CRITERIA A tribe, tribal organization, or consortia receiving advance payments under the ISDEAA or the Tribally Controlled Schools Act may invest advance payments (some recipients refer to these advanced payments as “deferred revenue”), before such funds are expended for the purposes of the grant, contract, or funding agreement, so long as such funds are (1) invested only in obligations of the United States or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission (SEC) and which only invest in obligations of the United States or Securities that are guaranteed or insured by the United States or (2) deposited only in accounts that are insured by an agency or instrumentality of the United States CONDITION The Campus had investments of federal funds that were deemed unallowable. CAUSE The Campus did not have a process in place to ensure that investment types were allowable. EFFECT The Campus was not in compliance with Indian Self-Determination and the Education Assistance Act CONTEXT The Campus had investments of $540,574 that appear to be unallowable. RECOMMENDATION The Campus should ensure its financial investments are only invested in the obligations of the United States or mutual funds registered with the SEC and which only invest in obligations of the United States
CRITERIA The Board adopted policies that require the collection of quotes for purchases of at least $10,000 but no more than $100,000, and formal bid procedures for purchases over $100,000. In addition, the Uniform Guidance requires employees to verify that the vendor, supplier, contractor, subcontractor, provider, or their respective principals (e.g., owners, top management, etc.) with expenditures in excess of $25,000 are not suspended, debarred or otherwise excluded by the Federal Government. The Campus should consult the Federal Excluded Parties List System (EPLS) before awarding funds and print the documentation to maintain in the contract file. This requirement is specified in 2 CFR §180.220. CONDITION The Campus did not follow its Board adopted policies or federal regulations regarding the collection of quotes and suspension and debarment. CAUSE The Campus has not implemented controls to perform the collection of quotes and suspension and debarment checks for vendors. In addition, documentation was not always maintained. EFFECT The Campus was not in compliance with the Board adopted policies. Additionally, the Campus was not compliant with 2 CFR §180.220 and as a result could have entered into a contract with a suspended or debarred party. CONTEXT For two of two purchases reviewed within the Campus’s quote range, quotes were not maintained. In addition, the Campus did not check to see if vendors were suspended or debarred. However, it was determined that vendors were not suspended or debarred. Samples were not intended to be, and were not, statistically valid samples.
CRITERIA Campus management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure that all financial activities are properly processed and reported. Additionally, the Campus is required, except where otherwise authorized by statute, to ensure costs meet the general criteria outlined in 2 CFR 200.403 in order to be allowable under federal awards, including the costs be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. The Single Audit Reporting Package must have a report date nine months after fiscal year-end. CONDITION The Campus did not follow its Board adopted policies for federal regulations regarding disbursements to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. The Campus did not provide all of the audit information for fiscal year 2021-22 in a timely manner to allow sufficient time for the audit to be completed by the deadline. CAUSE The Campus has not implemented controls over disbursement transactions. In addition, documentation was not always maintained. EFFECT The Campus was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The following items were noted during our review of disbursement transactions: For four of 40 disbursements reviewed, supporting documentation was not maintained. The Campus did not maintain credit card statements for all credit cards. The Campus did not maintain a complete list of credit card users to ensure possession was monitored. For six of 40 disbursements reviewed, dual signatures were not obtained when issuing the check.
CRITERIA The Campus is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425. Quarterly and semi-annual reports are required to be submitted no later than 30 days after the end of each reporting period. CONDITION Federal Financial Reports SF-425 were not always submitted on a timely basis. CAUSE The Campus’s procedures were not always followed due to turnover at the Campus. EFFECT The Campus was not always in compliance with federal regulations and guidelines for SF-425 submission. CONTEXT The second and fourth quarter Federal Financial Report, SF-425 was not filed within 30 days of the end of the reporting period.
CRITERIA A tribe, tribal organization, or consortia receiving advance payments under the ISDEAA or the Tribally Controlled Schools Act may invest advance payments (some recipients refer to these advanced payments as “deferred revenue”), before such funds are expended for the purposes of the grant, contract, or funding agreement, so long as such funds are (1) invested only in obligations of the United States or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission (SEC) and which only invest in obligations of the United States or Securities that are guaranteed or insured by the United States or (2) deposited only in accounts that are insured by an agency or instrumentality of the United States CONDITION The Campus had investments of federal funds that were deemed unallowable. CAUSE The Campus did not have a process in place to ensure that investment types were allowable. EFFECT The Campus was not in compliance with Indian Self-Determination and the Education Assistance Act CONTEXT The Campus had investments of $540,574 that appear to be unallowable. RECOMMENDATION The Campus should ensure its financial investments are only invested in the obligations of the United States or mutual funds registered with the SEC and which only invest in obligations of the United States
CRITERIA The Board adopted policies that require the collection of quotes for purchases of at least $10,000 but no more than $100,000, and formal bid procedures for purchases over $100,000. In addition, the Uniform Guidance requires employees to verify that the vendor, supplier, contractor, subcontractor, provider, or their respective principals (e.g., owners, top management, etc.) with expenditures in excess of $25,000 are not suspended, debarred or otherwise excluded by the Federal Government. The Campus should consult the Federal Excluded Parties List System (EPLS) before awarding funds and print the documentation to maintain in the contract file. This requirement is specified in 2 CFR §180.220. CONDITION The Campus did not follow its Board adopted policies or federal regulations regarding the collection of quotes and suspension and debarment. CAUSE The Campus has not implemented controls to perform the collection of quotes and suspension and debarment checks for vendors. In addition, documentation was not always maintained. EFFECT The Campus was not in compliance with the Board adopted policies. Additionally, the Campus was not compliant with 2 CFR §180.220 and as a result could have entered into a contract with a suspended or debarred party. CONTEXT For two of two purchases reviewed within the Campus’s quote range, quotes were not maintained. In addition, the Campus did not check to see if vendors were suspended or debarred. However, it was determined that vendors were not suspended or debarred. Samples were not intended to be, and were not, statistically valid samples.
CRITERIA Campus management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure that all financial activities are properly processed and reported. Additionally, the Campus is required, except where otherwise authorized by statute, to ensure costs meet the general criteria outlined in 2 CFR 200.403 in order to be allowable under federal awards, including the costs be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. The Single Audit Reporting Package must have a report date nine months after fiscal year-end. CONDITION The Campus did not follow its Board adopted policies for federal regulations regarding disbursements to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. The Campus did not provide all of the audit information for fiscal year 2021-22 in a timely manner to allow sufficient time for the audit to be completed by the deadline. CAUSE The Campus has not implemented controls over disbursement transactions. In addition, documentation was not always maintained. EFFECT The Campus was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The following items were noted during our review of disbursement transactions: For four of 40 disbursements reviewed, supporting documentation was not maintained. The Campus did not maintain credit card statements for all credit cards. The Campus did not maintain a complete list of credit card users to ensure possession was monitored. For six of 40 disbursements reviewed, dual signatures were not obtained when issuing the check.
CRITERIA The Campus is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425. Quarterly and semi-annual reports are required to be submitted no later than 30 days after the end of each reporting period. CONDITION Federal Financial Reports SF-425 were not always submitted on a timely basis. CAUSE The Campus’s procedures were not always followed due to turnover at the Campus. EFFECT The Campus was not always in compliance with federal regulations and guidelines for SF-425 submission. CONTEXT The second and fourth quarter Federal Financial Report, SF-425 was not filed within 30 days of the end of the reporting period.
CRITERIA A tribe, tribal organization, or consortia receiving advance payments under the ISDEAA or the Tribally Controlled Schools Act may invest advance payments (some recipients refer to these advanced payments as “deferred revenue”), before such funds are expended for the purposes of the grant, contract, or funding agreement, so long as such funds are (1) invested only in obligations of the United States or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission (SEC) and which only invest in obligations of the United States or Securities that are guaranteed or insured by the United States or (2) deposited only in accounts that are insured by an agency or instrumentality of the United States CONDITION The Campus had investments of federal funds that were deemed unallowable. CAUSE The Campus did not have a process in place to ensure that investment types were allowable. EFFECT The Campus was not in compliance with Indian Self-Determination and the Education Assistance Act CONTEXT The Campus had investments of $540,574 that appear to be unallowable. RECOMMENDATION The Campus should ensure its financial investments are only invested in the obligations of the United States or mutual funds registered with the SEC and which only invest in obligations of the United States
CRITERIA The Board adopted policies that require the collection of quotes for purchases of at least $10,000 but no more than $100,000, and formal bid procedures for purchases over $100,000. In addition, the Uniform Guidance requires employees to verify that the vendor, supplier, contractor, subcontractor, provider, or their respective principals (e.g., owners, top management, etc.) with expenditures in excess of $25,000 are not suspended, debarred or otherwise excluded by the Federal Government. The Campus should consult the Federal Excluded Parties List System (EPLS) before awarding funds and print the documentation to maintain in the contract file. This requirement is specified in 2 CFR §180.220. CONDITION The Campus did not follow its Board adopted policies or federal regulations regarding the collection of quotes and suspension and debarment. CAUSE The Campus has not implemented controls to perform the collection of quotes and suspension and debarment checks for vendors. In addition, documentation was not always maintained. EFFECT The Campus was not in compliance with the Board adopted policies. Additionally, the Campus was not compliant with 2 CFR §180.220 and as a result could have entered into a contract with a suspended or debarred party. CONTEXT For two of two purchases reviewed within the Campus’s quote range, quotes were not maintained. In addition, the Campus did not check to see if vendors were suspended or debarred. However, it was determined that vendors were not suspended or debarred. Samples were not intended to be, and were not, statistically valid samples.
CRITERIA Campus management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure that all financial activities are properly processed and reported. Additionally, the Campus is required, except where otherwise authorized by statute, to ensure costs meet the general criteria outlined in 2 CFR 200.403 in order to be allowable under federal awards, including the costs be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. The Single Audit Reporting Package must have a report date nine months after fiscal year-end. CONDITION The Campus did not follow its Board adopted policies for federal regulations regarding disbursements to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. The Campus did not provide all of the audit information for fiscal year 2021-22 in a timely manner to allow sufficient time for the audit to be completed by the deadline. CAUSE The Campus has not implemented controls over disbursement transactions. In addition, documentation was not always maintained. EFFECT The Campus was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The following items were noted during our review of disbursement transactions: For four of 40 disbursements reviewed, supporting documentation was not maintained. The Campus did not maintain credit card statements for all credit cards. The Campus did not maintain a complete list of credit card users to ensure possession was monitored. For six of 40 disbursements reviewed, dual signatures were not obtained when issuing the check.
CRITERIA The Campus is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425. Quarterly and semi-annual reports are required to be submitted no later than 30 days after the end of each reporting period. CONDITION Federal Financial Reports SF-425 were not always submitted on a timely basis. CAUSE The Campus’s procedures were not always followed due to turnover at the Campus. EFFECT The Campus was not always in compliance with federal regulations and guidelines for SF-425 submission. CONTEXT The second and fourth quarter Federal Financial Report, SF-425 was not filed within 30 days of the end of the reporting period.
CRITERIA A tribe, tribal organization, or consortia receiving advance payments under the ISDEAA or the Tribally Controlled Schools Act may invest advance payments (some recipients refer to these advanced payments as “deferred revenue”), before such funds are expended for the purposes of the grant, contract, or funding agreement, so long as such funds are (1) invested only in obligations of the United States or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission (SEC) and which only invest in obligations of the United States or Securities that are guaranteed or insured by the United States or (2) deposited only in accounts that are insured by an agency or instrumentality of the United States CONDITION The Campus had investments of federal funds that were deemed unallowable. CAUSE The Campus did not have a process in place to ensure that investment types were allowable. EFFECT The Campus was not in compliance with Indian Self-Determination and the Education Assistance Act CONTEXT The Campus had investments of $540,574 that appear to be unallowable. RECOMMENDATION The Campus should ensure its financial investments are only invested in the obligations of the United States or mutual funds registered with the SEC and which only invest in obligations of the United States
CRITERIA The Board adopted policies that require the collection of quotes for purchases of at least $10,000 but no more than $100,000, and formal bid procedures for purchases over $100,000. In addition, the Uniform Guidance requires employees to verify that the vendor, supplier, contractor, subcontractor, provider, or their respective principals (e.g., owners, top management, etc.) with expenditures in excess of $25,000 are not suspended, debarred or otherwise excluded by the Federal Government. The Campus should consult the Federal Excluded Parties List System (EPLS) before awarding funds and print the documentation to maintain in the contract file. This requirement is specified in 2 CFR §180.220. CONDITION The Campus did not follow its Board adopted policies or federal regulations regarding the collection of quotes and suspension and debarment. CAUSE The Campus has not implemented controls to perform the collection of quotes and suspension and debarment checks for vendors. In addition, documentation was not always maintained. EFFECT The Campus was not in compliance with the Board adopted policies. Additionally, the Campus was not compliant with 2 CFR §180.220 and as a result could have entered into a contract with a suspended or debarred party. CONTEXT For two of two purchases reviewed within the Campus’s quote range, quotes were not maintained. In addition, the Campus did not check to see if vendors were suspended or debarred. However, it was determined that vendors were not suspended or debarred. Samples were not intended to be, and were not, statistically valid samples.
CRITERIA Campus management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure that all financial activities are properly processed and reported. Additionally, the Campus is required, except where otherwise authorized by statute, to ensure costs meet the general criteria outlined in 2 CFR 200.403 in order to be allowable under federal awards, including the costs be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. The Single Audit Reporting Package must have a report date nine months after fiscal year-end. CONDITION The Campus did not follow its Board adopted policies for federal regulations regarding disbursements to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. The Campus did not provide all of the audit information for fiscal year 2021-22 in a timely manner to allow sufficient time for the audit to be completed by the deadline. CAUSE The Campus has not implemented controls over disbursement transactions. In addition, documentation was not always maintained. EFFECT The Campus was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The following items were noted during our review of disbursement transactions: For four of 40 disbursements reviewed, supporting documentation was not maintained. The Campus did not maintain credit card statements for all credit cards. The Campus did not maintain a complete list of credit card users to ensure possession was monitored. For six of 40 disbursements reviewed, dual signatures were not obtained when issuing the check.
CRITERIA The Campus is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425. Quarterly and semi-annual reports are required to be submitted no later than 30 days after the end of each reporting period. CONDITION Federal Financial Reports SF-425 were not always submitted on a timely basis. CAUSE The Campus’s procedures were not always followed due to turnover at the Campus. EFFECT The Campus was not always in compliance with federal regulations and guidelines for SF-425 submission. CONTEXT The second and fourth quarter Federal Financial Report, SF-425 was not filed within 30 days of the end of the reporting period.