PAP.10.6.170 Internal Audit and Self-Monitoring

The following apply regarding internal audit and self-monitoring:

(a) The Executive Director will schedule a date annually to meet with the Program Director of each Tribal program (excluding health) that provides services based upon eligibility determinations. The meeting shall be for the purpose of conducting an internal audit and to review Contract Compliance Procedures including grant/contract applications and administration, professional services contracts, match documentation requirements, and to distribute any updated forms.

(b) The Executive Director shall instruct any Program Director that has $2,000 or more budgeted for a construction contract concerning the requirements of the Davis Bacon Act. Under the Davis Bacon Act all laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor.

(c) A signed acknowledgement must be received by the Program Director from any contractor receiving a construction contract in excess of $2,000 stating that they have been informed of the requirements of the Davis Bacon Act and that they will provide the Tribe with copies of their certified payrolls for the said contract.

(d) Before the Contracts Office approves any payment on construction contracts of $2,000 or more, it must verify that the Davis Bacon Act is being complied with and that said contractor has provided the Tribe with said acknowledgement and with a copies of their certified payrolls for the afore said construction contract.

(e) All client/ participant files prepared or maintained during the twelve (12) months prior to the review will be audited. It will be determined if the program has followed all applicable policies, procedures and statutory requirements for eligibility and the payment or distribution of benefits from that program.

(f) Program Directors will be required to provide the Executive Director copies of that programs policies, procedures and requirements at least one (1) week prior to the scheduled meeting. A report will be prepared within ten (10) working days after the completion of the review and copies will be forwarded to the Program Director and their Supervisor.

(g) If the Executive Director finds a program to be non-compliant, a corrective action plan will be initiated. This corrective action plan will be prepared with the participation of the Program Director, their Supervisor and the Executive Director.

(h) The corrective action plan will include a list of violations and strategies and the time line for correction of the same. The time line for completion of the tasks in the corrective action plan will be no less than five (5) working days and no longer than two (2) months from the date of the corrective action plan, depending upon the severity of the issues and the potential impact to that program's continuation.

(i) The Program Director will be responsible for correcting the deficiencies found in the review. The Executive Director will review the status of the corrective action plan at the end of the established time line. Program Directors that fail to correct noncompliance issues by that dead line will be subject to disciplinary action.

(j) The Executive Director will schedule a date annually to meet with the Program Director of each Tribal program that does not include the determination of eligibility or the distribution of benefits. The meeting shall be for the purpose of reviewing grant/contract compliance procedures including applications and administration, professional services contracts, match documentation requirements, and to distribute any updated forms. In the event of a violation, the above provisions of this section shall apply as applicable.