Macy, Nebraska 68039

P, O. Box 368

Macy, Nebraska 68039

EXECUTIVE OFFICER

Ansiey Griffin, Chairman

Bary D. Webster, Vice-Chairman

‘Amen Sheridan., Treasurer

Rodney Morris. Secretary

OMAHA TRIBE OF NEBRASKA

tecnPatier

RESOLUTION

OMAHA TRIBAL COUNCIL

No. 08-_2]

TO APPROVE A CORRECTIVE ACTION PLAN AND ASSOCIATED

PURCHASING AND PAYROLL MANA GEMENT POLICIES AND

WHEREAS,

WHEREAS,

WHEREAS,

WHEREAS,

WHEREAS,

WHEREAS,

PROCEDURES

the Omaha Tribe of Nebraska is a federally recognized Indian tribe

organized under a constitution and bylaws approved by the

Secretary of Interior on April 30, 1936, pursuant to Section 16 of the

Indian Reorganization Act of June 18, 1934; and,

pursuant to Article Hl, Section 1 of the Constitution of the Omaha

Tribe of Nebraska, the governing body of the Omaha Tribe shall be

known as the Tribal Council; and,

pursuant to Article IV, Section 1 (a) of the Constitution of the

Omaha Tribe of Nebraska, the Tribal Council has ihe authority to

negotiate with the Federal, State, and local governments on behalf

of the Tribe, and to advise and consult with the representatives of

the Department of the Interior on all activities of the Department

that may affect the Omaha Tribe; and,

pursuant to Article IV, Section 4(m) of the Constitution of the

Omaha Tribe of Nebraska, the Tribal Council has the authority to

adopt resolutions regulating the procedure of the Tribal Council

itself and of other Tribal agencies and Tribal officials; and,

the Tribal Council finds that on March 6, 2006, the Tribe and

Aberdeen Area Health Services entered into an Alternative Dispute

Resolution Agreement; and,

the Tribal Council finds that the purpose of the Agreement is to

identify and resolve the issues that are the “root cause” leading to

Page 7 of 3

(402) 837-5391

FAX (402) 837-5308

WHERAS,

WHEREAS,

WHEREAS,

WHEREAS,

WHEREAS.

»» WHEREAS,

the Tribe’s questioned and/ or disallowed cost and other

bookkeeping prablems which lead to the Tribe's “high risk”

designation and the imposition of sanctions covering fiscal years

1993 through 2006; and,

pursuant to the Agreement, the Tribe agreed to prepare a

Corrective Action Plan and to maintain internal controls over

Federal programs that provide reasonable assurances that the

Tribe is managing Federal awards in compliance with laws,

regulations, and the provisions of the P.L, 93-638 contract that has

a material effect on each of its Federal programs; and,

the purpose of this Resolution is to approve the attached Corrective

Action Plan, and the associated Payroll and Purchasing

Management Policies and Procedures, and,

the purpose of the Corrective Action Plan is to remedy repetitive

audit findings involving Financial Management Processes and

Procedures, and the accountability of the Tribal Council, Finance

Staff and Program Directors and their staff to understand and follow

those procedures; and,

the purpose of the payroll policy and procedure manual is to define

the process of compensating workers for work performed; and,

the purpose of the purchasing management policy and procedure

manual is to define the process of obtaining services, supplies and

equipment and how to do so in conformance with applicable law

and regulations; and,

the Tribal Council has determined that it is in the best interest of the

Omaha Tribe of Nebraska to approve the attached Corrective

Action Plan, and the associated Payroll and Purchasing

Management Policies and Procedures.

NOW THEREFORE BE !T RESOLVED:

That the Omaha Tribal Council hereby approves and shall

implement the Corrective Action Plan, andthe associated Payroll

and Purchasing Management Policies and: Procedures.

GERTIFIGATION

Page 2 of 3

This will certify that the foregoing résolution was considered at a meeting

of the Tribal Council of the Omaha Tribe of Nebraska, duly called and held on

CAD OF , and was adopted by a vote of 4 FOR,

=f AGAINST and ze NOT VOTING OR ABSENT with the Chairperson not

voting. A quorum of 37 was present.

INTRODUCED BY: __t

MOTION: Dnced Tpvitbasd

SECOND: FF _Crent

QUESTION: Sher - taseul Kee

Dated: _ -A-/ 2-4 & :

ae tte

Sordtaty, Omaha Tribal Council

Ghéiperson, Omaha Tribal Council te

Page 3 of 3

OTON Corrective Action Plan

Omaha Tribe of Nebraska

Corrective Action Plan

1.0 Purpose

The purpose of this Corrective Action Plan is to remedy repetitive audit findings

involving Financial Management Processes and Procedures, and the accountability of the

Tribal Council, Finance Staff, and Program Directors and their staff, to understand and

follow those processes and procedures. The Tribe has developed this Corrective Action

Plan to improve our business processes and internal controls, providing an increased

reliability on compliance, and thereby reducing audit findings, facilitating timely

reporting and audits, and removal from sanctioned status.

1 employees paid by Indirect Cost funding.

e Human Resources and Administrative staff

{Financial Officer and all Finance staff that

Financial Management refers to al

This includes the Chief Tribal Officer and th

that report up through the CTO, and the Chie

report up through the CFO.

on Plan has been developed in consultation with the

it is the understanding of the Omaha Tribal

an shall result in the closure of audit findings

d programs from 1993-2006. It is also the intent

rmance of ali Tribal Programs.

This Corrective Acti

Aberdeen Area Indian Health Service.

Council that implementation of this pt

related to the operation of IHS contracte:

of this Corrective Action Plan to improve the perfo

2.0 Overview

The Plan addresses the following areas:

21 Financial Management Policies and Procedures

2.2 Financial Management Software

2.3 Management Structure

24 Resolution of Findings

2.5 Removal of Sanctions

2.6 Amendments (to be added in the future).

3.0 Financial Management Policies and Procedures

The Financial Management Policy and Procedure manuals have been identified as

Page 1 of 7

OTON Corrective Action Plan

being outdated, incomplete and an inaccurate presentation of Tribal Operations thereby

resulting in audit findings.

The methodology we are following in the revision and development of our policies and

procedures is to initially document processes as they are today, so as not to continue to be

audited to processes that we do not follow. Current processes will then be re-engineered to

provide improved internal controls, enhanced program services, as well as compliance with the

Single Audit Act and OMB circulars A-87 and A-133.

Training of Program Directors and staff will be ongoing in this process. The revised

policies and procedures will be presented in a simple and concise manner and maintained as

living documents. Concern must be used to ensure that the revised procedures are achievable

under the constraints of Indirect Cost funding and staffing of qualified personnel in both Finance

and our Programs.

3.1 Current Process Documentation Timeline:

Human Resources Completed

Purchasing August 31, 2007

Payroll August 31, 2007

Indirect Cost February 28, 2008

Matching February 28, 2008

General Journal Entries March 31, 2008

Accounts Receivable May 30, 2008

Accounts Payable June 30, 2008

Travel July 31, 2008

Fixed Assets July 33, 2008

Record Retention August 31, 2008

Finance Disaster Recovery September 30, 2009

¢ will be passed by resolution of the Tribal

Council. Revisions to Policies and Procedures wil! be presented to the Council

for approval during January of each year. Program Director training will follow

the approval of each Policy and Procedure and updates.

Each Policy and Procedur

32 Responsibility for Compliance with Policies and Procedures:

« Tribal Council Officers

« Tribal Council

« Program Directors and their staff

e Chief Tribal Officer

e Human Resource Director

« Chief Financial Officer and Finance Staff

3.21 The Tribal Council and its officers have the ultimate

responsibility for enforcement of Policies and Procedures

Page 2 of 7

OTON Corrective Action Plan

according to the Constitution and Bylaws of the Omaha Tribe of

Nebraska:

Constitution Article IV — Powers Section 1]. Enumerated powers ~

the Tribal Council shall exercise the following powers, subject to

any limitations imposed by the Constitution or statutes of the

United States, and subject further to all express restrictions upon

such powers contained in this constitution and the attached bylaws.

{a) To negotiate with the Federal, State, and local governments

on behalf of the Tribe, and to advise and consult with the

representatives of the Interior Department on all activities of the

Department that may affect the Omaha Tribe.

(fh) To manage all economic affairs and enterprises of the Tribe

in accordance with the terms of a charter which may be issued to

the Tribe by the Secretary of the Interior.

G) To safeguard. Promote, and enforce the peace, economy,

safety, law and order, and general welfare of the Tribe and the

Omaha Indian Reservation; to regulate all manner of trade and

commerce; to regulate all manner of criminal and non-criminal

conduct, subject to any limitation of federal law.

(m) To adopt resolutions regulating the procedure of the Tribal

Council itself and of other Tribal Agencies and Tribal officials.

Bylaws Article !— Duties of the officers of the Tribal Council shall

be as follows:

‘The Chairman of the Tribal Council shall at all times have

general supervision of the affairs of the Tribal Council and such

matters as naturally pertain to the general welfare of the

community. It shal] also be the duty of the chairman to

countersign all checks drawn against funds of the organization by

the Treasurer.

The Secretary shall keep an accurate record of all

proceedings of the Tribal Council and furnish copies thereof to the

Superintendent and the Commissioner of Indian Affairs. He shall

be responsible for the prompt and efficient handling of all

correspondence pertaining to the business of the Tribal Council

and the Tribal Corporation. All official records of the Tribal

Secretary shall be open to inspection of the Tribe at all times.

The Treasurer shail be the custodian of all funds in

possession from any source. He shall be under bond to a surety

company of recognized standing in an amount to be determined by

the Tribal Council, such surety company and bond to be approved

by the Commissioner of Indian Affairs. He shall keep an accurate

record of all such funds and shal] disburse the same in accordance

with the vote of the Tribal Council and as designated by this

constitution and bylaws. The books of the Treasurer shal! be open

to audit and examination by the duly authorized officers of the

Page 3 of 7

OTON Corrective Action Plan

Secretary of Interior at al! times and shall be open to inspection by

members of the Tribal Council and its officers.

The subordinate officers, boards, and committees of the

Tribal Council shall perform such duties as the Tribal Council

shall, by resolution from time to time provide.

Bylaws Article V — Cooperation, Section 1:

The Tribal Council shall work in very close cooperation with

the Indian Service Bureau and various departments of the State of

Nebraska in matters of charity, education, recreation, social work,

and public health.

3.22 Tribal Council Members shall participate in an annual

review of this Corrective Action Plan completed between the

November election date and January 31 of the next year. It is

recommended that each Tribal Council member complete 638

contract training.

3.23 Contract Approval Authorization: the Chairman of the

Tribal Council shall sign approval to ali contracts in conjunction

with the Program Director (except where a contract is being

accepted and a Program Director has not yet been assigned). Both

signatures are required for an initial or renewal contract or grant.

Modifications to the Indian Health Services contract shal] be

signed by any of the seven Tribal Council members, as well as the

Program Director. If a Program Director is assigned after the

acceptance ofa contract, the new Director shall read the contract,

then sign and date the Finance copy of the contract accepting the

responsibility of the program.

3.24 Program Directors are responsible for understanding and

complying with Tribal Policies and Procedures as well as their

individual contract and grant rules and regulations.

3.25 The Chief Financial Officer and the Finance staff are

responsible for overseeing adherence to Policies and Procedures

and for communicating infractions to the Tribal Council, the

Program Director, the CTO, and to the Director of Human

Resources.

3.24 The CTO and the Human Resources Director are jointly

responsible under the direction of the Tribal Council for

disciplinary action for non-adherence to Tribal Policies and

Procedures.

4.0 Financial Management Software

FUTEX is the general ledger software used by the Tribe. The software system is

unstable and is the cause of some of our audit findings. Neither the Tribe nor the Indirect

Cost Funding is financially capable of purchasing and implementing a new software

Page 4 of 7

OTON Corrective Action Plan

package. We are applying for the IHS Management Grant and will replace our software

system if we receive this funding. If the grant is not received, we will continue to apply

for grants and will appeal to other Tribal Governments for help in obtaining and

implementing a new software package.

4.1 Software Implernentation Timeline

FUTEX is unable to provide a stable data download

necessary to map a data conversion to another software system. We will

implement new software at the beginning of a fiscal year, on October 1.

Programs that do not operate on our fiscal year will require manual entry

of summarized data. The FUTEX system will need to be utilized for detail

inquiry of those programs, and for the 90 day close out of the prior fiscal

year of fiscal year programs.

Due to the complexity of implementing a new system, and to

running two systems simultaneously, we will require additional qualified

staff. Software consultants will be needed for a successful software

implementation. Audit cost may also increase for the audit year we are on

two systems.

The Tribal Council may need to prioritize and budget additional

Triba} funding to supplement grant money received, or a sbortfall in

Indirect Cost funding.

5.0 Management Structure

The Tribal Chief Financial Officer (CFO) shall be supervised by the Tribal

Council, but shall report to the Treasurer. The hiring and the removal of the CFO

must be by majority vote of the Tribat Council.

Numerous audit findings relate to the lack of qualified, knowledgeable

staff within the Finance and Human Resources Departments, therefore, if funding

is available, the Tribe shall commit to hiring the most qualified individual for the

relative position. Non-Indian or non-enrolled Native American personnel will be

hired where there are no qualified Omaha enrolled applicants.

5.1 The Human Resource Director shall hire or develop an individual

from within its current staffing that will be delegated management

authority to make management decisions and perform ADP entry in the

Director’s absence.

5.2 The CFO shali hire an additional management level accountant to

supervise staff and perform financial accounting and reporting duties.

Page 5 of 7

OTON Corrective Action Plan

5.3 Low funding is an obstacle to hiring staff at this time. We intend

to hire or develop these positions by April 1, 2008.

6.0 Resolution of Findings:

The resolution of findings have and will occur as the Corrective Action Plan is

carried out.

6.1 Training and Technical Assistance

The Finance Department shall make a serious effort to upgrade the quality

of its accounting, through on-going training. This shall include technical

assistance for the finance staff from the Aberdeen Area Indian Health Service,

technical assistance from other funding agencies, and other training when funding

is available.

As part of the Corrective Action Plan for the Omaha Tribe of Nebraska,

the IHS shall provide technical assistance to the Tribe. Training is needed in the

areas of allowable cost, travel, records management and GASB 34.

Appropriations Law training (allowable cost) will include Council m

Directors of all programs.

embers and

6.2 It will be the policy of the Tribe to respond to all inquiries from funding

agencies in a timely manner. Communication to funding agencies must be

on-going. When questions arise pertaining to the operations of our

Programs, the Finance staff, the Council and Program Directors will

communicate with funding agencies to provide clarification and direction

of program operations.

6.3 The Tribe shall be committed to obtaining expert assistance outside the

Tribe when itis needed. An example of this is the current contracting of

Falmouth Institute to complete Indirect Cost proposals.

7.0 Removal of Sanctions:

The Omaha Tribe was placed on sanctions on October 1, 1999, while at the

Aberdeen Area Office for contract negotiations. At that time no one at the Area Office

could answer any questions or give any direction to the Tribe conceming the sanctions.

Since that time both parties have been educated through participation in the Alternative

Dispute Resolution (ADR) process. This has resulted in many positive changes for the

Tribe in the areas of financial management, policy and procedures and has opened

communication at many different levels. The Corrective Action Plan addresses

deficiencies found and a timeline for action. The ADR minutes reflect our efforts and

identify benchmarking for each item. The 2005 audit is being finalized now. Our intent

is to complete the 2006 audit within 3 months of the completion of the 2005 audit, or by

March 31, 2008.

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OTON Corrective Action Plan

As a Treaty Tribe the Omaha’s feel that the sanctions are only an additional

burden we carry to provide healthcare to the population we serve. To begin with the

Health Center is only funded at 70%. The loss of the lump sum payment means that the

interest earned (approximately $300,000 a year) is no longer available to supplement

program shortfalls. With al] the efforts toward correction and the audits nearly current

the Omaha Tribe requests the removal of the sanctions. If not removal, then an

agreement where the lump sum will be placed in a restricted bank account monitored and

released by the Indian Health Service. This would allow the Tribe to earn interest on the

funds, and reduce the financial damage caused by the sanction.

The removal or reduction in sanctions is being requested for FY08.

Page 7 of 7

OTON Resolution 08-21, 2/12/2008

OMAHA TRIBE OF NEBRASKA

PAYROLL MANAGEMENT POLICY AND PROCEDURE

This Payroll policy and procedure manual defines the process of compensating

workers for work performed.

All federal, state, and privately funded programs that are processed through

Omaha Tribe Finance Department must comply with this policy and procedure

manual.

INTRODUCTION

The procedure for an employee to receive payroll will be pursuant to the hiring

practices of the Omaha Tribe of Nebraska’s Personnel Manual.

The Human Resources Personnel Action form is the source document for employee

or consultant entry to the ADP payroll system. Human Resources staff is

responsible for entering all Personnel Actions to the payroll system. Payroll

personnel are responsible for processing the payroll.

Personnel Action Form:

» Administered by and entered to the ADP system by the Human Resources

Department. .

e Source document for approval signatures.

e Required for all changes in pay and status.

« Program Directors are responsible for completing the program accounting

code for payroll charges.

e Primary copy of the Personnel Action form i

Resources employee fle.

e Copies of each completed Personnel Action form will be forwarded to the

Payroll Department and to the Program Director.

« New employees will not be paid until a Personnel Action Form is completed

and entered to ADP.

e Personnel Action forms are available from the Human Resources staff in the

Tribal Administration office, and by the Human Resources Specialist located

at the Car! T. Curtis Health and Education Center.

+ Program Directors are responsible for obtaining and completing Personnel

Action forms for their employees.

s retained in the Human

Please see the Human Resources procedure manual for more information on the

Personnel Action Form, or call the Human Resources Department at 402-837-5391.

OTON Resolution 08-21, 2/12/2008

or pension. These employees who are terminated or resign will be paid their

final check minus deductions on their last day of employment.

Payroll Filing System:

» The Payroll staff will be responsible for payroll preparation and payroll

recordkeeping.

« Payroll files will be maintained by individual, by program.

« When an employee moves to another program, the employees file will be

moved to the appropriate program file area in payroll.

» Any subsequent changes applied to the a Personnel Action form will be

forwarded from HR and filed by the payroll department after being properly

reviewed by each HR Manager.

» Payroll staff shall maintain individual earnings records and safeguard these

records in their department.

Tax Filing

Due to the fact that the Omaha Tribe of Nebraska uses ADP they file the tribe’s

federal and state taxes and withholdings.

> A.D.P. will insure compliance with IRS and state regulations concerning

filing of forms 941, W-2, 1099.

« ADP then forwards all transactions that are completed by the payroll clerk

to the Omaha Tribe of Nebraska via mail.

e The mail includes a CD-ROM for review of each payroll transaction. This is

given to the accounting supervisor for filing.

e Should there be a concern or issue it will easily accessible for reviewing.

on a quarterly basis a copy of our 941 worksheets. The

ryroll of all totals.

« ADP forwards

cialist has set up an excel spreadsheet per pa.

accounting spe!

» twill be the duty of the accounting specialist to review and reconcile the

worksheet.

e Ifany issues do arise we will contact ADP and inform them of the issue and

make the corrections they will amend our reports.

OTON Resolution 08-21, 2/12/2008

Payroll Preparation

‘The Payroll staff will prepare payroll checks

The Payroll checks when printed are already pre-signed by designated

officials of the Omaha Tribe of Nebraska.

These officials include the Chairperson, Vice-Chairperson, Tribal Secretary,

Treasurer and other Tribal Council members. ‘These individuals are the

elected officials of the Omaha Tribe of Nebraska and have sole signature

authority for approval

Payroll transfers must be completed before distribution of payroll checks.

Each employee is required to personally obtain his or her check and a sign

out sheet is there to verify they obtained their own check.

All Payroll information is confidential and can only be giv

signed release by the employee or by a court order.

en out by either a

OTON Resolution 08-21, 2/12/2008

Procedure:

POLICY / PROCEDURE

Description: This procedure ens

Nebraska have wor'

PAYROLL

ures that all employees of the Omaha Tribe of

ked at any time during the previous two weeks

receive payment for their services. Also, that all necessary reports,

including payroll taxes and deposits are filed accurately and timely.

Responsible Party

Human Resources:

Payroll Clerk:

Director of Program:

Action

Process all P.A.’s (Personnel Action forms) and

any changes to be made to employee

maintenance records on the payroll system.

Signs them and enters them in the Automatic

Data Processing system, (ADP).

Reviews all P.A.’s and changes on the payroll

system to make sure all necessary entries have

been made. Documentation is filed in individual

payroll file.

Reviews and signs all punch detail reports,

(timesheets), from employees under his/her

supervision. Any questionable entries on

timesheets should be reviewed with employee.

Also when an employee is working for multiple

programs they are requested to provide a valid

timesheet corresponding with each program. ”

‘The director then forwards completed timesheets

to the payroll department by Monday morning

the week of payroll, (This deadline is changed

according to Holiday pay weeks). The Omaha

Tribe of Nebraska does recognize that various

funding agencies may require payroll procedures

be in compliance with their funding regulations,

such as, E.P.A.

OTON Resolution 08-21, 2/12/2008

Payroll Clerk:

Payroll Clerk:

Payroll Clerk:

Payroll Clerk:

Brings all timesheets together prior to entering

information. Next, checks all vacation hours and

sick hours that are listed on timesheets against

the leave report from last pay period. If

employee does not have enough time available

that they entered on their timesheet, it is

necessary to alter their hours to be paid

accordingly. This will also require a phone call

and e-mail to the supervisor and or employee te

notify them of the change.

Opens file that contains al] vacation and sick

hours from last pay period and enter the hours

off current timesheets per employee. At this time

also enter any withholdings to be included for

this pay period that are not done every pay

period, (travel etc.). (NOTE: Salary employees

are not required to turn in a timesheet unless

they have taken vacation or sick hours. Reviews

the hours and updates file before entering the

hours inte ADP.

Input Timesheets: Using the E-time go into ADP

under pay your employees and open hour and

earnings. Enter Processing Group — Biweekly,

Timesheets for regular, pay date will

automatically come up (does not do this for

supplemental) Enter employee info for any

employee who had taken vacation or sick or did

not work 80 hours or if they have OT hours

approved, (all overtime MUST be approved by

director of the program in order for OT hours to

be paid). If they worked a full 80 hours and did

not take any time off you need to do nothing,

their default timesheet will kick in. It will be

necessary to adjust deductions that are different

from their default timesheet like travel

deductions, pay advances, one time deductions

etc. After ail hours and adjustments are entered.

and saved.

Calculating Payroll: Enter Regular or

Supplemental, pay date and click available item

to select item, then calculate. Transmit data to

ADP. When transmittal is complete a message

will come up when calculations are complete and

it will inform you when something Is wrong so

OTON Resolution 08-21, 2/12/2008

Payroll Clerk:

Payroll Clerk:

Accounting Specialist:

Payrolt Clerk:

ADP pe nit studls

Erurlepas :

you can check ft out and correct it if necessary,

Click OK and it will close.

After calculations are completed go into

review/modify calculated payroll and delete any

employee timesheet that should net get paid,

(these' are the FMLA, LOA or no timesheet

turned in employees). Also, this is where any

adjustments that need to be made are entered. If

you find it necessary to reealeulate for any

reason these will have to be checked and deleted

again.

Complete a Calculated Check Register: Print

this out and then check the report against the

payroll summary report to make sure that

correct hours are being paid per employee and

that sick and vacation hours are used. Also,

make sure that no check is being issued to

someone that should not be getting one or being

charged to a different department. After

reviewing forward payroll summary to

accounting specialist for to complete payroll

transfers. Utilizing the payroll summary the

accounting specialist will review all deductions at

the request per employee.

Review the calculated check register that is

forwarded from the Payroll Clerk to make sure

all is correct. It wil be necessary to transfer

money into payroll account to cover payroll.

After reports are run, calculate the total amount

needed to cover payroll. This is the Check

Register total plus the total for the employer

share, (social security and Medicare), payment.

Forward information to accounting supervisor

for approval to cut payroll transfers, deductions

and payroll checks or question any entry that

seems incorrect.

Printing Payroll Checks: After approval from

accounting supervisor the payroll clerk will

proceed to print payroll checks. After printed

checks are complete the payroll clerk will group

the employee checks into departments. At this

time the payroll clerk will attach a summary of

hours worked to each employee check and to be

OTON Resolution 08-21, 2/12/2008

Accounting Supervisor:

Authorized Signer:

Council:

Accounting Specialist:

Payroll Clerk:

Payroll Clerk:

Payroll Clerk:

put into envelopes for either delivery or pickup.

Also a summary report will be attached to the

department for director’s review. Should there

be any concerns the director can contact the

accounting supervisor for any solutions.

Forward correct amount of payroll transfers and

deductions to accounts payable to use in cutting

payroll transfers. After payroll transfer checks

are complete a designee will be authorized to

transfer deposits to bank prior to release of

payroll. Accounts payable will mail all

deduction checks.

Individuals who have been given authority signs

the payroll transfer checks before returning it to

the accounting specialist.

Signs the’ payroll transfer checks before

returning it to the accounting specialist.

Take the signed transfer check to the bank and

wait while a teller does the transfer. The teller

will give you the transfer slips and a copy of the

payroll transfer sheet for our records. Keep a

running total of these transactions on a

Columnar Pad sheet, (just for our records).

Record the name and address of any checks that

are mailed to employees on the form “Check

Sign out”. A list of the employees that have

requested their check be mailed is posted in the

work area of the payroll administrator close to

the computer.

Oversees the pickup of the checks and will

request the signature of the party picking up the

checks for a department. Any checks that are

not picked up by the Monday after payday will

be sent to the accounting receptionist for

mailing.

Reports need to be completed for the following,

and filed.

Check Register - Summary check/transaction

register, edit summary, penefit summary

OTON Resolution 08-21, 2/12/2008

Deductions: A report will be forwarded to the

accounting specialist from payroll clerk for

review and forward to accounts payable for

checks to be completed. After completion the

accounting receptionist will mail all deduction

checks and will file accordingly. Deductions are

a voluntary service completed by the Omaha

Tribe of Nebraska.

POLICY / PROCEDURE

END OF MONTH

Description: This procedure ensures that necessary reports are completed on 4

monthly

basis.

Responsible Party

Payroll Clerk:

Contract Specialist Clerk:

Accounting Supervisor

Action

Reports that need to be completed at end of

month include:

Leave Liability: Print out a report for each

individual program. Send these reports to the

program directors. This enables the director to

keep track of the available hours each employee

of the program has to use and the total liability

to their program. Print out a summary report of

the leave liability for the Accounting Supervisor.

The Accounting Supervisor will forward the

information to the HR Director, Chief Financia!

Officer, and Chief Tribal Officer.

Financial Report: Finance department will send

monthly reports to each program director to

reconcile the wage and fringe benefits. If any

questions or concerns the director will contact

either the Accounting Supervisor and or

Contract Specialist to resolve issue,

Staff Report: This is completed at the end of the

month. It is a summary of the activities that were

completed by the payroll clerks during the

month, The Accounting Supervisor will report

to the Chief Financial Officer.

10

OTON Resolution 08-21, 2/12/2008

POLICY / PROCEDURE

POLW sys Se

END OF QUARTER

Description: This procedure ensures that necessary quarterly reports are

completed and

Processed in a tim

Responsible Party

Accounting Specialist:

Accounting Supervisor:

Accounting Supervisor:

Accounting Supervisor:

ely manner.

Action

Total the payroll reports for the quarter. Total

and print the quarterly summary for the

quarter. Reconcile quarterly 941 reports sent

from ADP for the Tribal Organization. These

figures must all match and in case they do not it

will be necessary to investigate and find out why.

Files ali quarterly report copies from ADP. Also

forward copies to accounting specialist for

reconciliation.

Should any discrepancies arise it will be the duty

of the accounting supervisor to work with the

accounting specialist and contact ADP for

possible solutions and or amendments.

In ADP: Reports, History, Earnings, open the

earnings-miscellaneous report. Make sure that

the correct dates for the quarter are entered by

reviewing the mailed CD-ROM provided by

ADP. Print this report out.

qd

Addendum A to OTN PAYROLL MANAGEMENT POLICY AND PROCEDURE

Resolution 08-21, 2/12/2008

Omaha Tribe Environmental Protection Department

Time Accounting Form

EPA Assistance Number:

Sunday | 8-9 9-10 10-11 1-12 12- 12:30- | 1:30- 2:30- 3:30-

12:30 1:30 2:30 3:30 4:30

Task

Code

Activity Description:

Monday | 8-9 9-10 10-11 T-12 12- 12:30- | 1:30- 2:30- 3:30-

12:30 1:30 2:30 3:30 4:30

Task

Code

Activity Description:

Tuesday | 8-9 9-10 10-11 11-12 12- 12:30- ) 1:30- 2:30- 3:30-

12:30 1:30 2:30 3:30 4:30

Task

Code

Activity Discription:

Wednesday | 8-9 9-10 10-11 W-120 | 12- 12:30- | 1:30- 2:30- 3:30.

12:30 1:30 2:30 3:30 4:30

Task Code

Activity Description:

Thursday | 8-9 9-10 10-11 1-12 _ i2- 12:30- 1:30- 2:30- 3:30-

12:30 1:30 2:30 3:30 4:30

Task Code

Activity Description:

Friday 8-9 ] 9-10 10-11 11-32 12- 12:30- 1:30- 2:30- 3:30-

12:30 1:30 2:30 3:30 4:30

Task

Code

Activity Description:

Saturday | 8-9 9-10 10-11 11-12 12- 32:30- 1:30- 2:30- 3:30-

12:30 1:30 2:30 3:30 4:30

Task

Code

Activity Description:

Sunday | 8-9 9-10 10-14 11-12 12- $2:30- 1:30- 2:30- 3:30-

12:30 1:30 2:30 3:30 4:30

Task

Code

Activity Description:

PAGE 1

Addendum A to OTN PAYROLL MANAGEMENT POLICY AND PROCEDURE

Resolution 08-21, 2/12/2008

| Monday | 8-9 T9-10 10-1) | li-12 | 12- 12:30- | 1:30- 2:30- | 3:30-

12:30 1:30 2:30 3:30 4:30

Task

Code

Activity Description:

Tuesday | 8-9 9-10 10-11 11-12 12- 12:30- 1:30- 2:30- 3:30-

12:30 1:30 2:30 3:30 4:30

Task

Code

Activity Description:

Wednesday | 8-9 9-10 10-11 11-42 12- $2:30- 1:30- 2:30- 3:30-

12:30 1:30 2:30 3:30 4:30

Task Code

Activity Description:

Thursday | 8-9 9-10 10-11 11-12 12- 12:30- 1;30- 2:30- 3:30-

12:30 1:30 2:30 3:30 4:30

Task Code

Activity Description:

Friday 8-9 9-10 10-11 11-12 12- 12:30- 1:30- 2:30- 3:30-

12:30 1:30 2:30 3:30 4:30

Task

Code

Activity Description:

Saturday | 8-9 9-30 10-11 11-12 12- 12:30- 1:30- 2:30- 3:30-

* | :12:30 1;30 2:30 3:30 4:30

Task

Code

Activity Description:

—_

l hereby certify that this

, 2007 and ending on

Executive Director

Omaha Tribe of Nebraska and Iowa

Environmental Protection Department

Chief of Tribal Operations (Exec. Dir. Only)

Omaha Tribe of Nebraska and Iowa

PAGE 2

, 2007.

is a true accounting of hours worked for work week beginning on

Employee Signature

Addendum A to OTN PAYROLL MANAGEMENT POLICY AND PROCEDURE

Resolution 08-21, 2/12/2008

Omaha Tribe of Nebraska and lowa

Environmental Protection Department

Task Code Listing

FY 2007

Task Code Description

101 Management/Oversight

102 Financia) Management

103 Quality Assurance/Quality Control

104 Workplan Development

105 Workplan Negotiation

106 Workplan Finalization

107 Workplan Task Activity

108 Workplan Task Completion

L 109 Data Collection Activity

110 Community Meeting

Hi Staff Meeting

12 Stated Meeting

113 RTOC Business/Teleconference

114 RTOC Meeting

118 Tribal Council Meeting

116 Travel

7 Training

8 Communication with Project Officer (Federal Agency)

119 Communication with Colleagues (other Tribal Departments, etc...)

120 Communication with other Federal, State, and/or Local Agencies

121 Review of applicable program (Federal) regulations

122 Program Review

123 Staff Evaluations

124 Project Closure

125 Inter-Office Meeting with Federal Agency

126 Workplan Reporting

127 Travel Reporting

128 Presentation Development

129 Communication with Tribal Consultant

130 Annual Leave

131 Sick Leave

132 Federal/National Holiday

133 Birthday Leave

134 Other Business

PAGE 3

Addendum A to OTN PAYROLL MANAGEMENT POLICY AND PROCEDURE

Resolution 08-21, 2/12/2008

The following time sheet shall be used by the Omaha Tribe Environmental

Protection Agency programs,

e The time sheet will be completed daily.

e The EPA time sheets will be reviewed, signed, and appropriately approved,

then forwarded to the Finance Payroll office by noon on Monday morning

following the end of a payroll period.

» The time sheet will be the Payroll source document for EPA employee time

documentation.

« Payroll staff will enter time from the EPA time sheet.

+ Ifan EPA employee records time on more than one program, the Payroll}

Department will provide the Payroll Supervisor a copy of the timesheet(s).

« The Payroll Supervisor will oversee that payroll charges are charged to the

correct EPA program through the payroll reimbursement process.

« Acopy of all time sheets shall be retained in the EPA office.

Version May, 2007 Resolution 08-21, 2/12/2008

OMABA TRIBE OF NEBRASKA

PURCHASING MANAGEMENT POLICY AND PROCEDURE

This purchasing policy and procedure manual defines the process of obtaining services,

supplies and equipment in conformance with applicable laws and regulations.

All federal, state, and privately funded programs that are processed through Omaha Tribe

Finance Department must comply with this policy and procedure manual.

The procurement of human resources, both contract and regular employees, is the

responsibility of the Human Resource Department and is addressed under the Human

Resources Policy and Procedure Manual.

RESPONSIBILITY FOR COMPLIANCE

« Tribal Council.

» Program Directors and their staff.

e Chief Tribal Officer.

« Chief Financial Officer and Finance staff.

STATEMENT OF RESPONSIBILITIES

The following is a summary of the major responsibilities of the various individuals and

groups involved in the Procurement and Disbursement activities. These are presented in

order to clearly emphasize the importance of the various roles that must be performed to

make the procedures which follow work well.

RIBAL CHAIRMAN

TRIBAL CHAIRMAN

Along with the Chief Financial Officer and the Chief Tribal Officer, the Tribal Chairman

plays a key role in controlling Tribal expenditures and the use of Tribal assets. As the

Chief Executive Officer of the Tribe, the Chairman may make exceptions to procedures

within the constraints of Tribal policy. This authority should be used sparingly, because

deviation from established procedures will cause the whole financial control of the Tribe to

weaken and these procedures to be meaningless. If procedures outlined are followed, the

Chairman’s workload will be minimized and the system which has been established will

support proper administration of the Tribe.

Version May, 2007 Resolution 08-21, 2/12/2008

TRIBAL COUNCIL

The final authority for the management of Tribal resource sets with Tribal Council. The

key responsibility of the Council is in establishing and insisting upon standard practices for

running the Tribe’s financial affairs (policies and procedures). Within these procedures,

Council approval and review is also reserved for authorization of contracts. Beyond this

each Council member is responsible for personally complying with established policies and

procedures and for overseeing that all programs are in compHance,

PROGRAM DIRECTORS and PROGRAM STAFF

Program Directors and their staff members that complete purchase requisitions are

responsible for knowing and understanding their program requirements. Before a

requisition is completed, the requisitioner must ask themselves these questions:

Js this an Allowable Cost under OMB Circular A-877

Js this a Reasonable Cost for this purchase?

1s this an Allocable Cost under my work plan?

1s this an Eligible Cost within my program?

AYN

PROCUREMENT MANUALS

« The distribution of the Omaha Tribe of Nebraska Procurement and Property

Management Polices and Procedures Manual will be coordinated by the Finance

Office so that all manuals can be kept up-to-date.

« Policy changes will require review and approval by the Tribal Council. The Chief

Financial Officer shall be responsible for the review and submission of any updates

or revisions to the manual,

« Procedures revisions will be submitte

d by the Finance staff to the Chief Financial

Officer. Once approved, updates or revisions to the policies and procedures will be

distributed to all holders of the Omaha Tribe of Nebraska Purchasing and Property

Management Policies and Procedures Manuals. ;

« Minor changes to the manual for the purpose of clarifying the intent of the

procedure, or to correct language, spelling or format errors do not require approval

by the Tribal Council.

» A file containing al} superse

Purchasing Manager.

ded policies and procedures will be maintained by the

Version May, 2007 Resolution 08-21, 2/12/2008

PURCHASING MANAGEMENT

POLICIES AND PROCEDURES

POLICY OBJECTIVES

POLL x LOU

Purchasing of goods an

To contro! expenditures by obtaining services, supplies and equipment with the

lowest cost and satisfactory quality.

To make the purchasing process more efficient for Program Directors and

Supervisors who have the ultimate responsibility to ensure that their program

purchases are in compliance with federal, state, or local contract requirements as

they apply to their program, and with Tribal policies.

To include internal contro) elements necessary to properly account for purchasing

transactions and the safeguard of Tribal assets.

d equipment requires the completion of a REQUISITION FORM

and the issuance of a PURCHASE ORDER:

Step 1:

Complete the Requisition Form and Approval(s):

Requisition forms are distributed by the Purchasing Manager in the Finance office,

the Finance staff back ups to the Purchasing Manager, and by the Purchasing

Specialist located at Carl T. Curtis Health and Education Center.

Requisition forms are numbered and tracked by the Purchasing Staff.

The requisition form includes a detail listing of all items to be purchased, cost of

items, total requisition cost, and the purchase from vendor name.

The Program Director will code the appropriate budget account number(s) on the

requisition.

The Program Director must approve the Purchase Requisition by signing the

requisition form. The requisition form is the documented purchase approval of the

program director.

The Program Director is responsible for all expenditures of their program. The

Director is required to know their programs requirements, and to prevent

overspending of their approved budget.

The approved and completed Requisition Form will be returned to Purchasing staff.

Issuance of a Purchase Order:

Upon receipt of an approved and completed purchase requisition, 4 purchase order

will be prepared by the Purchasing staff. The purchase order will be completed

within two business days after the receipt of the purchase requisition.

The purchase order will be signed by the Purchasing Manager or the Purchasing

Specialist. The CFO, the Senior Financial Reporting Analyst, or the Accounting

Manager may sign the purchase order during the absence of Purchasing staff.

3

Version May, 2007 Resolution 08-21, 2/12/2008

» The purchase order is intended to manage vendors. The Purchasing Manager is

responsible for vendor negotiation and compliance. An exception to this is the Carl

. Curtis contract health vendors. Contract Health vendors will be managed by

Cari T. Curtis management staff.

e No business will be done with vendors who do not accept purchase orders. The

Finance Office will formally notify vendors of this policy.

© Purchase orders are numbered and entered to the Futex software system.

* Purchase orders are filed numerically and stored in the Finance Department.

3. Actual purchase transaction:

° Most of our program purchases are completed by program staff physically going to

a retailer and making their purchase. Tbe purchase receipt from the vendor must

be attached to the applicable requisition and forwarded to Finance.

+ Ifan item is delivered to a program, the Program Director must attach the receiving

documentation to the invoice and the original purchase requisition and forward all

te Finance for payment.

e Documentation for vendor payment must be received in Finance at least ten

business days prior to the vendor payment due date.

* In some instances a requisition and purchase order will be completed for items that

will be distributed at a program function. The Program Director is responsible for

forwarding a list of actual recipients to Finance within five days of the program

function.

4, Exceptions to the requirements for purchase requisitions and purchase orders:

° Property and liability insurance. The Purchasing Manager oversees bidding and

negotiation of property and liability insurance. The Purchasing Manager approves

program payments for each program’s applicable insurance payment.

e Cellular telephones. The Purchasing Manager oversees bidding and negotiation of

the cellular telephone contracts. The Purchasing Manager approves program

payments for cell telephone usage. The Program Director is responsible for

reviewing cell telephone use, and insuring that staff members are using cell phones

appropriately.

e Long distance telephone service. The Purchasing Manager with the assistance of

the Fmance Computer Technical Analyst will oversee bidding and negotiation of

long distance telephone service. The Purchasing Manager approves program

payments for each program’s applicable long distance telephone charges. The

Program Director is responsible for reviewing long distance telephone usage and

ensuring long distance is being used for program related activities.

e Utility payments (telephone, water, sewer, propane, electricity). Utilities are

negotiated and overseen by the Purchasing Manager. All invoices and statements

will be sent to the Purchasing Director, and charges will be allocated to the

applicable program. Programs that are physically located outside of Macy may

receive utility bills. These pills do not require a requisition or purchase order but

should be approved by the program director.

° Travel payments. Travel does not require a requisition or a purchase order. There

is a separate travel policy and procedure. Travel is not a part of the Purchasing

policy and procedure.

4

Version May, 2007 Resolution 08-21, 2/12/2008

« Legal bills. Legal bills do not require a requisition or purchase order. Programs

are required to receive Council approval when requiring the assistance of the Tribal

attorneys. Carl T. Curtis legal bills are approved by the CEO of Car! T. Curtis or

her designated representative.

© Tribal assistance and donations. Payments of this type from Tribal funds do not

require a requisition or a purchase order.

e Bank charges, fees, etc, do not require a requisition or a purchase order.

« Publications and other transactions similar in nature to those listed above will not

require a purchase requisition and a purchase order.

5. A total purchase of any item (or group of items) of $5,000 or more require bids as

follows, unless they are determined to be sole source items :

« The total cost of a purchase includes all costs of completing a purchase. If there are

several vendors and invoices included in a purchase, the total cost is the

consolidated cost. :

Three bids required. In the case of a sole source item, one bid is required, For a

reference as to when an item can be considered a sole source item, see 25 CFR

276.12 (b) (3) (vi).

e Advertising for written bids is required.

e All planned purchases totaling $5,000 or more require the approval of the Tribal

Council on the requisition, or by attaching Council meeting minutes to the

requisition.

e The bids must be presented to the Tribal Council by the Program Director. The

Purchasing Manager will assist the program director in the bid process if requested,

put is not required to participate in the bid process,

+ A purchase order will not be issued until the bids have been collected and the

Council has approved the requisition form.

If the lowest bid is not chosen, the Program Director must include a narrative

explaining the purchase choice,

¢ Purchases of used equipment or

supported by a documented appraisal or

not excessive.

* Preference will be given to Indian-owned businesses so long as they are reasonably

competitive in price and quantity of materials and workmanship.

e Omaha Tribe businesses and programs receive first preference. Bids will not be

required when a Tribal business or program can complete work for an amount

deemed reasonable by the Program Director and the Tribal Chairman.

Payment documentation must be submitted stapled or bound together to Finance,

fixtures with a value in excess of $5,000 will be

other evidence that the requested price is

including:

o Requisition copy approve

Council meeting minutes).

Purchase order copy.

Three or more bids collected.

Invoice from vendor signed by the Program Director.

Additional documentation or narrative that may provide a better

understanding of the purchase.

a by Tribal Council and the Program Director (or

oo00o°0

Version May, 2007 Resolution 08-21, 2/12/2008

6. Copy machines, printers, computer equipment must be purchased and negotiated by the

Purchasing Director.

° Program Directors DO NOT bave the authority to sign a lease or 2 maintenance

agreement for equipment,

° The Purchasing Manager will negotiate and/or approve any purchase or lease of

equipment. ,

e The Computer Technical Analyst located at Carl T. Curtis will assist with all Carl

T. Curtis purchases of computer equipment and printers, and the Purchasing

Manager is not required to approve the purchase.

7. Contract provisions. You must ensure your contracts are sound and complete under

applicable state and local jaw. Contract agreements must contain the provisions listed

below:

(1) Administrative, contractual, or legal remedies in instances

where contractors violate or breach contract terms, and provide for such

sanctions and penalties as may be appropriate. (Contracts more than the

simplified acquisition threshold) 4. Remedies — Contracts must include administrative,

contractual, and legal remedies for use in cases in which contractors violate or breach

contract terms. The contract must also make clear the remedial actions you may take.

(2) Termination for cause and for convenience by the grantee or

subgrantee including the manner by which it will be effected and the

basis for settlement. (All contracts in excess of $10,000) Termination — Contracts in

excess of $10,000 must explain the conditions under which you may terminate them for

cause or for your convenience, including the process for bringing about the termination

and the basis for settlement.

(3) Compliance with Executive Order 11246 of September 24, 1965,

entitled “Equal Employment Opportunity," as amended by Executive Order

11375 of October 13, 1967, and as supplemented in Department of Labor

regulations (41 CFR chapter 60). (AH construction contracts awarded in

excess of $10,000 by grantees and their contractors or subgrantees)

(4) Compliance with the Copeland ~ anti-Kickback" Act (18 U.S.C.

874) as supplemented in Department of Labor regulations (29 CFR part 3).

(All contracts and subgrants for construction or repair)

(5) Compliance with the Davis-Bacon Act (40 U.S.C. 276a to 2762-7)

as supplemented by Department of Labor regulations (29 CFR part 5).

(Construction contracts in excess of $2000 awarded by

grantees and subgrantees when required by Federal grant program

legislation)

(6) CompHance with Sections 103 and 107 of the Contract Work Hours

and Safety Standards Act (40 U.S.C. 327-330) as supplemented by

Department of Labor regulations (29 CFR part 5). (Construction contracts

awarded by grantees and subgrantees in excess of $2000, and in excess of

$2500 for other contracts which involve the employment of mechanics or

6

Version May, 2007 Resolution 08-21, 2/12/2008

laborers)

(7) Notice of awarding agency requirements and regulations

pertaining to reporting.

(8) Notice of awarding agency requirements and regulations

pertaining to patent rights with respect to any discovery or invention

which arises or is developed in the course of or under such contract.

(9) Awarding agency requirements and regulations pertaining to

copyrights and rights in data.

(10) Access by the grantee, the subgrantee, the Federal grantor

agency, the Comptroller General of the United States, or any of their

duly authorized representatives to any books, documents, papers, and

of the contractor which are directly pertinent to that specific

contract for the purpose of making audit, examination, excerpts, and

transcriptions.

(11) Retention of all required records for three years after

grantees or subgrantees make final payments and all other peuding

matters are closed.

(12) Compliance with all applicable standards, orders, or

requirements issued under section 306 of the Clean Air Act (42 U.S.C,

1857(h)), section 508 of the Clean Water Act (33 U.S.C. 1368), Executive

Order 11738, and Environmental Protection Agency regulations (40 CFR

part 15). (Contracts, subcontracts, and subgrants of amounts im excess

of $100,000) .

(13) Mandatory standards and policies relating to energy efficiency

which are contained in the State energy conservation plan issued in

compliance with the Energy Policy and Conservation Act (Pub. L. 94-163,

89 Stat. 871).

If you have any questions regarding this process please contact the Purchasing Director at

402-837-5391.