Full text
OFFICE OF
INSPECTOR GENERAL
DEPARTM ENT OF THE TREASURY
WASHINGTON, D.C. 20220
July 21, 2023
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 Pleasant Point Indian Reservation,
Maine’s Use of Coronavirus Relief Fund Proceeds
(OIG-CA-23-033)
Please find the attached desk review memorandum1 on the Pleasant Point Indian
Reservation, Maine’s (Pleasant Point) 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 Pleasant Point was non-compliant
with the quarterly Financial Progress Reports (FPR) submission timeline as
required under Department of Treasury’s (Treasury) guidance for cycles 12
through 43 and cycles 64 through 8.5 However, Castro did not identify any
reporting issues with FPRs for Cycle 5,6 9,7 and 10.8 In addition, Castro personnel
reviewed documentation for a selection of 20 transactions reported in the
quarterly reports through cycle 10. 9
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 March 31, 2021.
4 Calendar quarter ending September 30, 2021.
5 Calendar quarter ending March 31, 2022.
6 Calendar quarter ending June 30, 2021.
7 Calendar quarter ending June 30, 2022.
8 Calendar quarter ending September 30, 2022.
9 Calendar quarter ending September 30, 2022.
Page 2
Castro confirmed with Pleasant Point personnel that the Fiscal Year 2019, 2020,
and 2021 Single Audit Act reports were still in process during Castro’s planning
procedures. Castro recommends that the Department of the Treasury (Treasury)
Office of Inspector General (OIG) follow-up to obtain the status of these Single
Audit reports.
Castro’s review of Pleasant Point’s documentation supporting its use of CRF
proceeds found that expenditures for the Aggregate Reporting less than $50,00010
payment types complied with the CARES Act and Treasury’s Guidance. Castro
found that CRF proceeds for the Contracts greater than or equal to $50,000,
Transfers greater than or equal to $50,000,11 and Aggregate Payments to
Individuals12 payment types did not comply with the CARES Act and Treasury’s
Guidance.
Support for certain expenditures related to Aggregate Payments to Individuals
provided to Castro was less than the costs that were reported in the grants portal.
Therefore, Castro questioned $48,818.90 for Aggregate Payments to Individuals.
Based on the totality of the work performed, Castro identified total questioned
costs of $339,672.43 and determined that Pleasant Point’s risk of unallowable use
of funds to be moderate. Based on Castro’s desk review, Treasury Office of
Inspector General (OIG) is questioning unsupported expenditures of $339,672.43.
See the attachment to this transmittal for the definition of a questioned cost.
Castro does not recommend Treasury OIG perform an audit of Pleasant Point.
However, Castro recommends Treasury OIG follow-up on the status of Single
Audit reports and necessary reporting corrections for Contracts greater than or
equal to $50,000, Transfers greater than or equal to $50,000, and Aggregate
Payments to Individuals. Treasury OIG and Castro met with Pleasant Point
management to discuss the questioned costs. Pleasant Point management stated
they will provide additional documentation regarding unsupported expenditures.
In addition, Treasury OIG clarified the reporting errors and corrections needed for
the expenditures reported in the Transfers greater than or equal to $50,000
category and Pleasant Point management stated that they would make the
required changes.
10 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).
11 A transfer to another government entity is a disbursement or payment to a government entity
that is legally distinct from the prime recipient.
12 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
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 Pleasant Point’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 Inspectors General.
We appreciate the courtesies and cooperation provided to Castro and our staff
during the desk review. 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.
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
Christopher Sun, Director of Data and Reporting, Department of the
Treasury
Andy Seeley, Chief Financial Officer, Pleasant Point Indian Reservation,
Maine
Wayne Ference, Partner, Castro & Company, LLC
Page 4
Attachment
Schedule of Monetary Benefits
According to the Code of Federal Regulations,13 a questioned cost is a cost that is
questioned due to 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).14 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 5 USC Section 405(b) of the Inspector General Act of 1978.
Recommendation
Questioned Costs
Recommendation No. 1
$339,672.43
The questioned cost represents amounts provided by Treasury under the
Coronavirus Relief Fund. As discussed in the attached desk review, $339,672.43 is
Pleasant Point’s total expenditures reported in the grants reporting portal that
were either ineligible or lacked supporting documentation.
13 2 CFR § 200.84 – Questioned Cost
14 JAMES is Treasury’s audit recommendation tracking system.
Desk Review of the Pleasant Point Indian Reservation
1
1635 King Street
Alexandria, VA 22314
Phone: 703.229.4440
Fax: 703.859.7603
www.castroco.com
July 21, 2023
OIG-CA-23-033
MEMORANDUM FOR DEBORAH L. HARKER,
ASSISTANT INSPECTOR GENERAL FOR AUDIT
FROM:
Wayne Ference
Partner, Castro & Company, LLC
SUBJECT:
Desk Review of the Pleasant Point Indian Reservation, Maine
On June 16, 2022, we initiated a desk review of the Pleasant Point Indian
Reservation’s (herein referred to as “Pleasant Point”) 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 Pleasant Point’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, 2022 as reported in Cycles 13
through 104 in the GrantSolutions portal.
As part of our desk review, we performed the following:
1) reviewed Pleasant Point’s quarterly Financial Progress Reports (FPRs)
submitted in the GrantSolutions portal through September 30, 2022;
2) reviewed the U.S. 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, 2022.
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
Desk Review of the Pleasant Point Indian Reservation
2
3) reviewed Treasury Office of Inspector General’s (OIG) Coronavirus Relief
Fund Frequently Asked Questions Related to Reporting and
Recordkeeping;6
4) reviewed Treasury OIG’s monitoring checklists7 of Pleasant Point’s
quarterly FPR submissions for reporting deficiencies;
5) reviewed other audit reports issued, such as Single Audit reports, 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 Pleasant Point’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),8 and Treasury OIG Office of Counsel
input on issues that may pose risk or impact Pleasant Point’s uses of CRF
proceeds;
7) interviewed key personnel responsible for preparing and certifying
Pleasant Point’s GrantSolutions portal quarterly FPR submissions, as well
as officials responsible for obligating and expending CRF proceeds;
8) made a non-statistical selection of Contracts, Aggregate Reporting,9 and
Aggregate Payments to Individuals10 data11 identified through
GrantSolutions reporting; and
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 personnel 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 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.
9 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).
10 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.
11 Castro noted that Pleasant Point incorrectly reported funds that it returned to Treasury under the
Transfers >= $50,000 payment type. A Transfer to another government entity is a disbursement or
payment to a government entity that is legally distinct from the prime recipient. Pleasant Point
personnel were actively working with Treasury OIG to correct this error in the GrantSolutions
portal. As such, we excluded this amount from our testing population.
Desk Review of the Pleasant Point Indian Reservation
3
9) evaluated documentation and records used to support Pleasant Point’s
quarterly FPRs.
Based on our review of Pleasant Point’s documentation supporting the uses of its
CRF proceeds as reported in the GrantSolutions portal, we determined that the
expenditures related to the Contracts greater than or equal to $50,000, Transfers
greater than or equal to $50,000, and Aggregate Payments to Individuals payment
types did not comply with the CARES Act and Treasury’s Guidance. We also found
that uses of CRF proceeds for the Aggregate Reporting less than $50,000 payment
types complied with the CARES Act and Treasury’s Guidance.
We identified questioned costs of $339,672.43 and determined that Pleasant
Point’s risk of unallowable use of funds is moderate. Castro is not recommending
Treasury OIG perform an audit of Pleasant Point. However, we recommend that
Treasury OIG follow-up on necessary reporting corrections for the Contracts
greater than or equal to $50,000, Transfers greater than or equal to $50,000, and
Aggregate Payments to Individuals payment types.
Non-Statistical Transaction Selection Methodology
Treasury issued a CRF payment to Pleasant Point of $4,929,535.23. As of
Cycle 10,12 Pleasant Point’s cumulative obligations and expenditures were
$4,929,535.23. Pleasant Point’s cumulative obligations and expenditures, by
payment type as reported in GrantSolutions through Cycle 10,12 are summarized
below.
Payment Type
Cumulative
Obligations
Cumulative
Expenditures
Contracts >= $50,000
$ 739,594.10
$ 739,594.10
Grants >= $50,000
$ -
$ -
Loans >= $50,000
$ -
$ -
Transfers >= $50,000
$ 232,590.53
$ 232,590.53
Direct Payments >= $50,000
$ -
$ -
Aggregate Reporting < $50,000
$ 194,939.70
$ 194,939.70
Aggregate Payments to Individuals
(In Any Amount)
$ 3,762,410.90
$ 3,762,410.90
Totals
$ 4,929,535.23
$ 4,929,535.23
Castro made a non-statistical selection of the Contracts greater than or equal to
$50,000, Aggregate Reporting less than $50,000, and Aggregate Payments to
Individuals payment types. Selections were made using auditor judgment based
on information and risks identified in reviewing audit reports, the GrantSolutions
12 Calendar quarter ending September 30, 2022.
Desk Review of the Pleasant Point Indian Reservation
4
portal reporting anomalies13 identified by the Treasury OIG CRF monitoring team,
and review of Pleasant Point’s FPR submissions. Castro noted Pleasant Point did
not obligate or expend CRF proceeds to Grants greater than or equal to $50,000,
Loans greater than or equal to $50,000, or Direct Payments greater than or equal
to $50,000. Therefore, we did not make a selection of transactions from these
categories. Additionally, Castro noted that Pleasant Point incorrectly reported
funds that it returned to Treasury under the Transfers greater than or equal to
$50,000 payment type. As Pleasant Point personnel are actively working with
Treasury OIG to correct this error within GrantSolutions, Castro did not perform
any additional testing over these balances.
The number of transactions (20) we selected to test were based on Pleasant
Point’s total CRF award amount and our overall risk assessment of Pleasant Point.
To allocate the number of transactions (20) by payment type (Contracts 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 10.14
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 Pleasant Point for $4,929,535.23.
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
(3) were incurred between March 1, 2020 and December 31, 2022.15
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 Pleasant Point. No anomalies were noted.
14 Calendar quarter ending September 30, 2022.
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.
Desk Review of the Pleasant Point Indian Reservation
5
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-recipients.
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)).
Pleasant Point had expenditures within its Aggregate Payments to Individuals
payment type related to the issuance of hardship checks to individual Pleasant
Point tribal citizens. The Pleasant Point tribal government passed a resolution to
issue CRF economic relief payments to eligible tribal citizens who submitted
applications in order to receive relief checks. Applicants were required to attest to
one of the following criteria: loss of job or reduction in income, increased medical
expenses related to COVID-19, or difficulty making rental or mortgage payments
due to the pandemic. The applications also required the number of family
members living in the household, whether any member within the household had
received COVID-19 aid from other sources, a summary of monthly household
income, and an applicant signature attesting to the accuracy of the information
submitted.
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.
Desk Review of the Pleasant Point Indian Reservation
6
Desk Review Results
Financial Progress Reports
Our review of Pleasant Point’s quarterly FPR submissions through September 30,
2022 identified reporting issues and a variance, as detailed below.
We did not identify reporting issues within FPR submissions for Cycles 5,19 9,20
and 10.21 However, we found that Pleasant Point personnel did not submit FPRs
for Cycles 1 through 422 and Cycles 623 through 8.24 Quarterly FPRs were due by
the 10th day of the month following quarter end unless it falls on a holiday. Based
on our review of the quarterly FPRs, we determined Pleasant Point did not comply
with the Reporting Timeline as required under Treasury OIG’s Guidance OIG-A-20-
021, Coronavirus Relief Fund Reporting and Record Retention Requirements.
Additionally, Castro confirmed with Pleasant Point personnel that the Fiscal Year
(FY) 2019, 2020, and 2021 Single Audit reports were still in process during our
planning procedures. Castro recommends that Treasury OIG follow-up to obtain
the status of these Single Audits.
In addition, we identified a reporting variance between the amount reported for
expenditures in the GrantSolutions portal and Pleasant Point’s supporting
documentation within its Cycle 1025 GrantSolutions submission. We noted a
variance of $48,818.90 between the $3,762,410.90 Aggregate Payments to
Individuals balance reported within the GrantSolutions portal as of
September 30, 2022, and the $3,713,592 balance expended based on supporting
documentation. We questioned this expenditure amount.
The Pleasant Point staff explained that this variance occurred because they had
not completed their reconciliation of funds to be returned to Treasury. Pleasant
Point informed us that they planned to correct the variance within future
GrantSolutions reporting cycles; however, the correction had not been completed
as of Cycle 11.26
19 Calendar quarter ending June 30, 2021.
20 Calendar quarter ending June 30, 2022.
21 Calendar quarter ending September 30, 2022.
22 Calendar quarter ending March 31, 2021.
23 Calendar quarter ending September 30, 2021.
24 Calendar quarter ending March 31, 2022.
25 Calendar quarter ending September 30, 2022.
26 Calendar quarter ending December 31, 2022.
Desk Review of the Pleasant Point Indian Reservation
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Summary of Testing Results
Other than the Contracts greater than or equal to $50,000 and Transfers greater
than or equal to $50,000 payment types, transactions selected for detailed review
were supported by documentation and were allowable expenditures in
accordance with the CARES Act and Treasury’s guidance. Based on the results of
our testing, we also found that Aggregate Reporting less than $50,000 and
Aggregate Payments to Individuals 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. The transaction selection was not a statistical selection, and therefore
results cannot be extrapolated to the total universe of transactions.
The following table includes the total cumulative expenditure population amount
and the expenditure amount tested. Within the table below, we have included a
summary of unsupported and ineligible expenditures identified as questioned
costs. Additionally, in the far-right column, we have identified the expenditures
that Castro tested without exceptions noted. See the 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.
Desk Review of the Pleasant Point Indian Reservation
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Summary of Expenditure Testing and Recommended Results – As of Cycle 1027
Payment Type
Cumulative
Expenditure
Population
Amount
Cumulative
Expenditure
Tested Amount
Unsupported
Exception28
Ineligible
Exception
Castro Reviewed
Value Without
Exception
(per Support)
Contracts >=
$50,000
$ 739,594.10 $ 739,594.10
$ - $ 58,263.00 $ 681,331.10
Grants >= $50,000
$ - $ - $ - $ - $ -
Loans >= $50,000
$ - $ - $ - $ - $ -
Transfers >=
$50,000
$ 232,590.53 $ - $ 232,590.5329
$ - $ -
Direct Payments
>= $50,000
$ - $ - $ - $ - $ -
Aggregate
Reporting <
$50,000
$ 194,939.70 $ 128,922.19
$ - $ - $ 128,922.19
Aggregate
Payments to
Individuals (in any
amount)
$ 3,762,410.90 $ 11,470.00
$ 48,818.9030
$ - $ 11,470.00
Totals
$ 4,929,535.23 $ 879,986.29
$ 281,409.43
$ 58,263.00 $ 821,723.29
Contracts Greater than or Equal to $50,000
We determined Pleasant Point’s Contracts greater than or equal to $50,000 did not
comply with the CARES Act and Treasury’s Guidance. We questioned $58,263
related to an expenditure that had a purchase order dated prior to the beginning
of the CRF covered period of March 1, 2020.15 In addition, we identified $681,969 in
expenditures that were included with Contracts greater than or equal to $50,000
and should have been reported as Direct Payments greater than or equal to
$50,000.
27 Calendar quarter ending September 30, 2022.
28 In addition to the questioned costs identified in this table, Castro noted $681,969 in misclassified
expenditure balances, which should not have been included within the Contracts greater than or
equal to $50,000 payment type. Although we do not consider misclassifications to be questioned
costs, these costs did not comply with Treasury’s Guidance, as they should have been reported
under a different payment type. See the Desk Review Results section below for additional
discussion.
29 Castro noted that Pleasant Point incorrectly reported funds that it returned to Treasury under the
Transfers >= $50,000 obligation type. Pleasant Point was actively working with Treasury OIG to
correct this amount within a future GrantSolutions portal submission. We did not include the
transfers in the “Cumulative Expenditure Tested Amount” column because we did not review any
detailed support related to this balance, and therefore do not consider this balance tested.
30 We noted a variance of $48,818.90 between the $3,762,410.90 Aggregate Payments to Individuals
balance reported within the GrantSolutions portal as of September 30, 2022, and the $3,713,592
balance based on supporting documentation. Although the $11,470 of transactions we selected for
testing were supported and allowable, we questioned the reconciliation variance of 48,818.90. We
did not include the reconciliation variance in the “Cumulative Expenditure Tested Amount”
column because we did not review detailed support for this variance.
Desk Review of the Pleasant Point Indian Reservation
9
As part of our procedures for Contracts greater than or equal to $50,000, we
selected 8 transactions to test. We found no issues with 1 of the 8 transactions for
$57,625.10.
For 7 out of 8 transactions, Castro noted the misclassification exceptions
discussed in the previous paragraph. Pleasant Point personnel concurred with the
errors noted and agreed to make corrections in future GrantSolutions reporting
cycles. We further tested these 7 transactions for eligibility and support and did
not note any issues for 6 out of 7 transactions, or $623,706 out of the total
$681,969 in misclassifications. Therefore, we are not questioning these
misclassification expenditures, but we consider these to be reporting errors.
For 1 out of the 7 misclassified transactions identified above, we question the
expenditure of $58,263. The cost relates to a purchase order dated January 21,
2020, which was prior to the beginning of the COVID-19 covered period of
March 1, 2020.31 Pleasant Point personnel told us that the purchase order request
was dated January 1, 2020, due to the vendor locking in the vehicle’s price at the
2020 level. However, Pleasant Point personnel confirmed that they did not have a
different version of this purchase order request with an approving signature after
the March 1, 2020 cutoff date. Castro determined that Pleasant Point was checking
the price for an old garbage truck and chassis that needed to be replaced, which
indicated that they were planning to purchase this chassis prior to the COVID-19
pandemic. As a result, we question the expenditure amount of $58,263 as
ineligible.
Transfers Greater Than or Equal to $50,000
Based on the documentation reviewed and entries in GrantSolutions, we
determined that Pleasant Point’s Transfers greater than or equal to $50,000 did
not comply with the CARES Act and Treasury’s Guidance. Castro noted that
Pleasant Point personnel incorrectly reported $232,590.53 in the GrantSolutions
portal that was to be returned to Treasury. Pleasant Point personnel told us that
they would correct this error in future GrantSolutions submissions. As corrections
were not made as of the end of our fieldwork, we question this expenditure of
$232,590.53.
31 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.
Desk Review of the Pleasant Point Indian Reservation
10
Conclusion
We found that uses of CRF proceeds for Aggregate Reporting less than $50,000
complied with the CARES Act and Treasury’s Guidance.
We found that Pleasant Point personnel did not submit FPRs for Cycles 1 through
432 and Cycles 633 through 8.34 Castro confirmed with Pleasant Point personnel that
the Fiscal Year (FY) 2019, 2020, and 2021 Single Audit reports were still in process
during our planning procedures. Castro recommends that Treasury OIG follow-up
to obtain the status of these Single Audits.
Support for certain expenditures related to Aggregate Payments to Individuals
that was provided to Castro was less than the costs that had been reported.
Therefore, we question cumulative expenditure amounts of $48,818.90 for
Aggregate Payments to Individuals.
We determined that the expenditures related to Contracts greater than or equal to
$50,000 did not comply with the CARES Act and Treasury’s Guidance. As such, we
questioned $58,263. We also identified $681,969 in misclassifications related to
Contracts greater than or equal to $50,000 that should have been reported as
Direct Payments greater than or equal to $50,000. We are not questioning the
misclassification amounts that are supported and eligible.
Finally, we question $232,590.53 in funds recorded as Transfers greater than or
equal to $50,000 that should have been returned to Treasury.
In summary, we questioned total costs of $339,672.43 and determined that
Pleasant Point’s risk of unallowable use of funds is moderate. Castro is not
recommending Treasury OIG perform an audit of Pleasant Point. However, we
recommend Treasury OIG follow-up on necessary reporting corrections for
Contracts greater than or equal to $50,000, Transfers greater than or equal to
$50,000, and Aggregate Payments to Individuals.
32 Calendar quarter ending March 31, 2021.
33 Calendar quarter ending September 30, 2021.
34 Calendar quarter ending March 31, 2022.
Desk Review of the Pleasant Point Indian Reservation
11
*****
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.35 We appreciate the courtesies
and cooperation provided to our staff during the desk review.
Sincerely,
Wayne Ference
Partner, Castro & Company, LLC
35 https://www.ignet.gov/sites/default/files/files/Silver%20Book%20Revision%20-%208-20-12r.pdf