Audit 303981

FY End
2022-06-30
Total Expended
$26.59M
Findings
18
Programs
28
Organization: Little Wound School Board, Inc. (SD)
Year: 2022 Accepted: 2024-04-19

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
393772 2022-001 Significant Deficiency - N
393773 2022-001 Significant Deficiency - N
393774 2022-001 Significant Deficiency - N
393775 2022-001 Significant Deficiency - N
393776 2022-001 Significant Deficiency - N
393777 2022-001 Significant Deficiency - N
393778 2022-001 Significant Deficiency - N
393779 2022-001 Significant Deficiency - N
393780 2022-001 Significant Deficiency - N
970214 2022-001 Significant Deficiency - N
970215 2022-001 Significant Deficiency - N
970216 2022-001 Significant Deficiency - N
970217 2022-001 Significant Deficiency - N
970218 2022-001 Significant Deficiency - N
970219 2022-001 Significant Deficiency - N
970220 2022-001 Significant Deficiency - N
970221 2022-001 Significant Deficiency - N
970222 2022-001 Significant Deficiency - N

Programs

ALN Program Spent Major Findings
15.042 Indian School Equalization Program $7.01M - 0
15.062 Replacement and Repair of Indian Schools $2.77M Yes 1
84.010 Title I Grants to Local Educational Agencies $2.33M Yes 1
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $2.18M - 0
84.425 Education Stabilization Fund $1.67M Yes 1
15.046 Administrative Cost Grants for Indian Schools $1.44M - 0
84.027 Special Education_grants to States $1.33M - 0
15.044 Indian Schools_student Transportation $1.09M Yes 1
15.047 Indian Education Facilities, Operations, and Maintenance $958,738 - 0
84.299 Indian Education -- Special Programs for Indian Children $527,021 - 0
93.665 Emergency Grants to Address Mental and Substance Use Disorders During Covid-19 $490,161 Yes 1
15.043 Indian Child and Family Education $341,317 - 0
84.060 Indian Education_grants to Local Educational Agencies $223,302 - 0
15.149 Focus on Student Achievement Project $206,175 Yes 1
84.336 Teacher Quality Partnership Grants $199,500 - 0
93.587 Promote the Survival and Continuing Vitality of Native American Languages $161,681 - 0
84.287 Twenty-First Century Community Learning Centers $158,660 - 0
10.553 School Breakfast Program $107,915 - 0
15.959 Education Program Management $71,300 - 0
45.164 Promotion of the Humanities_public Programs $68,005 - 0
84.101 Career and Technical Education - Grants to Native Americans and Alaska Natives $28,514 - 0
10.575 Farm to School Grant Program $19,745 - 0
10.582 Fresh Fruit and Vegetable Program $16,021 - 0
10.555 National School Lunch Program $11,972 - 0
10.558 Child and Adult Care Food Program $10,584 - 0
84.358 Rural Education $10,500 - 0
84.371 Striving Readers $9,268 - 0
84.424 Student Support and Academic Enrichment Program $1,296 - 0

Contacts

Name Title Type
M2GVXNYCYZK7 Paula Pourier Auditee
6054556173 Donna Denker Auditor
No contacts on file

Notes to SEFA

Accounting Policies: The accompanying schedule of expenditures of federal awards (the Schedule) includes the federal award activity of Little Wound School Board, Inc. (the School) under programs of the federal government for the year ended June 30, 2022. The information in this Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the School, it is not intended to and does not present the financial position or changes in net position of the School. The schedule of expenditures of federal awards is presented using the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform Guidance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: Y Rate Explanation: The School has elected to use the 10% de minimis indirect cost rate as allowed under the Uniform Guidance for their Department of Education grants and Department of Health and Human Services grants.

Finding Details

Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.
Identification of Major Programs: This finding relates to all major programs. Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.