Audit 2809

2022-006 Procurement, Suspension, and Debarment (Significant Deficiency) - Repeated & Modified (Prior Year Finding 2021-006) Federal Program Information: Funding Agency Title ALN # Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2021 AI9AV00859 Criteria or Specific Requirement Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended, or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition During the testwork over procurement, we noted that for all three (3) transactions over $25,000 tested, the School was unable to provide documentation showing that the procurement process was followed. In addition, there was no documentation showing that the School had searched the respective vendor on the System for Award Management (sam.gov) to ensure that the vendor was not suspended or debarred. Questioned Costs The calculation of questioned costs was not determinable for these instances of noncompliance. Cause The School did not follow its policies and procedures regarding procurement, suspension, and debarment. Effect Noncompliance with grant requirements. Auditor's Recommendation For procurements over $25,000, the School should implement policies and procedures that ensure suspension and debarment checks are performed annually on required vendors.

2022-007 Internal Controls and Compliance over Reporting (Significant Deficiency) - Repeated & Modified (Prior Year Finding 2021-007) Federal Program Information: Funding Agency Title ALN # Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2021 AI9AV00859 U.S. Department of Education Indian Education Facilities, Operations, and Maintenance Program 15.047 2022 AI9AV00859 Criteria or Specific Requirement The School is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425 (7 CFR § 2500.046). Quarterly reports are required to be submitted no later than 30 days after the end of each reporting period. In accordance with 2 CFR 200.512, the Single Audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s) or nine months after the end of the audit period. Condition The School did not submit their required Federal Financial Reports (SF-425) for the quarters ending on September 30, 2021, December 31, 2021, and June 30, 2022 of the program year. All four quarters of SF-425s were not reconciled to the general ledger. In addition, the audit was not completed by the deadline. Cause The School did not have adequate monitoring over the completion and submission of required reports. School policies were not always followed, or controls were not in place to ensure complete and accurate information could be provided timely. Effect The School was not in compliance with federal regulations and guidelines for SF-425 and single audit submissions. Auditor's Recommendation We recommend that the School's personnel obtain appropriate training from a consultant to be able to prepare the SF-425 reports accurately. Additionally, we recommend that the School establish and implement policies and procedures to create, approve, submit, and retain all required reports in a timely manner.

2022-007 Internal Controls and Compliance over Reporting (Significant Deficiency) - Repeated & Modified (Prior Year Finding 2021-007) Federal Program Information: Funding Agency Title ALN # Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2021 AI9AV00859 U.S. Department of Education Indian Education Facilities, Operations, and Maintenance Program 15.047 2022 AI9AV00859 Criteria or Specific Requirement The School is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425 (7 CFR § 2500.046). Quarterly reports are required to be submitted no later than 30 days after the end of each reporting period. In accordance with 2 CFR 200.512, the Single Audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s) or nine months after the end of the audit period. Condition The School did not submit their required Federal Financial Reports (SF-425) for the quarters ending on September 30, 2021, December 31, 2021, and June 30, 2022 of the program year. All four quarters of SF-425s were not reconciled to the general ledger. In addition, the audit was not completed by the deadline. Cause The School did not have adequate monitoring over the completion and submission of required reports. School policies were not always followed, or controls were not in place to ensure complete and accurate information could be provided timely. Effect The School was not in compliance with federal regulations and guidelines for SF-425 and single audit submissions. Auditor's Recommendation We recommend that the School's personnel obtain appropriate training from a consultant to be able to prepare the SF-425 reports accurately. Additionally, we recommend that the School establish and implement policies and procedures to create, approve, submit, and retain all required reports in a timely manner.

2022-006 Procurement, Suspension, and Debarment (Significant Deficiency) - Repeated & Modified (Prior Year Finding 2021-006) Federal Program Information: Funding Agency Title ALN # Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2021 AI9AV00859 Criteria or Specific Requirement Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR §180.995 and agency adopting regulations, is not suspended, or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity or adding a clause or condition to the covered transaction with that entity (2 CFR §180.300). Condition During the testwork over procurement, we noted that for all three (3) transactions over $25,000 tested, the School was unable to provide documentation showing that the procurement process was followed. In addition, there was no documentation showing that the School had searched the respective vendor on the System for Award Management (sam.gov) to ensure that the vendor was not suspended or debarred. Questioned Costs The calculation of questioned costs was not determinable for these instances of noncompliance. Cause The School did not follow its policies and procedures regarding procurement, suspension, and debarment. Effect Noncompliance with grant requirements. Auditor's Recommendation For procurements over $25,000, the School should implement policies and procedures that ensure suspension and debarment checks are performed annually on required vendors.

2022-007 Internal Controls and Compliance over Reporting (Significant Deficiency) - Repeated & Modified (Prior Year Finding 2021-007) Federal Program Information: Funding Agency Title ALN # Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2021 AI9AV00859 U.S. Department of Education Indian Education Facilities, Operations, and Maintenance Program 15.047 2022 AI9AV00859 Criteria or Specific Requirement The School is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425 (7 CFR § 2500.046). Quarterly reports are required to be submitted no later than 30 days after the end of each reporting period. In accordance with 2 CFR 200.512, the Single Audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s) or nine months after the end of the audit period. Condition The School did not submit their required Federal Financial Reports (SF-425) for the quarters ending on September 30, 2021, December 31, 2021, and June 30, 2022 of the program year. All four quarters of SF-425s were not reconciled to the general ledger. In addition, the audit was not completed by the deadline. Cause The School did not have adequate monitoring over the completion and submission of required reports. School policies were not always followed, or controls were not in place to ensure complete and accurate information could be provided timely. Effect The School was not in compliance with federal regulations and guidelines for SF-425 and single audit submissions. Auditor's Recommendation We recommend that the School's personnel obtain appropriate training from a consultant to be able to prepare the SF-425 reports accurately. Additionally, we recommend that the School establish and implement policies and procedures to create, approve, submit, and retain all required reports in a timely manner.

2022-007 Internal Controls and Compliance over Reporting (Significant Deficiency) - Repeated & Modified (Prior Year Finding 2021-007) Federal Program Information: Funding Agency Title ALN # Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2021 AI9AV00859 U.S. Department of Education Indian Education Facilities, Operations, and Maintenance Program 15.047 2022 AI9AV00859 Criteria or Specific Requirement The School is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425 (7 CFR § 2500.046). Quarterly reports are required to be submitted no later than 30 days after the end of each reporting period. In accordance with 2 CFR 200.512, the Single Audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s) or nine months after the end of the audit period. Condition The School did not submit their required Federal Financial Reports (SF-425) for the quarters ending on September 30, 2021, December 31, 2021, and June 30, 2022 of the program year. All four quarters of SF-425s were not reconciled to the general ledger. In addition, the audit was not completed by the deadline. Cause The School did not have adequate monitoring over the completion and submission of required reports. School policies were not always followed, or controls were not in place to ensure complete and accurate information could be provided timely. Effect The School was not in compliance with federal regulations and guidelines for SF-425 and single audit submissions. Auditor's Recommendation We recommend that the School's personnel obtain appropriate training from a consultant to be able to prepare the SF-425 reports accurately. Additionally, we recommend that the School establish and implement policies and procedures to create, approve, submit, and retain all required reports in a timely manner.