Audit 297787

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001, 2021‐001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S Department of Interior Federal Award Number: A22AV00793 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 Prevention Act 925 USC §3201 et. sec.), the School must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFS part 63). Condition The School did not complete character reinvestigations timely for all employees. Cause School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. Effect The School was not in compliance with the Indian Child Protection and Family Violence Prevention Act. Context During our review of the School’s character investigations, we noted the following:  For 10 of 30 character investigations reviewed, the five year reinvestigation was not completed timely. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should ensure character investigations are performed in a timely manner to achieve full compliance with the School’s policies and the Indian Child Protection and Family Violence Prevention Act. Views of Responsible Officials See Corrective Action Plan. Page

Finding Number: 2023‐002 Repeat Finding: Yes, 2022‐002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A Federal Agency: U.S. Department of Interior Pass‐Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement and Suspension and Debarment Criteria Non‐federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320. Condition Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. Cause The School’s internal controls over procurement of goods and services were not adequate. Effect The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. Context The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to 3 vendors with the Indian School Equalization Program and 5 vendors with the Administrative Cost Grants for Indian Schools. Additionally, for four vendors paid in excess of the small purchase threshold ($10,000), the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐002 Repeat Finding: Yes, 2022‐002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A Federal Agency: U.S. Department of Interior Pass‐Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement and Suspension and Debarment Criteria Non‐federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320. Condition Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. Cause The School’s internal controls over procurement of goods and services were not adequate. Effect The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. Context The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to 3 vendors with the Indian School Equalization Program and 5 vendors with the Administrative Cost Grants for Indian Schools. Additionally, for four vendors paid in excess of the small purchase threshold ($10,000), the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐003 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Number: A22AV00793 Pass‐Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment and Real Property Management Criteria Local governments and Indian tribes shall follow 2 CFR 200 for equipment acquired under federal awards received directly from a federal awarding agency. Institutions of higher education, hospitals, and other non‐profit organizations shall follow the provisions of Uniform Guidance. The Uniform Guidance requires that equipment be used in the program for which it was acquired or, when appropriate, other federal programs. Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Condition Documentation was not available to review equipment purchases or inventory listings and procedures. Cause The School has not been able to devote proper resources and training to ensure capital assets are accurate and up to date. Effect The School’s internal controls over capital assets were not adequate to ensure that a misstatement would be prevented and/or detected. The School was not in compliance with requirements set by the federal government. Context During our review of the School’s capital asset schedules we noted the following:  The capital asset listing does not include identification numbers for individual assets.  Capital asset policies appear outdated and need to be updated; this includes adding policies related to finance purchases and lease recognition thresholds.  Physical inventory procedures are not documented and it is unable to be determined in inventories are done periodically. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should design and implement effective internal control procedures to ensure the capital assets schedules are prepared in accordance with GAAP and School policy. The School’s personnel should obtain additional training as needed. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐003 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Number: A22AV00793 Pass‐Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment and Real Property Management Criteria Local governments and Indian tribes shall follow 2 CFR 200 for equipment acquired under federal awards received directly from a federal awarding agency. Institutions of higher education, hospitals, and other non‐profit organizations shall follow the provisions of Uniform Guidance. The Uniform Guidance requires that equipment be used in the program for which it was acquired or, when appropriate, other federal programs. Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Condition Documentation was not available to review equipment purchases or inventory listings and procedures. Cause The School has not been able to devote proper resources and training to ensure capital assets are accurate and up to date. Effect The School’s internal controls over capital assets were not adequate to ensure that a misstatement would be prevented and/or detected. The School was not in compliance with requirements set by the federal government. Context During our review of the School’s capital asset schedules we noted the following:  The capital asset listing does not include identification numbers for individual assets.  Capital asset policies appear outdated and need to be updated; this includes adding policies related to finance purchases and lease recognition thresholds.  Physical inventory procedures are not documented and it is unable to be determined in inventories are done periodically. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should design and implement effective internal control procedures to ensure the capital assets schedules are prepared in accordance with GAAP and School policy. The School’s personnel should obtain additional training as needed. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐004 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A COVID‐19 Education Stabilization Fund 84.425 A22AV00793 N/A Federal Agencies: U.S. Department of the Interior, U.S. Department of Education Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Reporting Criteria The School is required to file the Federal Financial Report, SF‐425 to report program outlays and program income as prescribed by the Federal Awarding Agency. Condition Financial reporting obligations were not met during the year. Cause Adequate review systems were not in place for management to monitor compliance with these requirements and ensure accurate amounts were reported. Effect The School was not always in compliance with federal regulations and guidelines. Context The School reported incorrect expenditures for one of four quarterly reports reviewed. The School included both federal and non‐federal expenditures in the reporting. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should implement review procedures to ensure the information reported on the Federal Financial Report, SF‐425, is accurate and appropriate. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐004 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A COVID‐19 Education Stabilization Fund 84.425 A22AV00793 N/A Federal Agencies: U.S. Department of the Interior, U.S. Department of Education Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Reporting Criteria The School is required to file the Federal Financial Report, SF‐425 to report program outlays and program income as prescribed by the Federal Awarding Agency. Condition Financial reporting obligations were not met during the year. Cause Adequate review systems were not in place for management to monitor compliance with these requirements and ensure accurate amounts were reported. Effect The School was not always in compliance with federal regulations and guidelines. Context The School reported incorrect expenditures for one of four quarterly reports reviewed. The School included both federal and non‐federal expenditures in the reporting. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should implement review procedures to ensure the information reported on the Federal Financial Report, SF‐425, is accurate and appropriate. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐004 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A COVID‐19 Education Stabilization Fund 84.425 A22AV00793 N/A Federal Agencies: U.S. Department of the Interior, U.S. Department of Education Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Reporting Criteria The School is required to file the Federal Financial Report, SF‐425 to report program outlays and program income as prescribed by the Federal Awarding Agency. Condition Financial reporting obligations were not met during the year. Cause Adequate review systems were not in place for management to monitor compliance with these requirements and ensure accurate amounts were reported. Effect The School was not always in compliance with federal regulations and guidelines. Context The School reported incorrect expenditures for one of four quarterly reports reviewed. The School included both federal and non‐federal expenditures in the reporting. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should implement review procedures to ensure the information reported on the Federal Financial Report, SF‐425, is accurate and appropriate. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐004 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A COVID‐19 Education Stabilization Fund 84.425 A22AV00793 N/A Federal Agencies: U.S. Department of the Interior, U.S. Department of Education Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Reporting Criteria The School is required to file the Federal Financial Report, SF‐425 to report program outlays and program income as prescribed by the Federal Awarding Agency. Condition Financial reporting obligations were not met during the year. Cause Adequate review systems were not in place for management to monitor compliance with these requirements and ensure accurate amounts were reported. Effect The School was not always in compliance with federal regulations and guidelines. Context The School reported incorrect expenditures for one of four quarterly reports reviewed. The School included both federal and non‐federal expenditures in the reporting. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should implement review procedures to ensure the information reported on the Federal Financial Report, SF‐425, is accurate and appropriate. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001, 2021‐001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S Department of Interior Federal Award Number: A22AV00793 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 Prevention Act 925 USC §3201 et. sec.), the School must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFS part 63). Condition The School did not complete character reinvestigations timely for all employees. Cause School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. Effect The School was not in compliance with the Indian Child Protection and Family Violence Prevention Act. Context During our review of the School’s character investigations, we noted the following:  For 10 of 30 character investigations reviewed, the five year reinvestigation was not completed timely. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should ensure character investigations are performed in a timely manner to achieve full compliance with the School’s policies and the Indian Child Protection and Family Violence Prevention Act. Views of Responsible Officials See Corrective Action Plan. Page

Finding Number: 2023‐002 Repeat Finding: Yes, 2022‐002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A Federal Agency: U.S. Department of Interior Pass‐Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement and Suspension and Debarment Criteria Non‐federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320. Condition Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. Cause The School’s internal controls over procurement of goods and services were not adequate. Effect The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. Context The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to 3 vendors with the Indian School Equalization Program and 5 vendors with the Administrative Cost Grants for Indian Schools. Additionally, for four vendors paid in excess of the small purchase threshold ($10,000), the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐002 Repeat Finding: Yes, 2022‐002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A Federal Agency: U.S. Department of Interior Pass‐Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement and Suspension and Debarment Criteria Non‐federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320. Condition Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. Cause The School’s internal controls over procurement of goods and services were not adequate. Effect The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. Context The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to 3 vendors with the Indian School Equalization Program and 5 vendors with the Administrative Cost Grants for Indian Schools. Additionally, for four vendors paid in excess of the small purchase threshold ($10,000), the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐003 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Number: A22AV00793 Pass‐Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment and Real Property Management Criteria Local governments and Indian tribes shall follow 2 CFR 200 for equipment acquired under federal awards received directly from a federal awarding agency. Institutions of higher education, hospitals, and other non‐profit organizations shall follow the provisions of Uniform Guidance. The Uniform Guidance requires that equipment be used in the program for which it was acquired or, when appropriate, other federal programs. Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Condition Documentation was not available to review equipment purchases or inventory listings and procedures. Cause The School has not been able to devote proper resources and training to ensure capital assets are accurate and up to date. Effect The School’s internal controls over capital assets were not adequate to ensure that a misstatement would be prevented and/or detected. The School was not in compliance with requirements set by the federal government. Context During our review of the School’s capital asset schedules we noted the following:  The capital asset listing does not include identification numbers for individual assets.  Capital asset policies appear outdated and need to be updated; this includes adding policies related to finance purchases and lease recognition thresholds.  Physical inventory procedures are not documented and it is unable to be determined in inventories are done periodically. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should design and implement effective internal control procedures to ensure the capital assets schedules are prepared in accordance with GAAP and School policy. The School’s personnel should obtain additional training as needed. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐003 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Number: A22AV00793 Pass‐Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment and Real Property Management Criteria Local governments and Indian tribes shall follow 2 CFR 200 for equipment acquired under federal awards received directly from a federal awarding agency. Institutions of higher education, hospitals, and other non‐profit organizations shall follow the provisions of Uniform Guidance. The Uniform Guidance requires that equipment be used in the program for which it was acquired or, when appropriate, other federal programs. Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Condition Documentation was not available to review equipment purchases or inventory listings and procedures. Cause The School has not been able to devote proper resources and training to ensure capital assets are accurate and up to date. Effect The School’s internal controls over capital assets were not adequate to ensure that a misstatement would be prevented and/or detected. The School was not in compliance with requirements set by the federal government. Context During our review of the School’s capital asset schedules we noted the following:  The capital asset listing does not include identification numbers for individual assets.  Capital asset policies appear outdated and need to be updated; this includes adding policies related to finance purchases and lease recognition thresholds.  Physical inventory procedures are not documented and it is unable to be determined in inventories are done periodically. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should design and implement effective internal control procedures to ensure the capital assets schedules are prepared in accordance with GAAP and School policy. The School’s personnel should obtain additional training as needed. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐004 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A COVID‐19 Education Stabilization Fund 84.425 A22AV00793 N/A Federal Agencies: U.S. Department of the Interior, U.S. Department of Education Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Reporting Criteria The School is required to file the Federal Financial Report, SF‐425 to report program outlays and program income as prescribed by the Federal Awarding Agency. Condition Financial reporting obligations were not met during the year. Cause Adequate review systems were not in place for management to monitor compliance with these requirements and ensure accurate amounts were reported. Effect The School was not always in compliance with federal regulations and guidelines. Context The School reported incorrect expenditures for one of four quarterly reports reviewed. The School included both federal and non‐federal expenditures in the reporting. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should implement review procedures to ensure the information reported on the Federal Financial Report, SF‐425, is accurate and appropriate. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐004 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A COVID‐19 Education Stabilization Fund 84.425 A22AV00793 N/A Federal Agencies: U.S. Department of the Interior, U.S. Department of Education Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Reporting Criteria The School is required to file the Federal Financial Report, SF‐425 to report program outlays and program income as prescribed by the Federal Awarding Agency. Condition Financial reporting obligations were not met during the year. Cause Adequate review systems were not in place for management to monitor compliance with these requirements and ensure accurate amounts were reported. Effect The School was not always in compliance with federal regulations and guidelines. Context The School reported incorrect expenditures for one of four quarterly reports reviewed. The School included both federal and non‐federal expenditures in the reporting. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should implement review procedures to ensure the information reported on the Federal Financial Report, SF‐425, is accurate and appropriate. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐004 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A COVID‐19 Education Stabilization Fund 84.425 A22AV00793 N/A Federal Agencies: U.S. Department of the Interior, U.S. Department of Education Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Reporting Criteria The School is required to file the Federal Financial Report, SF‐425 to report program outlays and program income as prescribed by the Federal Awarding Agency. Condition Financial reporting obligations were not met during the year. Cause Adequate review systems were not in place for management to monitor compliance with these requirements and ensure accurate amounts were reported. Effect The School was not always in compliance with federal regulations and guidelines. Context The School reported incorrect expenditures for one of four quarterly reports reviewed. The School included both federal and non‐federal expenditures in the reporting. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should implement review procedures to ensure the information reported on the Federal Financial Report, SF‐425, is accurate and appropriate. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐004 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A COVID‐19 Education Stabilization Fund 84.425 A22AV00793 N/A Federal Agencies: U.S. Department of the Interior, U.S. Department of Education Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Reporting Criteria The School is required to file the Federal Financial Report, SF‐425 to report program outlays and program income as prescribed by the Federal Awarding Agency. Condition Financial reporting obligations were not met during the year. Cause Adequate review systems were not in place for management to monitor compliance with these requirements and ensure accurate amounts were reported. Effect The School was not always in compliance with federal regulations and guidelines. Context The School reported incorrect expenditures for one of four quarterly reports reviewed. The School included both federal and non‐federal expenditures in the reporting. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should implement review procedures to ensure the information reported on the Federal Financial Report, SF‐425, is accurate and appropriate. Views of Responsible Officials See Corrective Action Plan.