Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 $2,420
Administrative Cost Grants for Indian Schools 15.046 A22AV00871 $997
Indian Education Facilities, Operations
and Maintenance 15.047 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Material Weakness, Noncompliance
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles
Criteria
School management is responsible for establishing and maintaining internal controls over travel
reimbursements, credit card transactions, and disbursements that are adequate to ensure that all
financial activities are properly processed and recorded. Further, Indian tribes and tribal
organizations, may without the approval of the BIA, expend funds provided under a selfdetermination
contract for purposes identified in 25 USC 5325, to the extent that the expenditure of
the funds is supportive of a contracted program (25 USC 5325). These guidelines require internal
controls over expenditures of federal monies to ensure expenditures comply with federal regulations
and guidelines. (25 CFR 39; 25 CFR 900.)
Condition
Internal controls over accounting of disbursements were not followed.
Cause
Internal controls in place did not always operate effectively, or were not followed.
Effect
Financial activities relating to disbursements were not properly processed and documented.
Context
The sample was not intended to be, and was not, a statistically valid sample.
During our review of disbursements, we noted the following:
The School did not pay credit card statements timely, resulting in finance charges of $4,474.
For four of 51 disbursements reviewed, the purchase order was issued after the purchase of
goods/services.
For four of 51 disbursements reviewed, the disbursement was not coded in accordance with
the School’s chart of accounts.
For one of 51 disbursements reviewed, the goods were not received prior to payment.
For one of five travel reimbursements reviewed, the School did not reimburse the expense
using the correct rate, resulting in an overpayment of $20.
For one of 51 disbursements reviewed, there was no invoice or proof of purchase.
Board members who no longer served on the Board as of January 2023 were paid per diem
and stipends for board meetings through June 2023.
As a result of over expending grant revenues and carryover, $104,872 of Administrative Cost
Grants for Indian School and $44,534 of Indian Education Facilities, Operation and
Maintenance expenditures could not be reported on the Schedule of Expenditures of Federal
Awards.
Recommendation
School policies and procedures should be followed to ensure disbursements are properly processed
and documented.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐002
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 N/A
Indian School Student Transportation 15.044 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirements: Procurement and Suspension and Debarment
Criteria
Non‐federal entities other than states, including those operating federal programs as subrecipients
of states, must follow the procurement standards set out at 2 CFR §§200.318 through 200.326. They
must use their own documented procurement procedures, which reflect applicable State and local
laws and regulations, provided that the procurements conform to applicable federal statutes and the
procurement requirements identified in 2 CFR part 200.
Condition
Documentation for procurement performed for purchases below the Simplified Acquisition threshold
of $250,000 was not maintained.
Cause
School and federal policies to obtain three quotes for purchases between $10,000 and $249,000 were
not followed.
Effect
The School was not in compliance with federal regulations and guidelines or school policy.
Context
The sample was not intended to be, and was not, a statistically valid sample. For all five disbursements
reviewed, the School did not obtain three quotes in accordance School or federal policy.
Recommendation
The School should adhere to its Board adopted policies and federal regulations. The School should
implement stronger controls to ensure procurement guidelines are followed.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐003
Repeat Finding: No
Program Name/Assistance Listing Title: Indian School Equalization
Assistance Listing Number: 15.042
Federal Agency: U.S Department of Interior
Federal Award Number: A22AV00871
Pass‐Through Agency: Bureau of Indian Affairs
Questioned Costs: N/A
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirement: Special Tests Provisions
Criteria
According to the Indian Child Protection and Family Violence Prevention Act (25 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 contact with, or control over, Indian
children. The investigation should be reinvestigated every five years. The Act further states that the
School 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
Timely background investigations were not retained for all employees.
Cause
School policies were not always followed to ensure timely background investigation were performed.
Effect
The School was not in compliance with the Indian Child Protection and Family Violence
Prevention Act.
Context
The sample was not intended to be, and was not, a statistically valid sample. For one of 39 employee
files reviewed, a character investigation was on file, but had not been performed timely. In addition,
for one of 39 employee files reviewed, the School did not maintain a copy of the original FBI
background investigation, and for one of 39 employees, there was no background check on file;
therefore, we were unable to determine if the investigation was performed timely or if the employee
was eligible for employment.
Recommendation
The School should ensure adequate character investigations are performed in a timely manner and
documentation is retained 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
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 $2,420
Administrative Cost Grants for Indian Schools 15.046 A22AV00871 $997
Indian Education Facilities, Operations
and Maintenance 15.047 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Material Weakness, Noncompliance
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles
Criteria
School management is responsible for establishing and maintaining internal controls over travel
reimbursements, credit card transactions, and disbursements that are adequate to ensure that all
financial activities are properly processed and recorded. Further, Indian tribes and tribal
organizations, may without the approval of the BIA, expend funds provided under a selfdetermination
contract for purposes identified in 25 USC 5325, to the extent that the expenditure of
the funds is supportive of a contracted program (25 USC 5325). These guidelines require internal
controls over expenditures of federal monies to ensure expenditures comply with federal regulations
and guidelines. (25 CFR 39; 25 CFR 900.)
Condition
Internal controls over accounting of disbursements were not followed.
Cause
Internal controls in place did not always operate effectively, or were not followed.
Effect
Financial activities relating to disbursements were not properly processed and documented.
Context
The sample was not intended to be, and was not, a statistically valid sample.
During our review of disbursements, we noted the following:
The School did not pay credit card statements timely, resulting in finance charges of $4,474.
For four of 51 disbursements reviewed, the purchase order was issued after the purchase of
goods/services.
For four of 51 disbursements reviewed, the disbursement was not coded in accordance with
the School’s chart of accounts.
For one of 51 disbursements reviewed, the goods were not received prior to payment.
For one of five travel reimbursements reviewed, the School did not reimburse the expense
using the correct rate, resulting in an overpayment of $20.
For one of 51 disbursements reviewed, there was no invoice or proof of purchase.
Board members who no longer served on the Board as of January 2023 were paid per diem
and stipends for board meetings through June 2023.
As a result of over expending grant revenues and carryover, $104,872 of Administrative Cost
Grants for Indian School and $44,534 of Indian Education Facilities, Operation and
Maintenance expenditures could not be reported on the Schedule of Expenditures of Federal
Awards.
Recommendation
School policies and procedures should be followed to ensure disbursements are properly processed
and documented.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐002
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 N/A
Indian School Student Transportation 15.044 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirements: Procurement and Suspension and Debarment
Criteria
Non‐federal entities other than states, including those operating federal programs as subrecipients
of states, must follow the procurement standards set out at 2 CFR §§200.318 through 200.326. They
must use their own documented procurement procedures, which reflect applicable State and local
laws and regulations, provided that the procurements conform to applicable federal statutes and the
procurement requirements identified in 2 CFR part 200.
Condition
Documentation for procurement performed for purchases below the Simplified Acquisition threshold
of $250,000 was not maintained.
Cause
School and federal policies to obtain three quotes for purchases between $10,000 and $249,000 were
not followed.
Effect
The School was not in compliance with federal regulations and guidelines or school policy.
Context
The sample was not intended to be, and was not, a statistically valid sample. For all five disbursements
reviewed, the School did not obtain three quotes in accordance School or federal policy.
Recommendation
The School should adhere to its Board adopted policies and federal regulations. The School should
implement stronger controls to ensure procurement guidelines are followed.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐003
Repeat Finding: No
Program Name/Assistance Listing Title: Indian School Equalization
Assistance Listing Number: 15.042
Federal Agency: U.S Department of Interior
Federal Award Number: A22AV00871
Pass‐Through Agency: Bureau of Indian Affairs
Questioned Costs: N/A
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirement: Special Tests Provisions
Criteria
According to the Indian Child Protection and Family Violence Prevention Act (25 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 contact with, or control over, Indian
children. The investigation should be reinvestigated every five years. The Act further states that the
School 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
Timely background investigations were not retained for all employees.
Cause
School policies were not always followed to ensure timely background investigation were performed.
Effect
The School was not in compliance with the Indian Child Protection and Family Violence
Prevention Act.
Context
The sample was not intended to be, and was not, a statistically valid sample. For one of 39 employee
files reviewed, a character investigation was on file, but had not been performed timely. In addition,
for one of 39 employee files reviewed, the School did not maintain a copy of the original FBI
background investigation, and for one of 39 employees, there was no background check on file;
therefore, we were unable to determine if the investigation was performed timely or if the employee
was eligible for employment.
Recommendation
The School should ensure adequate character investigations are performed in a timely manner and
documentation is retained 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
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐002
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 N/A
Indian School Student Transportation 15.044 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirements: Procurement and Suspension and Debarment
Criteria
Non‐federal entities other than states, including those operating federal programs as subrecipients
of states, must follow the procurement standards set out at 2 CFR §§200.318 through 200.326. They
must use their own documented procurement procedures, which reflect applicable State and local
laws and regulations, provided that the procurements conform to applicable federal statutes and the
procurement requirements identified in 2 CFR part 200.
Condition
Documentation for procurement performed for purchases below the Simplified Acquisition threshold
of $250,000 was not maintained.
Cause
School and federal policies to obtain three quotes for purchases between $10,000 and $249,000 were
not followed.
Effect
The School was not in compliance with federal regulations and guidelines or school policy.
Context
The sample was not intended to be, and was not, a statistically valid sample. For all five disbursements
reviewed, the School did not obtain three quotes in accordance School or federal policy.
Recommendation
The School should adhere to its Board adopted policies and federal regulations. The School should
implement stronger controls to ensure procurement guidelines are followed.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 $2,420
Administrative Cost Grants for Indian Schools 15.046 A22AV00871 $997
Indian Education Facilities, Operations
and Maintenance 15.047 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Material Weakness, Noncompliance
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles
Criteria
School management is responsible for establishing and maintaining internal controls over travel
reimbursements, credit card transactions, and disbursements that are adequate to ensure that all
financial activities are properly processed and recorded. Further, Indian tribes and tribal
organizations, may without the approval of the BIA, expend funds provided under a selfdetermination
contract for purposes identified in 25 USC 5325, to the extent that the expenditure of
the funds is supportive of a contracted program (25 USC 5325). These guidelines require internal
controls over expenditures of federal monies to ensure expenditures comply with federal regulations
and guidelines. (25 CFR 39; 25 CFR 900.)
Condition
Internal controls over accounting of disbursements were not followed.
Cause
Internal controls in place did not always operate effectively, or were not followed.
Effect
Financial activities relating to disbursements were not properly processed and documented.
Context
The sample was not intended to be, and was not, a statistically valid sample.
During our review of disbursements, we noted the following:
The School did not pay credit card statements timely, resulting in finance charges of $4,474.
For four of 51 disbursements reviewed, the purchase order was issued after the purchase of
goods/services.
For four of 51 disbursements reviewed, the disbursement was not coded in accordance with
the School’s chart of accounts.
For one of 51 disbursements reviewed, the goods were not received prior to payment.
For one of five travel reimbursements reviewed, the School did not reimburse the expense
using the correct rate, resulting in an overpayment of $20.
For one of 51 disbursements reviewed, there was no invoice or proof of purchase.
Board members who no longer served on the Board as of January 2023 were paid per diem
and stipends for board meetings through June 2023.
As a result of over expending grant revenues and carryover, $104,872 of Administrative Cost
Grants for Indian School and $44,534 of Indian Education Facilities, Operation and
Maintenance expenditures could not be reported on the Schedule of Expenditures of Federal
Awards.
Recommendation
School policies and procedures should be followed to ensure disbursements are properly processed
and documented.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 $2,420
Administrative Cost Grants for Indian Schools 15.046 A22AV00871 $997
Indian Education Facilities, Operations
and Maintenance 15.047 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Material Weakness, Noncompliance
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles
Criteria
School management is responsible for establishing and maintaining internal controls over travel
reimbursements, credit card transactions, and disbursements that are adequate to ensure that all
financial activities are properly processed and recorded. Further, Indian tribes and tribal
organizations, may without the approval of the BIA, expend funds provided under a selfdetermination
contract for purposes identified in 25 USC 5325, to the extent that the expenditure of
the funds is supportive of a contracted program (25 USC 5325). These guidelines require internal
controls over expenditures of federal monies to ensure expenditures comply with federal regulations
and guidelines. (25 CFR 39; 25 CFR 900.)
Condition
Internal controls over accounting of disbursements were not followed.
Cause
Internal controls in place did not always operate effectively, or were not followed.
Effect
Financial activities relating to disbursements were not properly processed and documented.
Context
The sample was not intended to be, and was not, a statistically valid sample.
During our review of disbursements, we noted the following:
The School did not pay credit card statements timely, resulting in finance charges of $4,474.
For four of 51 disbursements reviewed, the purchase order was issued after the purchase of
goods/services.
For four of 51 disbursements reviewed, the disbursement was not coded in accordance with
the School’s chart of accounts.
For one of 51 disbursements reviewed, the goods were not received prior to payment.
For one of five travel reimbursements reviewed, the School did not reimburse the expense
using the correct rate, resulting in an overpayment of $20.
For one of 51 disbursements reviewed, there was no invoice or proof of purchase.
Board members who no longer served on the Board as of January 2023 were paid per diem
and stipends for board meetings through June 2023.
As a result of over expending grant revenues and carryover, $104,872 of Administrative Cost
Grants for Indian School and $44,534 of Indian Education Facilities, Operation and
Maintenance expenditures could not be reported on the Schedule of Expenditures of Federal
Awards.
Recommendation
School policies and procedures should be followed to ensure disbursements are properly processed
and documented.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 $2,420
Administrative Cost Grants for Indian Schools 15.046 A22AV00871 $997
Indian Education Facilities, Operations
and Maintenance 15.047 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Material Weakness, Noncompliance
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles
Criteria
School management is responsible for establishing and maintaining internal controls over travel
reimbursements, credit card transactions, and disbursements that are adequate to ensure that all
financial activities are properly processed and recorded. Further, Indian tribes and tribal
organizations, may without the approval of the BIA, expend funds provided under a selfdetermination
contract for purposes identified in 25 USC 5325, to the extent that the expenditure of
the funds is supportive of a contracted program (25 USC 5325). These guidelines require internal
controls over expenditures of federal monies to ensure expenditures comply with federal regulations
and guidelines. (25 CFR 39; 25 CFR 900.)
Condition
Internal controls over accounting of disbursements were not followed.
Cause
Internal controls in place did not always operate effectively, or were not followed.
Effect
Financial activities relating to disbursements were not properly processed and documented.
Context
The sample was not intended to be, and was not, a statistically valid sample.
During our review of disbursements, we noted the following:
The School did not pay credit card statements timely, resulting in finance charges of $4,474.
For four of 51 disbursements reviewed, the purchase order was issued after the purchase of
goods/services.
For four of 51 disbursements reviewed, the disbursement was not coded in accordance with
the School’s chart of accounts.
For one of 51 disbursements reviewed, the goods were not received prior to payment.
For one of five travel reimbursements reviewed, the School did not reimburse the expense
using the correct rate, resulting in an overpayment of $20.
For one of 51 disbursements reviewed, there was no invoice or proof of purchase.
Board members who no longer served on the Board as of January 2023 were paid per diem
and stipends for board meetings through June 2023.
As a result of over expending grant revenues and carryover, $104,872 of Administrative Cost
Grants for Indian School and $44,534 of Indian Education Facilities, Operation and
Maintenance expenditures could not be reported on the Schedule of Expenditures of Federal
Awards.
Recommendation
School policies and procedures should be followed to ensure disbursements are properly processed
and documented.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐002
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 N/A
Indian School Student Transportation 15.044 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirements: Procurement and Suspension and Debarment
Criteria
Non‐federal entities other than states, including those operating federal programs as subrecipients
of states, must follow the procurement standards set out at 2 CFR §§200.318 through 200.326. They
must use their own documented procurement procedures, which reflect applicable State and local
laws and regulations, provided that the procurements conform to applicable federal statutes and the
procurement requirements identified in 2 CFR part 200.
Condition
Documentation for procurement performed for purchases below the Simplified Acquisition threshold
of $250,000 was not maintained.
Cause
School and federal policies to obtain three quotes for purchases between $10,000 and $249,000 were
not followed.
Effect
The School was not in compliance with federal regulations and guidelines or school policy.
Context
The sample was not intended to be, and was not, a statistically valid sample. For all five disbursements
reviewed, the School did not obtain three quotes in accordance School or federal policy.
Recommendation
The School should adhere to its Board adopted policies and federal regulations. The School should
implement stronger controls to ensure procurement guidelines are followed.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐003
Repeat Finding: No
Program Name/Assistance Listing Title: Indian School Equalization
Assistance Listing Number: 15.042
Federal Agency: U.S Department of Interior
Federal Award Number: A22AV00871
Pass‐Through Agency: Bureau of Indian Affairs
Questioned Costs: N/A
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirement: Special Tests Provisions
Criteria
According to the Indian Child Protection and Family Violence Prevention Act (25 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 contact with, or control over, Indian
children. The investigation should be reinvestigated every five years. The Act further states that the
School 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
Timely background investigations were not retained for all employees.
Cause
School policies were not always followed to ensure timely background investigation were performed.
Effect
The School was not in compliance with the Indian Child Protection and Family Violence
Prevention Act.
Context
The sample was not intended to be, and was not, a statistically valid sample. For one of 39 employee
files reviewed, a character investigation was on file, but had not been performed timely. In addition,
for one of 39 employee files reviewed, the School did not maintain a copy of the original FBI
background investigation, and for one of 39 employees, there was no background check on file;
therefore, we were unable to determine if the investigation was performed timely or if the employee
was eligible for employment.
Recommendation
The School should ensure adequate character investigations are performed in a timely manner and
documentation is retained 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
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 $2,420
Administrative Cost Grants for Indian Schools 15.046 A22AV00871 $997
Indian Education Facilities, Operations
and Maintenance 15.047 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Material Weakness, Noncompliance
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles
Criteria
School management is responsible for establishing and maintaining internal controls over travel
reimbursements, credit card transactions, and disbursements that are adequate to ensure that all
financial activities are properly processed and recorded. Further, Indian tribes and tribal
organizations, may without the approval of the BIA, expend funds provided under a selfdetermination
contract for purposes identified in 25 USC 5325, to the extent that the expenditure of
the funds is supportive of a contracted program (25 USC 5325). These guidelines require internal
controls over expenditures of federal monies to ensure expenditures comply with federal regulations
and guidelines. (25 CFR 39; 25 CFR 900.)
Condition
Internal controls over accounting of disbursements were not followed.
Cause
Internal controls in place did not always operate effectively, or were not followed.
Effect
Financial activities relating to disbursements were not properly processed and documented.
Context
The sample was not intended to be, and was not, a statistically valid sample.
During our review of disbursements, we noted the following:
The School did not pay credit card statements timely, resulting in finance charges of $4,474.
For four of 51 disbursements reviewed, the purchase order was issued after the purchase of
goods/services.
For four of 51 disbursements reviewed, the disbursement was not coded in accordance with
the School’s chart of accounts.
For one of 51 disbursements reviewed, the goods were not received prior to payment.
For one of five travel reimbursements reviewed, the School did not reimburse the expense
using the correct rate, resulting in an overpayment of $20.
For one of 51 disbursements reviewed, there was no invoice or proof of purchase.
Board members who no longer served on the Board as of January 2023 were paid per diem
and stipends for board meetings through June 2023.
As a result of over expending grant revenues and carryover, $104,872 of Administrative Cost
Grants for Indian School and $44,534 of Indian Education Facilities, Operation and
Maintenance expenditures could not be reported on the Schedule of Expenditures of Federal
Awards.
Recommendation
School policies and procedures should be followed to ensure disbursements are properly processed
and documented.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐002
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 N/A
Indian School Student Transportation 15.044 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirements: Procurement and Suspension and Debarment
Criteria
Non‐federal entities other than states, including those operating federal programs as subrecipients
of states, must follow the procurement standards set out at 2 CFR §§200.318 through 200.326. They
must use their own documented procurement procedures, which reflect applicable State and local
laws and regulations, provided that the procurements conform to applicable federal statutes and the
procurement requirements identified in 2 CFR part 200.
Condition
Documentation for procurement performed for purchases below the Simplified Acquisition threshold
of $250,000 was not maintained.
Cause
School and federal policies to obtain three quotes for purchases between $10,000 and $249,000 were
not followed.
Effect
The School was not in compliance with federal regulations and guidelines or school policy.
Context
The sample was not intended to be, and was not, a statistically valid sample. For all five disbursements
reviewed, the School did not obtain three quotes in accordance School or federal policy.
Recommendation
The School should adhere to its Board adopted policies and federal regulations. The School should
implement stronger controls to ensure procurement guidelines are followed.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐003
Repeat Finding: No
Program Name/Assistance Listing Title: Indian School Equalization
Assistance Listing Number: 15.042
Federal Agency: U.S Department of Interior
Federal Award Number: A22AV00871
Pass‐Through Agency: Bureau of Indian Affairs
Questioned Costs: N/A
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirement: Special Tests Provisions
Criteria
According to the Indian Child Protection and Family Violence Prevention Act (25 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 contact with, or control over, Indian
children. The investigation should be reinvestigated every five years. The Act further states that the
School 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
Timely background investigations were not retained for all employees.
Cause
School policies were not always followed to ensure timely background investigation were performed.
Effect
The School was not in compliance with the Indian Child Protection and Family Violence
Prevention Act.
Context
The sample was not intended to be, and was not, a statistically valid sample. For one of 39 employee
files reviewed, a character investigation was on file, but had not been performed timely. In addition,
for one of 39 employee files reviewed, the School did not maintain a copy of the original FBI
background investigation, and for one of 39 employees, there was no background check on file;
therefore, we were unable to determine if the investigation was performed timely or if the employee
was eligible for employment.
Recommendation
The School should ensure adequate character investigations are performed in a timely manner and
documentation is retained 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
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐002
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 N/A
Indian School Student Transportation 15.044 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirements: Procurement and Suspension and Debarment
Criteria
Non‐federal entities other than states, including those operating federal programs as subrecipients
of states, must follow the procurement standards set out at 2 CFR §§200.318 through 200.326. They
must use their own documented procurement procedures, which reflect applicable State and local
laws and regulations, provided that the procurements conform to applicable federal statutes and the
procurement requirements identified in 2 CFR part 200.
Condition
Documentation for procurement performed for purchases below the Simplified Acquisition threshold
of $250,000 was not maintained.
Cause
School and federal policies to obtain three quotes for purchases between $10,000 and $249,000 were
not followed.
Effect
The School was not in compliance with federal regulations and guidelines or school policy.
Context
The sample was not intended to be, and was not, a statistically valid sample. For all five disbursements
reviewed, the School did not obtain three quotes in accordance School or federal policy.
Recommendation
The School should adhere to its Board adopted policies and federal regulations. The School should
implement stronger controls to ensure procurement guidelines are followed.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 $2,420
Administrative Cost Grants for Indian Schools 15.046 A22AV00871 $997
Indian Education Facilities, Operations
and Maintenance 15.047 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Material Weakness, Noncompliance
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles
Criteria
School management is responsible for establishing and maintaining internal controls over travel
reimbursements, credit card transactions, and disbursements that are adequate to ensure that all
financial activities are properly processed and recorded. Further, Indian tribes and tribal
organizations, may without the approval of the BIA, expend funds provided under a selfdetermination
contract for purposes identified in 25 USC 5325, to the extent that the expenditure of
the funds is supportive of a contracted program (25 USC 5325). These guidelines require internal
controls over expenditures of federal monies to ensure expenditures comply with federal regulations
and guidelines. (25 CFR 39; 25 CFR 900.)
Condition
Internal controls over accounting of disbursements were not followed.
Cause
Internal controls in place did not always operate effectively, or were not followed.
Effect
Financial activities relating to disbursements were not properly processed and documented.
Context
The sample was not intended to be, and was not, a statistically valid sample.
During our review of disbursements, we noted the following:
The School did not pay credit card statements timely, resulting in finance charges of $4,474.
For four of 51 disbursements reviewed, the purchase order was issued after the purchase of
goods/services.
For four of 51 disbursements reviewed, the disbursement was not coded in accordance with
the School’s chart of accounts.
For one of 51 disbursements reviewed, the goods were not received prior to payment.
For one of five travel reimbursements reviewed, the School did not reimburse the expense
using the correct rate, resulting in an overpayment of $20.
For one of 51 disbursements reviewed, there was no invoice or proof of purchase.
Board members who no longer served on the Board as of January 2023 were paid per diem
and stipends for board meetings through June 2023.
As a result of over expending grant revenues and carryover, $104,872 of Administrative Cost
Grants for Indian School and $44,534 of Indian Education Facilities, Operation and
Maintenance expenditures could not be reported on the Schedule of Expenditures of Federal
Awards.
Recommendation
School policies and procedures should be followed to ensure disbursements are properly processed
and documented.
Views of Responsible Officials
See Corrective Action Plan.
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Indian School Equalization 15.042 A22AV00871 $2,420
Administrative Cost Grants for Indian Schools 15.046 A22AV00871 $997
Indian Education Facilities, Operations
and Maintenance 15.047 A22AV00871 N/A
Federal Agency: U.S. Department of the Interior
Pass‐Through Agency: Bureau of Indian Affairs
Type of Finding: Material Weakness, Noncompliance
Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles
Criteria
School management is responsible for establishing and maintaining internal controls over travel
reimbursements, credit card transactions, and disbursements that are adequate to ensure that all
financial activities are properly processed and recorded. Further, Indian tribes and tribal
organizations, may without the approval of the BIA, expend funds provided under a selfdetermination
contract for purposes identified in 25 USC 5325, to the extent that the expenditure of
the funds is supportive of a contracted program (25 USC 5325). These guidelines require internal
controls over expenditures of federal monies to ensure expenditures comply with federal regulations
and guidelines. (25 CFR 39; 25 CFR 900.)
Condition
Internal controls over accounting of disbursements were not followed.
Cause
Internal controls in place did not always operate effectively, or were not followed.
Effect
Financial activities relating to disbursements were not properly processed and documented.
Context
The sample was not intended to be, and was not, a statistically valid sample.
During our review of disbursements, we noted the following:
The School did not pay credit card statements timely, resulting in finance charges of $4,474.
For four of 51 disbursements reviewed, the purchase order was issued after the purchase of
goods/services.
For four of 51 disbursements reviewed, the disbursement was not coded in accordance with
the School’s chart of accounts.
For one of 51 disbursements reviewed, the goods were not received prior to payment.
For one of five travel reimbursements reviewed, the School did not reimburse the expense
using the correct rate, resulting in an overpayment of $20.
For one of 51 disbursements reviewed, there was no invoice or proof of purchase.
Board members who no longer served on the Board as of January 2023 were paid per diem
and stipends for board meetings through June 2023.
As a result of over expending grant revenues and carryover, $104,872 of Administrative Cost
Grants for Indian School and $44,534 of Indian Education Facilities, Operation and
Maintenance expenditures could not be reported on the Schedule of Expenditures of Federal
Awards.
Recommendation
School policies and procedures should be followed to ensure disbursements are properly processed
and documented.
Views of Responsible Officials
See Corrective Action Plan.