Presented By:
Donna Denker, CPA
Donna Denker & Associates
 Internal
Controls
 Laws and Regulations
• Tribal Codes
• Federal Codes (i.e. IRS, FLSA)
• Protecting the civil rights of all individuals
• Fair practices towards recipients, students,
constituents
• Not using the position for personal gain (board
and staff)
 Prohibit
receiving gifts from suppliers
 Confidentiality regarding payroll, health
or employee issues
 Consistency in applying policies such as
travel
 Arms
length agreements with related
parties
 Duty of loyalty
 Written statements from Board and
Management each year
 Confidential
process for addressing
complaints or reporting suspected illegal
acts
 Retaliation against a whistleblower can
be an illegal act
 Efficient
filing system including paper
and electronic documents
 Schedule of document retention and
purging
 Board
Meetings – clear concise meeting
minutes documenting decisions and
directives
 Books
and Records – Accuracy and
Completeness
 Monitoring the Audit Process
• Understanding the scope of the audit
• Corrective Action Plans
 Development
 Assigning Individuals Responsible
 Assigning Deadlines
 Monitoring
 Budget
must be reflection of your goals
and mission
 Identify revenues expected
 Should be based upon reliable
information
 Must be monitored vigilantly
 Evaluations of finance staff
 Panel
on the Nonprofit Sector
• www.nonprofitpanel.org
 Internal
Revenue Service
• www.irs.gov
 Code
of Federal Regulations 25 CFR Part
900 Subpart F “Standards for Tribal or Tribal
Organization Management Systems.”
 OMB Circular A-133
• Auditee responsibilities Subpart C
• Part 6 – Internal Controls