Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Hall management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure all financial activities are properly processed and reported. Additionally, the Hall 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. Indian tribes and tribal organizations may without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (USC 46). These guidelines require internal controls over expenditures, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines. (25 CFR 39; 25 CFR 900). Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self-determination contract for purposes identified in 25?SC 450j-l(k), to the extent that the expenditure of the funds is supportive of a contracted program?25 USC 450j-l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 45; 25 CFR 900). CONDITION The Hall did not follow its Board adopted policies for federal regulations regarding disbursements and payroll to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. CAUSE The Hall has not always implemented and followed controls over disbursement and payroll transactions. EFFECT The Hall was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The following items were noted during our review of disbursement transactions: ? For one of 10 travel reimbursements reviewed, adequate backup was not retained to support the reimbursement. ? For one of 10 travel reimbursements reviewed, there was an overpayment of $33. ? For two of 45 disbursements reviewed, the goods or services were received prior to the issuance and approval of the purchase order. ? For two of 45 disbursements reviewed and two of 14 disbursements reviewed for cutoff, there was no receiving report received; therefore could not be determined if the goods or services were received prior to payment. ? For five of 14 cutoff selections reviewed, the expenditure was recorded in the fiscal year 2023 but should have been in fiscal year 2022. Audit adjustments were required to properly report the financial statements. ? For five of 45 disbursements reviewed, the goods or services were received after the payment was made. ? For one of 45 disbursements reviewed, the quantity on the receiving report did not match the purchase order. ? For one of 40 employee payrolls reviewed, the employee received backpay, but the Hall was unable to provide supporting documentation for the backpay. ? The Department of Treasury guidelines for using ARPA funds for hazard pay at a limit of $25,000 per employee. The Hall had three employees who exceeded this limit during the 2022 fiscal year. ? The Hall had a current year overexpenditure in the Education Stabilization Fund grant by $48,608. ? For one of 40 employee payrolls reviewed, the employee was overpaid by $160.55. RECOMMENDATION The Hall should adhere to its Board adopted policies and federal regulations and ensure all transactions are supported. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00933 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting CRITERIA The Single Audit Reporting Package must have a report submitted nine months after fiscal yearend (2 CFR 200.512). The Hall is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425. Quarterly and semi-annual interim reports shall be submitted no later than 30 days after the end of each reporting period. CONDITION The Hall 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. The Hall did not follow federal reporting requirements. CAUSE Hall policies were not always followed or controls were not in place to ensure complete and accurate information could be provided timely. EFFECT The Hall was not always in compliance with federal guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The Hall 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 submitted by the deadline. The SF-425 report for reporting period ending September 30, 2021 was not submitted within 30 days of the end of the reporting period. Amounts reported on the SF-425 reports include all income and expense for the Hall rather than just federal receipts and disbursements. In addition, the amounts reported reporting periods ending December 31, 2021, March 31, 2022, and June 30, 2022 were not cumulative. RECOMMENDATION The Hall should design and implement effective internal control procedures to timely close out the trial balance and provide all of the necessary audit evidence to ensure the general ledger, financial statements and related notes are free from material misstatements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-003 Repeat Finding: Yes, 2021-003 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Education Federal Award Number: A19AV00933 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to the Indian Child Protection and Family Violence Protection Act (25 USC ?3201 et. sec.), the Hall must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular contact with, or control over, Indian children. The investigation should be reinvestigated every five years. The Act further states that the Hall may employ individuals in those positions only if the individuals meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63). CONDITION The Hall did not complete character investigations in a timely manner for all of its employees. CAUSE Hall policies were not always followed or controls were not in place to ensure timely character investigations are performed. EFFECT The Hall was not in compliance with the Indian Child Protection and Family Violence Protection Act. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. For two of nine background investigations reviewed, the Hall did not complete the federal background investigations timely after expiration. RECOMMENDATION The Hall should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Hall?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Hall management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure all financial activities are properly processed and reported. Additionally, the Hall 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. Indian tribes and tribal organizations may without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (USC 46). These guidelines require internal controls over expenditures, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines. (25 CFR 39; 25 CFR 900). Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self-determination contract for purposes identified in 25?SC 450j-l(k), to the extent that the expenditure of the funds is supportive of a contracted program?25 USC 450j-l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 45; 25 CFR 900). CONDITION The Hall did not follow its Board adopted policies for federal regulations regarding disbursements and payroll to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. CAUSE The Hall has not always implemented and followed controls over disbursement and payroll transactions. EFFECT The Hall was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The following items were noted during our review of disbursement transactions: ? For one of 10 travel reimbursements reviewed, adequate backup was not retained to support the reimbursement. ? For one of 10 travel reimbursements reviewed, there was an overpayment of $33. ? For two of 45 disbursements reviewed, the goods or services were received prior to the issuance and approval of the purchase order. ? For two of 45 disbursements reviewed and two of 14 disbursements reviewed for cutoff, there was no receiving report received; therefore could not be determined if the goods or services were received prior to payment. ? For five of 14 cutoff selections reviewed, the expenditure was recorded in the fiscal year 2023 but should have been in fiscal year 2022. Audit adjustments were required to properly report the financial statements. ? For five of 45 disbursements reviewed, the goods or services were received after the payment was made. ? For one of 45 disbursements reviewed, the quantity on the receiving report did not match the purchase order. ? For one of 40 employee payrolls reviewed, the employee received backpay, but the Hall was unable to provide supporting documentation for the backpay. ? The Department of Treasury guidelines for using ARPA funds for hazard pay at a limit of $25,000 per employee. The Hall had three employees who exceeded this limit during the 2022 fiscal year. ? The Hall had a current year overexpenditure in the Education Stabilization Fund grant by $48,608. ? For one of 40 employee payrolls reviewed, the employee was overpaid by $160.55. RECOMMENDATION The Hall should adhere to its Board adopted policies and federal regulations and ensure all transactions are supported. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00933 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting CRITERIA The Single Audit Reporting Package must have a report submitted nine months after fiscal yearend (2 CFR 200.512). The Hall is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425. Quarterly and semi-annual interim reports shall be submitted no later than 30 days after the end of each reporting period. CONDITION The Hall 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. The Hall did not follow federal reporting requirements. CAUSE Hall policies were not always followed or controls were not in place to ensure complete and accurate information could be provided timely. EFFECT The Hall was not always in compliance with federal guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The Hall 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 submitted by the deadline. The SF-425 report for reporting period ending September 30, 2021 was not submitted within 30 days of the end of the reporting period. Amounts reported on the SF-425 reports include all income and expense for the Hall rather than just federal receipts and disbursements. In addition, the amounts reported reporting periods ending December 31, 2021, March 31, 2022, and June 30, 2022 were not cumulative. RECOMMENDATION The Hall should design and implement effective internal control procedures to timely close out the trial balance and provide all of the necessary audit evidence to ensure the general ledger, financial statements and related notes are free from material misstatements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-003 Repeat Finding: Yes, 2021-003 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Education Federal Award Number: A19AV00933 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to the Indian Child Protection and Family Violence Protection Act (25 USC ?3201 et. sec.), the Hall must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular contact with, or control over, Indian children. The investigation should be reinvestigated every five years. The Act further states that the Hall may employ individuals in those positions only if the individuals meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63). CONDITION The Hall did not complete character investigations in a timely manner for all of its employees. CAUSE Hall policies were not always followed or controls were not in place to ensure timely character investigations are performed. EFFECT The Hall was not in compliance with the Indian Child Protection and Family Violence Protection Act. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. For two of nine background investigations reviewed, the Hall did not complete the federal background investigations timely after expiration. RECOMMENDATION The Hall should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Hall?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Hall management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure all financial activities are properly processed and reported. Additionally, the Hall 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. Indian tribes and tribal organizations may without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (USC 46). These guidelines require internal controls over expenditures, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines. (25 CFR 39; 25 CFR 900). Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self-determination contract for purposes identified in 25?SC 450j-l(k), to the extent that the expenditure of the funds is supportive of a contracted program?25 USC 450j-l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 45; 25 CFR 900). CONDITION The Hall did not follow its Board adopted policies for federal regulations regarding disbursements and payroll to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. CAUSE The Hall has not always implemented and followed controls over disbursement and payroll transactions. EFFECT The Hall was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The following items were noted during our review of disbursement transactions: ? For one of 10 travel reimbursements reviewed, adequate backup was not retained to support the reimbursement. ? For one of 10 travel reimbursements reviewed, there was an overpayment of $33. ? For two of 45 disbursements reviewed, the goods or services were received prior to the issuance and approval of the purchase order. ? For two of 45 disbursements reviewed and two of 14 disbursements reviewed for cutoff, there was no receiving report received; therefore could not be determined if the goods or services were received prior to payment. ? For five of 14 cutoff selections reviewed, the expenditure was recorded in the fiscal year 2023 but should have been in fiscal year 2022. Audit adjustments were required to properly report the financial statements. ? For five of 45 disbursements reviewed, the goods or services were received after the payment was made. ? For one of 45 disbursements reviewed, the quantity on the receiving report did not match the purchase order. ? For one of 40 employee payrolls reviewed, the employee received backpay, but the Hall was unable to provide supporting documentation for the backpay. ? The Department of Treasury guidelines for using ARPA funds for hazard pay at a limit of $25,000 per employee. The Hall had three employees who exceeded this limit during the 2022 fiscal year. ? The Hall had a current year overexpenditure in the Education Stabilization Fund grant by $48,608. ? For one of 40 employee payrolls reviewed, the employee was overpaid by $160.55. RECOMMENDATION The Hall should adhere to its Board adopted policies and federal regulations and ensure all transactions are supported. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00933 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting CRITERIA The Single Audit Reporting Package must have a report submitted nine months after fiscal yearend (2 CFR 200.512). The Hall is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425. Quarterly and semi-annual interim reports shall be submitted no later than 30 days after the end of each reporting period. CONDITION The Hall 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. The Hall did not follow federal reporting requirements. CAUSE Hall policies were not always followed or controls were not in place to ensure complete and accurate information could be provided timely. EFFECT The Hall was not always in compliance with federal guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The Hall 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 submitted by the deadline. The SF-425 report for reporting period ending September 30, 2021 was not submitted within 30 days of the end of the reporting period. Amounts reported on the SF-425 reports include all income and expense for the Hall rather than just federal receipts and disbursements. In addition, the amounts reported reporting periods ending December 31, 2021, March 31, 2022, and June 30, 2022 were not cumulative. RECOMMENDATION The Hall should design and implement effective internal control procedures to timely close out the trial balance and provide all of the necessary audit evidence to ensure the general ledger, financial statements and related notes are free from material misstatements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-003 Repeat Finding: Yes, 2021-003 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Education Federal Award Number: A19AV00933 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to the Indian Child Protection and Family Violence Protection Act (25 USC ?3201 et. sec.), the Hall must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular contact with, or control over, Indian children. The investigation should be reinvestigated every five years. The Act further states that the Hall may employ individuals in those positions only if the individuals meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63). CONDITION The Hall did not complete character investigations in a timely manner for all of its employees. CAUSE Hall policies were not always followed or controls were not in place to ensure timely character investigations are performed. EFFECT The Hall was not in compliance with the Indian Child Protection and Family Violence Protection Act. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. For two of nine background investigations reviewed, the Hall did not complete the federal background investigations timely after expiration. RECOMMENDATION The Hall should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Hall?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Hall management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure all financial activities are properly processed and reported. Additionally, the Hall 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. Indian tribes and tribal organizations may without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (USC 46). These guidelines require internal controls over expenditures, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines. (25 CFR 39; 25 CFR 900). Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self-determination contract for purposes identified in 25?SC 450j-l(k), to the extent that the expenditure of the funds is supportive of a contracted program?25 USC 450j-l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 45; 25 CFR 900). CONDITION The Hall did not follow its Board adopted policies for federal regulations regarding disbursements and payroll to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. CAUSE The Hall has not always implemented and followed controls over disbursement and payroll transactions. EFFECT The Hall was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The following items were noted during our review of disbursement transactions: ? For one of 10 travel reimbursements reviewed, adequate backup was not retained to support the reimbursement. ? For one of 10 travel reimbursements reviewed, there was an overpayment of $33. ? For two of 45 disbursements reviewed, the goods or services were received prior to the issuance and approval of the purchase order. ? For two of 45 disbursements reviewed and two of 14 disbursements reviewed for cutoff, there was no receiving report received; therefore could not be determined if the goods or services were received prior to payment. ? For five of 14 cutoff selections reviewed, the expenditure was recorded in the fiscal year 2023 but should have been in fiscal year 2022. Audit adjustments were required to properly report the financial statements. ? For five of 45 disbursements reviewed, the goods or services were received after the payment was made. ? For one of 45 disbursements reviewed, the quantity on the receiving report did not match the purchase order. ? For one of 40 employee payrolls reviewed, the employee received backpay, but the Hall was unable to provide supporting documentation for the backpay. ? The Department of Treasury guidelines for using ARPA funds for hazard pay at a limit of $25,000 per employee. The Hall had three employees who exceeded this limit during the 2022 fiscal year. ? The Hall had a current year overexpenditure in the Education Stabilization Fund grant by $48,608. ? For one of 40 employee payrolls reviewed, the employee was overpaid by $160.55. RECOMMENDATION The Hall should adhere to its Board adopted policies and federal regulations and ensure all transactions are supported. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Hall management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure all financial activities are properly processed and reported. Additionally, the Hall 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. Indian tribes and tribal organizations may without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (USC 46). These guidelines require internal controls over expenditures, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines. (25 CFR 39; 25 CFR 900). Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self-determination contract for purposes identified in 25?SC 450j-l(k), to the extent that the expenditure of the funds is supportive of a contracted program?25 USC 450j-l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 45; 25 CFR 900). CONDITION The Hall did not follow its Board adopted policies for federal regulations regarding disbursements and payroll to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. CAUSE The Hall has not always implemented and followed controls over disbursement and payroll transactions. EFFECT The Hall was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The following items were noted during our review of disbursement transactions: ? For one of 10 travel reimbursements reviewed, adequate backup was not retained to support the reimbursement. ? For one of 10 travel reimbursements reviewed, there was an overpayment of $33. ? For two of 45 disbursements reviewed, the goods or services were received prior to the issuance and approval of the purchase order. ? For two of 45 disbursements reviewed and two of 14 disbursements reviewed for cutoff, there was no receiving report received; therefore could not be determined if the goods or services were received prior to payment. ? For five of 14 cutoff selections reviewed, the expenditure was recorded in the fiscal year 2023 but should have been in fiscal year 2022. Audit adjustments were required to properly report the financial statements. ? For five of 45 disbursements reviewed, the goods or services were received after the payment was made. ? For one of 45 disbursements reviewed, the quantity on the receiving report did not match the purchase order. ? For one of 40 employee payrolls reviewed, the employee received backpay, but the Hall was unable to provide supporting documentation for the backpay. ? The Department of Treasury guidelines for using ARPA funds for hazard pay at a limit of $25,000 per employee. The Hall had three employees who exceeded this limit during the 2022 fiscal year. ? The Hall had a current year overexpenditure in the Education Stabilization Fund grant by $48,608. ? For one of 40 employee payrolls reviewed, the employee was overpaid by $160.55. RECOMMENDATION The Hall should adhere to its Board adopted policies and federal regulations and ensure all transactions are supported. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00933 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting CRITERIA The Single Audit Reporting Package must have a report submitted nine months after fiscal yearend (2 CFR 200.512). The Hall is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425. Quarterly and semi-annual interim reports shall be submitted no later than 30 days after the end of each reporting period. CONDITION The Hall 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. The Hall did not follow federal reporting requirements. CAUSE Hall policies were not always followed or controls were not in place to ensure complete and accurate information could be provided timely. EFFECT The Hall was not always in compliance with federal guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The Hall 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 submitted by the deadline. The SF-425 report for reporting period ending September 30, 2021 was not submitted within 30 days of the end of the reporting period. Amounts reported on the SF-425 reports include all income and expense for the Hall rather than just federal receipts and disbursements. In addition, the amounts reported reporting periods ending December 31, 2021, March 31, 2022, and June 30, 2022 were not cumulative. RECOMMENDATION The Hall should design and implement effective internal control procedures to timely close out the trial balance and provide all of the necessary audit evidence to ensure the general ledger, financial statements and related notes are free from material misstatements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-003 Repeat Finding: Yes, 2021-003 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Education Federal Award Number: A19AV00933 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to the Indian Child Protection and Family Violence Protection Act (25 USC ?3201 et. sec.), the Hall must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular contact with, or control over, Indian children. The investigation should be reinvestigated every five years. The Act further states that the Hall may employ individuals in those positions only if the individuals meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63). CONDITION The Hall did not complete character investigations in a timely manner for all of its employees. CAUSE Hall policies were not always followed or controls were not in place to ensure timely character investigations are performed. EFFECT The Hall was not in compliance with the Indian Child Protection and Family Violence Protection Act. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. For two of nine background investigations reviewed, the Hall did not complete the federal background investigations timely after expiration. RECOMMENDATION The Hall should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Hall?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Hall management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure all financial activities are properly processed and reported. Additionally, the Hall 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. Indian tribes and tribal organizations may without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (USC 46). These guidelines require internal controls over expenditures, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines. (25 CFR 39; 25 CFR 900). Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self-determination contract for purposes identified in 25?SC 450j-l(k), to the extent that the expenditure of the funds is supportive of a contracted program?25 USC 450j-l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 45; 25 CFR 900). CONDITION The Hall did not follow its Board adopted policies for federal regulations regarding disbursements and payroll to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. CAUSE The Hall has not always implemented and followed controls over disbursement and payroll transactions. EFFECT The Hall was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The following items were noted during our review of disbursement transactions: ? For one of 10 travel reimbursements reviewed, adequate backup was not retained to support the reimbursement. ? For one of 10 travel reimbursements reviewed, there was an overpayment of $33. ? For two of 45 disbursements reviewed, the goods or services were received prior to the issuance and approval of the purchase order. ? For two of 45 disbursements reviewed and two of 14 disbursements reviewed for cutoff, there was no receiving report received; therefore could not be determined if the goods or services were received prior to payment. ? For five of 14 cutoff selections reviewed, the expenditure was recorded in the fiscal year 2023 but should have been in fiscal year 2022. Audit adjustments were required to properly report the financial statements. ? For five of 45 disbursements reviewed, the goods or services were received after the payment was made. ? For one of 45 disbursements reviewed, the quantity on the receiving report did not match the purchase order. ? For one of 40 employee payrolls reviewed, the employee received backpay, but the Hall was unable to provide supporting documentation for the backpay. ? The Department of Treasury guidelines for using ARPA funds for hazard pay at a limit of $25,000 per employee. The Hall had three employees who exceeded this limit during the 2022 fiscal year. ? The Hall had a current year overexpenditure in the Education Stabilization Fund grant by $48,608. ? For one of 40 employee payrolls reviewed, the employee was overpaid by $160.55. RECOMMENDATION The Hall should adhere to its Board adopted policies and federal regulations and ensure all transactions are supported. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00933 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting CRITERIA The Single Audit Reporting Package must have a report submitted nine months after fiscal yearend (2 CFR 200.512). The Hall is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425. Quarterly and semi-annual interim reports shall be submitted no later than 30 days after the end of each reporting period. CONDITION The Hall 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. The Hall did not follow federal reporting requirements. CAUSE Hall policies were not always followed or controls were not in place to ensure complete and accurate information could be provided timely. EFFECT The Hall was not always in compliance with federal guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The Hall 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 submitted by the deadline. The SF-425 report for reporting period ending September 30, 2021 was not submitted within 30 days of the end of the reporting period. Amounts reported on the SF-425 reports include all income and expense for the Hall rather than just federal receipts and disbursements. In addition, the amounts reported reporting periods ending December 31, 2021, March 31, 2022, and June 30, 2022 were not cumulative. RECOMMENDATION The Hall should design and implement effective internal control procedures to timely close out the trial balance and provide all of the necessary audit evidence to ensure the general ledger, financial statements and related notes are free from material misstatements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-003 Repeat Finding: Yes, 2021-003 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Education Federal Award Number: A19AV00933 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to the Indian Child Protection and Family Violence Protection Act (25 USC ?3201 et. sec.), the Hall must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular contact with, or control over, Indian children. The investigation should be reinvestigated every five years. The Act further states that the Hall may employ individuals in those positions only if the individuals meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63). CONDITION The Hall did not complete character investigations in a timely manner for all of its employees. CAUSE Hall policies were not always followed or controls were not in place to ensure timely character investigations are performed. EFFECT The Hall was not in compliance with the Indian Child Protection and Family Violence Protection Act. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. For two of nine background investigations reviewed, the Hall did not complete the federal background investigations timely after expiration. RECOMMENDATION The Hall should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Hall?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Hall management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure all financial activities are properly processed and reported. Additionally, the Hall 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. Indian tribes and tribal organizations may without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (USC 46). These guidelines require internal controls over expenditures, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines. (25 CFR 39; 25 CFR 900). Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self-determination contract for purposes identified in 25?SC 450j-l(k), to the extent that the expenditure of the funds is supportive of a contracted program?25 USC 450j-l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 45; 25 CFR 900). CONDITION The Hall did not follow its Board adopted policies for federal regulations regarding disbursements and payroll to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. CAUSE The Hall has not always implemented and followed controls over disbursement and payroll transactions. EFFECT The Hall was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The following items were noted during our review of disbursement transactions: ? For one of 10 travel reimbursements reviewed, adequate backup was not retained to support the reimbursement. ? For one of 10 travel reimbursements reviewed, there was an overpayment of $33. ? For two of 45 disbursements reviewed, the goods or services were received prior to the issuance and approval of the purchase order. ? For two of 45 disbursements reviewed and two of 14 disbursements reviewed for cutoff, there was no receiving report received; therefore could not be determined if the goods or services were received prior to payment. ? For five of 14 cutoff selections reviewed, the expenditure was recorded in the fiscal year 2023 but should have been in fiscal year 2022. Audit adjustments were required to properly report the financial statements. ? For five of 45 disbursements reviewed, the goods or services were received after the payment was made. ? For one of 45 disbursements reviewed, the quantity on the receiving report did not match the purchase order. ? For one of 40 employee payrolls reviewed, the employee received backpay, but the Hall was unable to provide supporting documentation for the backpay. ? The Department of Treasury guidelines for using ARPA funds for hazard pay at a limit of $25,000 per employee. The Hall had three employees who exceeded this limit during the 2022 fiscal year. ? The Hall had a current year overexpenditure in the Education Stabilization Fund grant by $48,608. ? For one of 40 employee payrolls reviewed, the employee was overpaid by $160.55. RECOMMENDATION The Hall should adhere to its Board adopted policies and federal regulations and ensure all transactions are supported. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00933 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting CRITERIA The Single Audit Reporting Package must have a report submitted nine months after fiscal yearend (2 CFR 200.512). The Hall is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425. Quarterly and semi-annual interim reports shall be submitted no later than 30 days after the end of each reporting period. CONDITION The Hall 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. The Hall did not follow federal reporting requirements. CAUSE Hall policies were not always followed or controls were not in place to ensure complete and accurate information could be provided timely. EFFECT The Hall was not always in compliance with federal guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The Hall 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 submitted by the deadline. The SF-425 report for reporting period ending September 30, 2021 was not submitted within 30 days of the end of the reporting period. Amounts reported on the SF-425 reports include all income and expense for the Hall rather than just federal receipts and disbursements. In addition, the amounts reported reporting periods ending December 31, 2021, March 31, 2022, and June 30, 2022 were not cumulative. RECOMMENDATION The Hall should design and implement effective internal control procedures to timely close out the trial balance and provide all of the necessary audit evidence to ensure the general ledger, financial statements and related notes are free from material misstatements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-003 Repeat Finding: Yes, 2021-003 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Education Federal Award Number: A19AV00933 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to the Indian Child Protection and Family Violence Protection Act (25 USC ?3201 et. sec.), the Hall must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular contact with, or control over, Indian children. The investigation should be reinvestigated every five years. The Act further states that the Hall may employ individuals in those positions only if the individuals meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63). CONDITION The Hall did not complete character investigations in a timely manner for all of its employees. CAUSE Hall policies were not always followed or controls were not in place to ensure timely character investigations are performed. EFFECT The Hall was not in compliance with the Indian Child Protection and Family Violence Protection Act. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. For two of nine background investigations reviewed, the Hall did not complete the federal background investigations timely after expiration. RECOMMENDATION The Hall should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Hall?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Hall management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure all financial activities are properly processed and reported. Additionally, the Hall 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. Indian tribes and tribal organizations may without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (USC 46). These guidelines require internal controls over expenditures, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines. (25 CFR 39; 25 CFR 900). Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self-determination contract for purposes identified in 25?SC 450j-l(k), to the extent that the expenditure of the funds is supportive of a contracted program?25 USC 450j-l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 45; 25 CFR 900). CONDITION The Hall did not follow its Board adopted policies for federal regulations regarding disbursements and payroll to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. CAUSE The Hall has not always implemented and followed controls over disbursement and payroll transactions. EFFECT The Hall was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The following items were noted during our review of disbursement transactions: ? For one of 10 travel reimbursements reviewed, adequate backup was not retained to support the reimbursement. ? For one of 10 travel reimbursements reviewed, there was an overpayment of $33. ? For two of 45 disbursements reviewed, the goods or services were received prior to the issuance and approval of the purchase order. ? For two of 45 disbursements reviewed and two of 14 disbursements reviewed for cutoff, there was no receiving report received; therefore could not be determined if the goods or services were received prior to payment. ? For five of 14 cutoff selections reviewed, the expenditure was recorded in the fiscal year 2023 but should have been in fiscal year 2022. Audit adjustments were required to properly report the financial statements. ? For five of 45 disbursements reviewed, the goods or services were received after the payment was made. ? For one of 45 disbursements reviewed, the quantity on the receiving report did not match the purchase order. ? For one of 40 employee payrolls reviewed, the employee received backpay, but the Hall was unable to provide supporting documentation for the backpay. ? The Department of Treasury guidelines for using ARPA funds for hazard pay at a limit of $25,000 per employee. The Hall had three employees who exceeded this limit during the 2022 fiscal year. ? The Hall had a current year overexpenditure in the Education Stabilization Fund grant by $48,608. ? For one of 40 employee payrolls reviewed, the employee was overpaid by $160.55. RECOMMENDATION The Hall should adhere to its Board adopted policies and federal regulations and ensure all transactions are supported. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.