2022-002 - Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior, U.S. Department of Education Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042, 84.027 Questioned Costs: None Condition: During our testwork over procurement, we noted that no check performed for sam.gov for 8 vendors before making payments. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: ?200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: The School did not establish adequate internal controls and procedures to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: The School is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require the School to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that the School establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: The Schools will implement internal controls and procedures in procurements using Federal grants to include having the vendor provide a certification that it is not suspended or debarred, as well as a valid search using the GSA website as needed. Estimated Completion Date: We will work with the auditors to complete by next audit day of next year. Responsible Party: SASI Administration Team
2022-003 - Special Tests and Provisions Compliance (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042 Questioned Costs: None Condition: During our test work over special test and provisions, we noted a few instances where the character investigation were not completed in a timely manner. Criteria: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Indian tribe or tribal organization may employ individuals in those positions only if the individual 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), as the Indian tribe or tribal organization establishes. Cause: The School policies were not followed or were not in place. Effect: The School is not in compliance with the special tests and provision compliance requirement. Auditor's Recommendation: The School's HR and Business office have made considerable efforts in resolving this finding. We recommend that the School ensures that employees follow the policies and procedures that are in place along with the compliance requirements for the Indian School Equalization Program and ensure that the compliance requirement is being followed. Management Response: The HR department is currently following a Personnel Checklist for Background Checks revised in SY 22-23. The checklist is to ensure new hires who are on boarding complete the required background checks and other required personnel documents. The board approved the date, verification of completing and I-9 form and additional notes. Provide training for administrators and supervisors on the proper hiring and on boarding process following the SASI Personnel Policies & Procedures. Estimated Completion Date: We will work with the auditors and complete by next audit next year. Responsible Party: SASI Administration Team
2022-002 - Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior, U.S. Department of Education Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042, 84.027 Questioned Costs: None Condition: During our testwork over procurement, we noted that no check performed for sam.gov for 8 vendors before making payments. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: ?200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: The School did not establish adequate internal controls and procedures to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: The School is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require the School to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that the School establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: The Schools will implement internal controls and procedures in procurements using Federal grants to include having the vendor provide a certification that it is not suspended or debarred, as well as a valid search using the GSA website as needed. Estimated Completion Date: We will work with the auditors to complete by next audit day of next year. Responsible Party: SASI Administration Team
2022-002 - Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior, U.S. Department of Education Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042, 84.027 Questioned Costs: None Condition: During our testwork over procurement, we noted that no check performed for sam.gov for 8 vendors before making payments. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: ?200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: The School did not establish adequate internal controls and procedures to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: The School is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require the School to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that the School establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: The Schools will implement internal controls and procedures in procurements using Federal grants to include having the vendor provide a certification that it is not suspended or debarred, as well as a valid search using the GSA website as needed. Estimated Completion Date: We will work with the auditors to complete by next audit day of next year. Responsible Party: SASI Administration Team
2022-003 - Special Tests and Provisions Compliance (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042 Questioned Costs: None Condition: During our test work over special test and provisions, we noted a few instances where the character investigation were not completed in a timely manner. Criteria: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Indian tribe or tribal organization may employ individuals in those positions only if the individual 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), as the Indian tribe or tribal organization establishes. Cause: The School policies were not followed or were not in place. Effect: The School is not in compliance with the special tests and provision compliance requirement. Auditor's Recommendation: The School's HR and Business office have made considerable efforts in resolving this finding. We recommend that the School ensures that employees follow the policies and procedures that are in place along with the compliance requirements for the Indian School Equalization Program and ensure that the compliance requirement is being followed. Management Response: The HR department is currently following a Personnel Checklist for Background Checks revised in SY 22-23. The checklist is to ensure new hires who are on boarding complete the required background checks and other required personnel documents. The board approved the date, verification of completing and I-9 form and additional notes. Provide training for administrators and supervisors on the proper hiring and on boarding process following the SASI Personnel Policies & Procedures. Estimated Completion Date: We will work with the auditors and complete by next audit next year. Responsible Party: SASI Administration Team
2022-002 - Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior, U.S. Department of Education Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042, 84.027 Questioned Costs: None Condition: During our testwork over procurement, we noted that no check performed for sam.gov for 8 vendors before making payments. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: ?200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: The School did not establish adequate internal controls and procedures to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: The School is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require the School to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that the School establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: The Schools will implement internal controls and procedures in procurements using Federal grants to include having the vendor provide a certification that it is not suspended or debarred, as well as a valid search using the GSA website as needed. Estimated Completion Date: We will work with the auditors to complete by next audit day of next year. Responsible Party: SASI Administration Team
2022-003 - Special Tests and Provisions Compliance (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042 Questioned Costs: None Condition: During our test work over special test and provisions, we noted a few instances where the character investigation were not completed in a timely manner. Criteria: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Indian tribe or tribal organization may employ individuals in those positions only if the individual 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), as the Indian tribe or tribal organization establishes. Cause: The School policies were not followed or were not in place. Effect: The School is not in compliance with the special tests and provision compliance requirement. Auditor's Recommendation: The School's HR and Business office have made considerable efforts in resolving this finding. We recommend that the School ensures that employees follow the policies and procedures that are in place along with the compliance requirements for the Indian School Equalization Program and ensure that the compliance requirement is being followed. Management Response: The HR department is currently following a Personnel Checklist for Background Checks revised in SY 22-23. The checklist is to ensure new hires who are on boarding complete the required background checks and other required personnel documents. The board approved the date, verification of completing and I-9 form and additional notes. Provide training for administrators and supervisors on the proper hiring and on boarding process following the SASI Personnel Policies & Procedures. Estimated Completion Date: We will work with the auditors and complete by next audit next year. Responsible Party: SASI Administration Team
2022-002 - Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior, U.S. Department of Education Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042, 84.027 Questioned Costs: None Condition: During our testwork over procurement, we noted that no check performed for sam.gov for 8 vendors before making payments. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: ?200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: The School did not establish adequate internal controls and procedures to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: The School is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require the School to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that the School establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: The Schools will implement internal controls and procedures in procurements using Federal grants to include having the vendor provide a certification that it is not suspended or debarred, as well as a valid search using the GSA website as needed. Estimated Completion Date: We will work with the auditors to complete by next audit day of next year. Responsible Party: SASI Administration Team
2022-002 - Procurement, Suspension and Debarment (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior, U.S. Department of Education Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042, 84.027 Questioned Costs: None Condition: During our testwork over procurement, we noted that no check performed for sam.gov for 8 vendors before making payments. Criteria: Uniform Grant Guidance and 2 CFR Part 200 Subpart C and D: ?200.213 Suspension and debarment. Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. These regulations restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities. Cause: The School did not establish adequate internal controls and procedures to ensure and maintain documentation to show that vendors were not suspended, debarred, or otherwise excluded from participating in contracts that are funded through Federal awards. Effect: The School is not in compliance with Federal regulations related to the grant and this could put its funding in jeopardy or require the School to reimburse the program for improper grant distributions. Auditor's Recommendation: We recommend that the School establish a policy and implement procedures to ensure the suspension or debarment status of vendors before entering into contract or transactions funded through Federal grants. Management Response: The Schools will implement internal controls and procedures in procurements using Federal grants to include having the vendor provide a certification that it is not suspended or debarred, as well as a valid search using the GSA website as needed. Estimated Completion Date: We will work with the auditors to complete by next audit day of next year. Responsible Party: SASI Administration Team
2022-003 - Special Tests and Provisions Compliance (Significant Deficiency) Federal program information Funding Agency: U.S. Department of Interior Title: Indian School Equalization Program Federal Assistance Listing Number: 15.042 Questioned Costs: None Condition: During our test work over special test and provisions, we noted a few instances where the character investigation were not completed in a timely manner. Criteria: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Indian tribe or tribal organization may employ individuals in those positions only if the individual 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), as the Indian tribe or tribal organization establishes. Cause: The School policies were not followed or were not in place. Effect: The School is not in compliance with the special tests and provision compliance requirement. Auditor's Recommendation: The School's HR and Business office have made considerable efforts in resolving this finding. We recommend that the School ensures that employees follow the policies and procedures that are in place along with the compliance requirements for the Indian School Equalization Program and ensure that the compliance requirement is being followed. Management Response: The HR department is currently following a Personnel Checklist for Background Checks revised in SY 22-23. The checklist is to ensure new hires who are on boarding complete the required background checks and other required personnel documents. The board approved the date, verification of completing and I-9 form and additional notes. Provide training for administrators and supervisors on the proper hiring and on boarding process following the SASI Personnel Policies & Procedures. Estimated Completion Date: We will work with the auditors and complete by next audit next year. Responsible Party: SASI Administration Team