.
Based on the results of our desk review, documentation supporting the uses of
CRF proceeds did not comply with the CARES Act and with Treasury’s Guidance,
6 Department of the Treasury Office of Inspector General Coronavirus Relief Fund Frequently Asked
Questions Related to Reporting and Recordkeeping OIG-20-028R; March 2, 2021
7 The checklists are used by Treasury OIG to monitor the progress of prime recipient reporting in
the GrantSolutions portal. GrantSolutions quarterly submission reviews are designed to identify
material omissions and significant errors, and where necessary, include procedures for notifying
prime recipients of misreported data for timely correction. Treasury OIG follows the CRF Prime
Recipient Quarterly GrantSolutions Submissions Monitoring and Review Procedures Guide, OIG­
CA-20-029R to monitor the prime recipients quarterly.
8 CCT provided Castro with the fiscal year (FY) 2019 Single Audit Report; however, at the time of
our review FY 2020, 2021, and 2022 Single Audit Reports were not complete.
9 Section 15010 of P.L. 116-136 established the Pandemic Response Accountability Committee
within the Council of the Inspectors General on Integrity and Efficiency to promote transparency
and conduct and support oversight of covered funds (see Footnote 17 for a definition of covered
funds) and the coronavirus response to (1) prevent and detect fraud, waste, abuse, and
mismanagement; and (2) mitigate major risks that cut across program and agency boundaries.
10 Recipients are required to report CRF transactions greater than or equal to $50,000 in detail in
the GrantSolutions portal. Transactions less than $50,000 can be reported as an aggregate lump-
sum amount by type (contracts, grants, loans, direct payments, and transfers to other government
entities).
11 Obligations and expenditures for payments made to individuals, regardless of amount, are
required to be reported in the aggregate in the GrantSolutions portal to prevent inappropriate
disclosure of personally identifiable information.
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Desk Review of the Chippewa Cree Tribe
resulting in total questioned costs across all payment types of $75,090.88.
Additionally, CCT’s risk of unallowable use of funds is high. As such, Castro
recommends Treasury OIG pursue obtaining documentation from CCT
management and ensure reporting corrections are made within the
GrantSolutions portal. Further, based on CCT’s responsiveness to Treasury OIG’s
requests and its ability to provide documentation, we recommend Treasury OIG
determine if a focused audit is feasible for Grants greater than or equal to $50,000
and Direct Payments greater than or equal to $50,000.
Non-Statistical Transaction Selection Methodology
Treasury issued a CRF payment to CCT of $19,333,069.80. As of Cycle 6,12 CCT’s
cumulative obligations and expenditures were $19,333,069.80 and $19,060,794.36,
respectively. CCT’s cumulative obligations and expenditures by payment type as
reported in GrantSolutions through Cycle 6 are summarized below:
Payment Type
Cumulative
Cumulative
Obligations
Expenditures
Contracts >= $50,000
$
-
$
-
Grants >= $50,000
$ 5,535,051.14
$
5,535,051.14
Loans >= $50,000
$
-
$
-
Transfers >= $50,000
$
-
$
-
Direct Payments >= $50,000
$ 7,605,780.21
$
7,333,504.77
Aggregate Reporting < $50,000
$
89,112.05
$
89,112.05
Aggregate Payments to Individuals
(Any Amount)
$ 6,103,126.40
$
6,103,126.40
Totals
$ 19,333,069.80
$
19,060,794.36
Castro made a non-statistical selection of Grants greater than or equal to $50,000,
Direct Payments greater than or equal to $50,000, Aggregate Reporting less than
$50,000 and Aggregate Payments to Individuals. Selections were made using
auditor judgment based on information and risks identified in reviewing audit
reports, the GrantSolutions portal reporting anomalies13 identified by the Treasury
OIG CRF monitoring team, and review of CCT’s FPR submissions. Castro noted
CCT personnel did not obligate or expend CRF proceeds to Contracts greater than
or equal to $50,000, Loans greater than or equal to $50,000, or Transfers14 greater
than or equal to $50,000; therefore, we did not make a selection of transactions
from these categories.
12 Calendar quarter ending September 30, 2021.
13 Treasury OIG has a pre-defined list of risk indicators that are triggered based on data submitted
by recipients in the FPR submissions that meet certain criteria. Castro reviewed these results
provided by Treasury OIG for CCT.
14 A transfer to another government entity is a disbursement or payment to a government entity
that is legally distinct from the prime recipient.
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Desk Review of the Chippewa Cree Tribe
The number of transactions (21) we selected to test were based on CCT’s total CRF
award amount and our initial overall risk assessment of CCT. To allocate the
number of transactions (21) by obligation type (Grants greater than or equal to
$50,000, Direct Payments greater than or equal to $50,000, Aggregate Reporting
less than $50,000 and Aggregate Payments to Individuals), we compared the
obligation type dollar amounts as a percentage of cumulative obligations for
Cycle 6. Additionally, Treasury OIG identified the following anomalies:
•
CCT received funding from multiple federal programs and would need
internal controls to ensure the proper federal fund was charged; and
•
CCT personnel reported sub-recipients that shared the same address as the
tribe. CCT personnel confirmed that these were separate departments
under the umbrella of CCT; however, the reported sub-recipients were not
separate legal entities. Treating departments within the tribe as sub-
recipients is incorrect GrantSolutions reporting. See additional information
in Section Desk Review Results below.
Due to obtaining 64 percent coverage of the obligation amount reported in
GrantSolutions through our selection of the 21 transactions, these anomalies
reported by Treasury OIG did not result in additional transactions for Castro’s
desk review. Based on our risk assessment and transaction selection, we feel
confident that our transaction selection provided us with coverage over the data
to address the risk of these anomalies.
Background
The CARES Act appropriated $150 billion to establish the CRF. Under the CRF,
Treasury made payments for specified uses to States and certain local
governments; the District of Columbia and U.S. Territories, including the
Commonwealth of Puerto Rico, the United States Virgin Islands, Guam, American
Samoa, and the Commonwealth of the Northern Mariana Islands; and Tribal
governments. Treasury issued a CRF payment to CCT for $19,333,069.80. The
CARES Act stipulates that a recipient may only use the funds to cover costs that—
(1) are necessary expenditures incurred due to the public health emergency
with respect to the coronavirus disease 2019 (COVID-19);
(2) were not accounted for in the budget most recently approved as of
March 27, 2020; and
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Desk Review of the Chippewa Cree Tribe
(3) were incurred between March 1, 2020 and December 31, 2022.15
Section 15011 of the CARES Act, requires each covered recipient16 to submit to
Treasury and the PRAC, no later than 10 days after the end of each calendar
quarter, a report that contains (1) the total amount of large covered funds17,18
received from Treasury; (2) the amount of large covered funds received that were
expended or obligated for each project or activity; (3) a detailed list of all projects
or activities for which large covered funds were expended or obligated; and (4)
detailed information on any level of sub-contracts or sub-grants awarded by the
covered recipient or its sub-contractees or sub-grantees.
The CARES Act assigned Treasury OIG the responsibility for compliance
monitoring and oversight of the receipt, disbursement, and use of CRF proceeds.
Treasury OIG also has authority to recoup funds in the event that it is determined
a recipient failed to comply with requirements of subsection 601(d) of the Social
Security Act, as amended, (42 U.S.C. 801(d)).
Desk Review Results
Our review of CCT’s quarterly FPR submissions through September 30, 2021
identified reporting issues and variances, as detailed below.
Financial Progress Reports
According to the CARES Act, quarterly FPRs are to be submitted by the 10th day of
the month following quarter end unless it falls on a holiday. Based on our review
of the quarterly FPRs, CCT was noncompliant with the reporting timeline as
required under Department of the Treasury’s Guidance OIG-CA-20-021 (issued
15 P.L. 116-260 (December 27, 2020). The period of performance end date of the CRF was extended
through December 31, 2021 by the Consolidated Appropriations Act, 2021. The period of
performance end date for tribal entities was further extended to December 31, 2022 by the State,
Local, Tribal, and Territorial Fiscal Recovery, Infrastructure, and Disaster Relief Flexibility Act,
Division LL of the Consolidated Appropriations Act, 2023, P.L. 117-328, December 29, 2022, 136
Stat. 4459.
16 Section 15011 of P.L. 116-136 defines a covered recipient as any entity that receives large
covered funds and includes any State, the District of Columbia, and any territory or possession of
the United States.
17 Section 15010 of P.L. 116-136 defines covered funds as any funds, including loans, that are made
available in any form to any non-Federal entity, not including an individual, under Public Laws 116­
123, 127, and 136, as well as any other law which primarily makes appropriations for Coronavirus
response and related activities.
18 Section 15011 of P.L. 116-136 defines large covered funds as covered funds that amount to more
than $150,000.
5

Desk Review of the Chippewa Cree Tribe
July 2, 2020), Coronavirus Relief Fund Reporting and Record Retention
Requirements.19
For Cycles 1 and 520 , CCT personnel told us that the reports were late due to
problems they were having with the submission of the information within the
GrantSolutions portal and issues with their email server. Once the issues were
resolved, Treasury OIG personnel confirmed that they would not reopen the portal
and that CCT personnel would have to submit the reports during the following
reporting cycle. CCT personnel told us that Cycles 221 and 422 were rejected
because they listed the tribe as a sub-recipient. The tribe did not state that this
was a reason for rejection of the Cycle 6 report. Castro staff confirmed that the
rejections of the FPR submissions were due to the fact that Treasury OIG does not
allow prime recipients to also list their organization as a sub-recipient. CCT
personnel distributed funding to departments for which CCT monitored financials.
These departments did not have a separate legal identifier or unique identifier that
could be used to report them as a sub-recipient within GrantSolutions. CCT
personnel attempted to change the identification numbers to something more in
line with the department’s unique identification, but the GrantSolutions form did
not allow for those types of changes. Further, CCT personnel reported that the
error identified in the Cycle 6 submission was a clerical error and funds were
reported in the wrong area; however, CCT personnel stated that they were fixed in
Cycle 7.23 Castro confirmed that the corrections were made to Aggregate
Reporting less than $50,000 as reported on CCT’s Cycle 7 FPR; however, these
transactions were not tested, as Cycle 7 was not included within our desk review
scope.
Sub-recipient Reporting
CCT’s FPRs continued to be returned for correction by Treasury OIG personnel
because CCT personnel reported 17 direct payments that were reportedly made
directly to the Tribal government. As noted in a memorandum submitted by CCT
personnel to Treasury OIG in response to report rejections, the payments were
not direct payments but instead were grants to different departments under the
Tribal government. The CCT personnel confirmed that these were separate
departments under the umbrella of CCT; however, they were not separate legal
entities (i.e., separate Employer Identification Numbers (EIN) or Articles of
Incorporation). Treating departments within the tribe as sub-recipients is incorrect
GrantSolutions reporting. The departments are not separate legal entities and
19 Department of the Treasury Office of Inspector General Coronavirus Relief Fund Reporting and
Record Retention Requirements OIG-CA-20-021; July 2, 2020
20 Calendar quarter ending June 30, 2021.
21 Calendar quarter ending September 30, 2020.
22 Calendar quarter ending March 31, 2021.
23 Calendar quarter ending December 31, 2021.
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Desk Review of the Chippewa Cree Tribe
Treasury OIG considers these departments as funding used by the prime
recipient/tribe. The obligations and expenditures of the departments should be
recorded in detail in the portal.
Castro recommends CCT personnel make the following corrections within the
GrantSolutions portal: (1) reclassify obligations and expenditures under the
correct obligation type within GrantSolutions; and (2) properly identify the sub-
recipients rather than reporting CCT departments as the sub-recipient.
CCT did not comply with Treasury OIG Guidance OIG-CA-20-028R,24 Department
of the Treasury Office of Inspector General Coronavirus Relief Fund Frequently
Asked Questions Related to Reporting and Recordkeeping (Revised), FAQs #s 5,
23, 28, and 48, because CCT personnel reported the Tribe as a sub-recipient and
reported grants to different Tribal departments under the CCT umbrella; however,
CCT personnel should have reported these Tribal departmental obligations and
expenditures as though they were incurred by the prime recipient government.
Specifically, CCT should have reported these transactions as Direct Payments
greater than or equal to $50,000 with the external vendors reported as sub­
recipients/beneficiaries and/or Aggregate Payments to Individuals for payroll-
related transactions.
Summary of Testing Results
Certain transactions selected for detailed review were not supported by
documentation and we were unable to determine if expenditures were allowable
in accordance with the CARES Act and Treasury’s guidance. Specifically, we were
unable to determine if the tested Grants greater than or equal to $50,000 and
Direct Payments greater than or equal to $50,000 were necessary expenditures
due to the COVID-19 public health emergency, were not accounted for in the
budget most recently approved as of March 27, 2020, and were incurred during
the covered period. We found that uses of CRF proceeds for Aggregate Reporting
less than $50,000, and Aggregate Payments to Individuals, did comply with the
CARES Act and Treasury’s Guidance. The transactions selected for testing were
not selected statistically, and therefore results cannot be extrapolated to the total
universe of transactions.
The following table includes the total cumulative expenditure population amount
and the cumulative expenditure amount tested. Additionally, this table includes a
summary of Castro’s testing results over cumulative expenditure transaction
balances. Within the “Exception Noted: IPA Recommended for Treasury OIG
Follow-up” section of this table, we have included a summary of unsupported and
24 https://oig.treasury.gov/sites/oig/files/2021-03/OIG-CA-20-028R.pdf
7

–
-
-
Desk Review of the Chippewa Cree Tribe
ineligible exception balances identified as questioned costs as a result of our desk
review. These transaction exceptions do not comply with both the CARES Act and
Treasury’s Guidance. Additionally, in the far-right column, we have identified the
cumulative expenditures that Castro tested without exception. See Desk Review
Results section below this table for a detailed discussion of questioned costs and
other issues identified throughout the course of our desk review.
Summary of Expenditure Testing and Recommended Results As of Cycle 625
Payment Type
Cumulative
Expenditure
Population
Amount
Cumulative
Expenditure
Tested Amount
Exception Noted: IPA
Recommended for Treasury OIG
Follow up
Castro
Reviewed Value
Without
Exception
(per Support)
Unsupported
Ineligible
Contracts >=
$50,000
$
-
$
-
$
-
$
-
$
-
Grants >= $50,000
$
5,535,051.14
$
5,215,029.79
$
 75,090.88
$
-
$
5,139,938.91
Loans >= $50,000
$
-
$
-
$
-
$
-
$
-
Transfers >=
$50,000
$
-
$
-
$
-
$
-
$
-
Direct Payments
>= $50,00026
$
7,333,504.77
$
6,836,895.66
$
-
$
-
$
-
Aggregate
Reporting <
$50,000
$
89,112.05
$
45,823.66
$
-
$
-
$
45,823.66
Aggregate
Payments to
Individuals (in any
amount)
$
6,103,126.40
$
6,000.00
$
-
$
-
$
6,000.00
Totals
$ 19,060,794.36
$ 12,103,749.11
$
75,090.88
$
$
5,191,762.57
Grants Greater than or Equal to $50,000
CCT’s Grants greater than or equal to $50,000 were not in compliance with the
CARES Act and Treasury’s Guidance. In accordance with Treasury OIG Guidance
OIG-CA-20-021, Recipients of Coronavirus Relief Fund payments shall maintain
and make available to Treasury OIG upon request all documents and financial
records sufficient to establish compliance with the CARES Act. CCT personnel
could not provide the necessary documents, including expenditure detail, to
support $75,090.88 of the $5,215,029.79 in expenditures reported for one of the six
selected transactions as reported in the GrantSolutions portal. Further, CCT
25 Calendar quarter ending September 30, 2021.
26 We did not report the $6.8 million as questioned costs due to the full amount of Direct Payments
reported within GrantSolutions being misclassified. The Chippewa Cree Tribe must make the
appropriate reclassifications within GrantSolutions. Castro is recommending that Treasury OIG
follow-up on all CCT’s corrections and reclassification entries and then perform audit work on
those related transactions, if deemed necessary.
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Desk Review of the Chippewa Cree Tribe
personnel over-reported obligations within the GrantSolutions portal by
$20,571.21. CCT personnel told us that they could not support the amount
because of variances due to the timing of expenditures and invoices coming in
late. Additionally, expenditures were often paid after the fact, but obligated prior
to the close of the award date since documentation was delayed. Lastly, with
limited staff during the pandemic, the reconciliation of the reports was
backlogged. As a result, CCT personnel were unable to support $75,090.88 of the
$5,215,029.79 in reported expenditures we tested, and over-reported obligations
by $20,571.21 from the reported obligations within the GrantSolutions portal of
$5,215,029.79. As a result, we questioned costs of $75,090.88.
Subsection 601 (d) of the Social Security Act, as amended, (42 U.S.C. 801 (d))
requires prime recipients to ensure eligible use of funds and Treasury OIG
Guidance OIG-CA-20-021,27 CRF Reporting and Record Retention Requirements,
states: “Recipients of Coronavirus Relief Fund payments shall maintain and make
available to the Treasury OIG upon request all documents and financial records
sufficient to establish compliance.” CCT did not comply because it did not
maintain and provide sufficient records to evidence transactions reported in
GrantSolutions.
Direct Payments Greater than or Equal to $50,000
CCT’s Direct Payments greater than or equal to $50,000 did not comply with the
CARES Act and Treasury’s Guidance. In accordance with Treasury OIG Guidance
OIG-CA-20-021, “Recipients of Coronavirus Relief Fund payments shall maintain
and make available to Treasury OIG upon request all documents and financial
records sufficient to establish compliance with the CARES Act.” CCT personnel
incorrectly classified the tribe’s obligations and expenditures for Direct Payments
in the amount of $7,080,546.87 and $6,836,895.66, respectively, for all eight
transactions we selected for testing.
CCT personnel reported 17 direct payments, which included the direct payments
that Castro tested. CCT personnel confirmed that these direct payments were
made to separate departments under the umbrella of CCT; however, they were
not separate legal entities. Therefore, the direct payments made by the
departments that were less than $50,000 should be reported under Aggregate
Reporting less than $50,000 and department payroll costs should be reported
under Aggregate Payments to Individuals. Any payments greater than $50,000
made by the departments should be recorded in the appropriate obligation type
for payments greater than $50,000. Castro recommends CCT personnel make the
following corrections within the GrantSolutions portal: (1) reclassify obligations
and expenditures under the correct obligation type within GrantSolutions; (2)
27 https://oig.treasury.gov/sites/oig/files/2021-01/OIG-CA-20-021.pdf
9

Desk Review of the Chippewa Cree Tribe
properly identify the sub-recipients/beneficiaries rather than reporting CCT
departments as the sub-recipient; and (3) evaluate and reclassify payroll costs for
the departments reported under Direct Payments greater than or equal to $50,000
to Aggregate Payments to Individuals. CCT personnel told us that they would
ensure all corrections and final closeout reconciliations are performed by the final
reporting period to ensure precise reporting. Based on the issues noted above,
we determined CCT to be noncompliant with Treasury OIG Guidance OIG-CA-20­
021 FAQ’s 5, 28, and 48 as described above.
Conclusion
Based on our review of CCT’s documentation supporting the uses of CRF
proceeds as reported in the GrantSolutions portal, we determined that the
expenditures related to Grants greater than or equal to $50,000 and Direct
Payments greater than or equal to $50,000 did not comply with the CARES Act
and Treasury’s Guidance, resulting in total questioned costs of $75,090.88. We
also found that uses of CRF proceeds for Aggregate Reporting less than $50,000,
and Aggregate Payments to Individuals did comply with the CARES Act and
Treasury’s Guidance. Additionally, CCT’s risk of unallowable use of funds is high.
As such, Castro recommends Treasury OIG pursue obtaining documentation from
CCT management and ensure reporting corrections are made within the
GrantSolutions portal. Further, based on CCT’s responsiveness to Treasury OIG’s
requests and its ability to provide documentation, we recommend Treasury OIG
determine if a focused audit is feasible for Grants greater than or equal to $50,000
and Direct Payments greater than or equal to $50,000.
*****
All work completed with this letter complies with the Council of the Inspectors
General on Integrity and Efficiency’s Quality Standards for Federal Offices of
Inspectors General, which require that the work adheres to the professional
standards of independence, due professional care, and quality assurance to
ensure the accuracy of the information presented.28 We appreciate the courtesies
and cooperation provided to our staff during the desk review.
Sincerely,
Wayne Ference
Partner, Castro & Company, LLC
28 https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdf
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