Sneak Preview: OIG Maintains Call for DOI ‘Multi-Dipping’ Policy
(The following was excerpted from a recent Thompson Grants Compliance Expert article.) While officials with two agencies within the Department of the Interior (DOI) argued that they have adequate processes in place to prevent “multi-dipping” of COVID-19 pandemic relief funds, the agencies did not provide documentation in response to a recent audit by the DOI Office of Inspector General (OIG) showing that they had sufficient internal controls over potential multi-dipping of these dollars.
OIG reviewed the Bureau of Indian Affairs’ (BIA) and the Bureau of Indian Education’s (BIE) controls to prevent the misuse of some $2.3 billion made available to the agencies under pandemic relief packages such as the Coronavirus Aid, Relief, and Economic Security (CARES) Act (Pub. L. 116-136) and the American Rescue Plan Act (ARPA) (Pub. L. 117-2). Multi-dipping occurs when recipients obtain funds from multiple federal programs for the same expenses and use the excess funds for another purpose.
“If an entity receives funding from multiple federal sources for the same expenditure, that entity cannot use any of that funding for any other purpose; doing so would constitute fraud or waste,” OIG explained. For example, if a recipient received $100 from DOI and $75 from another agency to purchase one air filtration system but the system cost, in total, only $100, the recipient could not properly use the remaining $75 for an unrelated expenditure.
Despite the massive influx of federal funds provided to DOI agencies under the pandemic relief packages, OIG found that BIA and the BIE did not specifically develop additional internal controls designed to prevent or detect multi-dipping of pandemic response funds. OIG found this especially concerning because its prior audits of BIA/BIE existing programs contained numerous deficiencies with controls, which “may suggest that the funds distributed through these [pandemic-relief] programs are more susceptible to mismanagement, fraud and abuse such as multi-dipping.”
OIG cited its June 2020 report that identified internal control weaknesses among Indian tribal governments that received CARES Act funding. These weaknesses led to improper commingling of federal funds with tribal funds, insufficient accounting and reporting, embezzlement and poor oversight. OIG noted that more-recent reports of tribal management of pandemic-relief funds has continued to show a lack of supporting documentation, unallowable and unsupported costs, and commingling of award funds. OIG explained that these issues may become even more concerning as DOI begins to receive funds under the Infrastructure Investment and Jobs Act (Pub. L. 117-58), which provides more than $13 billion to tribal communities nationwide.
(The full version of this story has now been made available to all for a limited time here.)
Join us for our following Thompson Grants events:
Federal Grants Forum for State & Local Governments | Feb. 15-16, 2022 | Virtual Event
Nonprofit Legal, Finance, and Grants Conference | April 6-7, 2023 | Washington, D.C.
