2022-002 —Reporting – Material Weakness over Internal Control and
Noncompliance (Repeat of Finding 2021-003, 2020-006 and 2019-006)
Federal program information:
Funding agency: Department of Interior
Title: Indian School Equalization Program (ISEP)
Passed through the Bureau of Indian Education (BIE)
CFDA number: 15.042
Award number: A18AV00671
Award period: July 1, 2019 – June 30, 2022
Criteria: Grant agreements require that an SF 425 report be submitted on a quarterly basis.
Condition: Two out of four SF 425 reports tested were filed late.
Questioned Costs: None
Cause: Due to the limited size of the School, the School did not file these SF 425 reports on time.
Effect: SF 425 reports were filed late.
Auditor’s Recommendation: We recommend a monitoring system be in place to ensure that reports are filed on time.
Management’s Response: Management does not dispute these findings. All SF 425 reports were submitted for the fiscal year 2022. The issue with the untimely submission of two SF 425 reports (a few days late) was due to only having one employee, the Business Manager, operating the entire financial department. Currently, our SF 425 reports are up to date and are being submitted in a timely manner to our Superintendent for review then sent to our BIE Grants Specialist as well as to the BIE email inbox specifically intended for this purpose.
2022-003 — Single Audit Report Submission – Material Weakness in Internal Control Over Compliance and Noncompliance (Repeat of finding 2021-004)
Federal program information:
Funding agency: Department of Interior and Department of Education
Passed through the Bureau of Indian Education (BIE)
Title: Indian School Equalization Program (ISEP)
Education Stabilization Fund (ESF)
CFDA number: 15.042 and 84.425
Award number: All major program award numbers
Award period: All major program periods
Criteria: The Uniform Guidance 2 CFR 200.512(a) requires the audit package and data collection form be submitted 30 days after receipt of the auditor’s report or 9 months after the end of the fiscal year, whichever comes first.
Condition: The School’s fiscal year 2022 single audit reporting package was not submitted within nine months after the end of the audit period.
Questioned Costs: N/A
Cause: The School did not have appropriate internal control policies and procedures in place to ensure accounting records and financial statements were reconciled timely and the audit conducted to meet compliance requirements.
Effect: The single audit reporting package was submitted after the required reporting time period.
Auditor’s Recommendations: To ensure compliance with the Uniform Guidance, the School should prepare accurate, complete, and timely financial statements and ensure an audit is performed to ensure the timely submission of the single audit reporting package.
Management’s Response: Management does not dispute these findings, however the reason for this goes well beyond the cause noted by the auditors. In March of 2019, it was discovered that the business manager (now former business manager) had not initiated single audits for FY 2016, 2017, 2018, or 2019. The Board terminated that employee. Current administration and management have been feverishly trying to not only catch up on multiple years’ worth of outstanding audits, but to also rectify myriad problems with existing policy, procedures, record keeping, and accounting mechanisms in cooperation with the Indian Board of Education. The School was without a business manager at all for several months, had one individual who resigned after only a year, and are currently utilizing the expertise of consultants to maintain operations. Nearly everything that is business office-related has been completely overhauled at the School since 2019, as we continue to attempt to become current with outstanding single audits. The School is determined to find solid ground and to meet compliance requirements.
2022-004 — Procurement – Material Weakness in Internal Control Over Compliance and Noncompliance
Federal program information:
Funding agency: Department of Interior and Department of Education
Passed through the Bureau of Indian Education (BIE)
Title: Indian School Equalization Program (ISEP)
Education Stabilization Fund (ESF)
CFDA number: 15.042 and 84.425
Award number: All major program award numbers
Award period: All major program periods
Criteria: The Uniform Guidance 2 CFR 200.318-200.326 require verification of suspension and debarment as part of the procurement process.
Condition: The School was unable to provide any evidence of verification of suspension and debarment on one of the vendors.
Questioned Costs: N/A
Cause: The School did not retain evidence of verification of suspension and debarment.
Effect: The School was unable to provide evidence of verification of suspension and debarment.
Auditor’s Recommendations: Evidence of verification of suspension and debarment to be kept.
Management’s Response: Although the PILC verifies the suspension and debarment status of every vendor for potential purchases above $150,000, we had not been routinely printing documentation verifying this process. In the future, the School will be printing off evidence of a dated keyword search to demonstrate that a vendor is not listed on the www.SAM.gov suspension/debarment list for procurement purposes.
2022-003 — Single Audit Report Submission – Material Weakness in Internal Control Over Compliance and Noncompliance (Repeat of finding 2021-004)
Federal program information:
Funding agency: Department of Interior and Department of Education
Passed through the Bureau of Indian Education (BIE)
Title: Indian School Equalization Program (ISEP)
Education Stabilization Fund (ESF)
CFDA number: 15.042 and 84.425
Award number: All major program award numbers
Award period: All major program periods
Criteria: The Uniform Guidance 2 CFR 200.512(a) requires the audit package and data collection form be submitted 30 days after receipt of the auditor’s report or 9 months after the end of the fiscal year, whichever comes first.
Condition: The School’s fiscal year 2022 single audit reporting package was not submitted within nine months after the end of the audit period.
Questioned Costs: N/A
Cause: The School did not have appropriate internal control policies and procedures in place to ensure accounting records and financial statements were reconciled timely and the audit conducted to meet compliance requirements.
Effect: The single audit reporting package was submitted after the required reporting time period.
Auditor’s Recommendations: To ensure compliance with the Uniform Guidance, the School should prepare accurate, complete, and timely financial statements and ensure an audit is performed to ensure the timely submission of the single audit reporting package.
Management’s Response: Management does not dispute these findings, however the reason for this goes well beyond the cause noted by the auditors. In March of 2019, it was discovered that the business manager (now former business manager) had not initiated single audits for FY 2016, 2017, 2018, or 2019. The Board terminated that employee. Current administration and management have been feverishly trying to not only catch up on multiple years’ worth of outstanding audits, but to also rectify myriad problems with existing policy, procedures, record keeping, and accounting mechanisms in cooperation with the Indian Board of Education. The School was without a business manager at all for several months, had one individual who resigned after only a year, and are currently utilizing the expertise of consultants to maintain operations. Nearly everything that is business office-related has been completely overhauled at the School since 2019, as we continue to attempt to become current with outstanding single audits. The School is determined to find solid ground and to meet compliance requirements.
2022-004 — Procurement – Material Weakness in Internal Control Over Compliance and Noncompliance
Federal program information:
Funding agency: Department of Interior and Department of Education
Passed through the Bureau of Indian Education (BIE)
Title: Indian School Equalization Program (ISEP)
Education Stabilization Fund (ESF)
CFDA number: 15.042 and 84.425
Award number: All major program award numbers
Award period: All major program periods
Criteria: The Uniform Guidance 2 CFR 200.318-200.326 require verification of suspension and debarment as part of the procurement process.
Condition: The School was unable to provide any evidence of verification of suspension and debarment on one of the vendors.
Questioned Costs: N/A
Cause: The School did not retain evidence of verification of suspension and debarment.
Effect: The School was unable to provide evidence of verification of suspension and debarment.
Auditor’s Recommendations: Evidence of verification of suspension and debarment to be kept.
Management’s Response: Although the PILC verifies the suspension and debarment status of every vendor for potential purchases above $150,000, we had not been routinely printing documentation verifying this process. In the future, the School will be printing off evidence of a dated keyword search to demonstrate that a vendor is not listed on the www.SAM.gov suspension/debarment list for procurement purposes.
2022-003 — Single Audit Report Submission – Material Weakness in Internal Control Over Compliance and Noncompliance (Repeat of finding 2021-004)
Federal program information:
Funding agency: Department of Interior and Department of Education
Passed through the Bureau of Indian Education (BIE)
Title: Indian School Equalization Program (ISEP)
Education Stabilization Fund (ESF)
CFDA number: 15.042 and 84.425
Award number: All major program award numbers
Award period: All major program periods
Criteria: The Uniform Guidance 2 CFR 200.512(a) requires the audit package and data collection form be submitted 30 days after receipt of the auditor’s report or 9 months after the end of the fiscal year, whichever comes first.
Condition: The School’s fiscal year 2022 single audit reporting package was not submitted within nine months after the end of the audit period.
Questioned Costs: N/A
Cause: The School did not have appropriate internal control policies and procedures in place to ensure accounting records and financial statements were reconciled timely and the audit conducted to meet compliance requirements.
Effect: The single audit reporting package was submitted after the required reporting time period.
Auditor’s Recommendations: To ensure compliance with the Uniform Guidance, the School should prepare accurate, complete, and timely financial statements and ensure an audit is performed to ensure the timely submission of the single audit reporting package.
Management’s Response: Management does not dispute these findings, however the reason for this goes well beyond the cause noted by the auditors. In March of 2019, it was discovered that the business manager (now former business manager) had not initiated single audits for FY 2016, 2017, 2018, or 2019. The Board terminated that employee. Current administration and management have been feverishly trying to not only catch up on multiple years’ worth of outstanding audits, but to also rectify myriad problems with existing policy, procedures, record keeping, and accounting mechanisms in cooperation with the Indian Board of Education. The School was without a business manager at all for several months, had one individual who resigned after only a year, and are currently utilizing the expertise of consultants to maintain operations. Nearly everything that is business office-related has been completely overhauled at the School since 2019, as we continue to attempt to become current with outstanding single audits. The School is determined to find solid ground and to meet compliance requirements.
2022-004 — Procurement – Material Weakness in Internal Control Over Compliance and Noncompliance
Federal program information:
Funding agency: Department of Interior and Department of Education
Passed through the Bureau of Indian Education (BIE)
Title: Indian School Equalization Program (ISEP)
Education Stabilization Fund (ESF)
CFDA number: 15.042 and 84.425
Award number: All major program award numbers
Award period: All major program periods
Criteria: The Uniform Guidance 2 CFR 200.318-200.326 require verification of suspension and debarment as part of the procurement process.
Condition: The School was unable to provide any evidence of verification of suspension and debarment on one of the vendors.
Questioned Costs: N/A
Cause: The School did not retain evidence of verification of suspension and debarment.
Effect: The School was unable to provide evidence of verification of suspension and debarment.
Auditor’s Recommendations: Evidence of verification of suspension and debarment to be kept.
Management’s Response: Although the PILC verifies the suspension and debarment status of every vendor for potential purchases above $150,000, we had not been routinely printing documentation verifying this process. In the future, the School will be printing off evidence of a dated keyword search to demonstrate that a vendor is not listed on the www.SAM.gov suspension/debarment list for procurement purposes.
2022-002 —Reporting – Material Weakness over Internal Control and
Noncompliance (Repeat of Finding 2021-003, 2020-006 and 2019-006)
Federal program information:
Funding agency: Department of Interior
Title: Indian School Equalization Program (ISEP)
Passed through the Bureau of Indian Education (BIE)
CFDA number: 15.042
Award number: A18AV00671
Award period: July 1, 2019 – June 30, 2022
Criteria: Grant agreements require that an SF 425 report be submitted on a quarterly basis.
Condition: Two out of four SF 425 reports tested were filed late.
Questioned Costs: None
Cause: Due to the limited size of the School, the School did not file these SF 425 reports on time.
Effect: SF 425 reports were filed late.
Auditor’s Recommendation: We recommend a monitoring system be in place to ensure that reports are filed on time.
Management’s Response: Management does not dispute these findings. All SF 425 reports were submitted for the fiscal year 2022. The issue with the untimely submission of two SF 425 reports (a few days late) was due to only having one employee, the Business Manager, operating the entire financial department. Currently, our SF 425 reports are up to date and are being submitted in a timely manner to our Superintendent for review then sent to our BIE Grants Specialist as well as to the BIE email inbox specifically intended for this purpose.
2022-003 — Single Audit Report Submission – Material Weakness in Internal Control Over Compliance and Noncompliance (Repeat of finding 2021-004)
Federal program information:
Funding agency: Department of Interior and Department of Education
Passed through the Bureau of Indian Education (BIE)
Title: Indian School Equalization Program (ISEP)
Education Stabilization Fund (ESF)
CFDA number: 15.042 and 84.425
Award number: All major program award numbers
Award period: All major program periods
Criteria: The Uniform Guidance 2 CFR 200.512(a) requires the audit package and data collection form be submitted 30 days after receipt of the auditor’s report or 9 months after the end of the fiscal year, whichever comes first.
Condition: The School’s fiscal year 2022 single audit reporting package was not submitted within nine months after the end of the audit period.
Questioned Costs: N/A
Cause: The School did not have appropriate internal control policies and procedures in place to ensure accounting records and financial statements were reconciled timely and the audit conducted to meet compliance requirements.
Effect: The single audit reporting package was submitted after the required reporting time period.
Auditor’s Recommendations: To ensure compliance with the Uniform Guidance, the School should prepare accurate, complete, and timely financial statements and ensure an audit is performed to ensure the timely submission of the single audit reporting package.
Management’s Response: Management does not dispute these findings, however the reason for this goes well beyond the cause noted by the auditors. In March of 2019, it was discovered that the business manager (now former business manager) had not initiated single audits for FY 2016, 2017, 2018, or 2019. The Board terminated that employee. Current administration and management have been feverishly trying to not only catch up on multiple years’ worth of outstanding audits, but to also rectify myriad problems with existing policy, procedures, record keeping, and accounting mechanisms in cooperation with the Indian Board of Education. The School was without a business manager at all for several months, had one individual who resigned after only a year, and are currently utilizing the expertise of consultants to maintain operations. Nearly everything that is business office-related has been completely overhauled at the School since 2019, as we continue to attempt to become current with outstanding single audits. The School is determined to find solid ground and to meet compliance requirements.
2022-004 — Procurement – Material Weakness in Internal Control Over Compliance and Noncompliance
Federal program information:
Funding agency: Department of Interior and Department of Education
Passed through the Bureau of Indian Education (BIE)
Title: Indian School Equalization Program (ISEP)
Education Stabilization Fund (ESF)
CFDA number: 15.042 and 84.425
Award number: All major program award numbers
Award period: All major program periods
Criteria: The Uniform Guidance 2 CFR 200.318-200.326 require verification of suspension and debarment as part of the procurement process.
Condition: The School was unable to provide any evidence of verification of suspension and debarment on one of the vendors.
Questioned Costs: N/A
Cause: The School did not retain evidence of verification of suspension and debarment.
Effect: The School was unable to provide evidence of verification of suspension and debarment.
Auditor’s Recommendations: Evidence of verification of suspension and debarment to be kept.
Management’s Response: Although the PILC verifies the suspension and debarment status of every vendor for potential purchases above $150,000, we had not been routinely printing documentation verifying this process. In the future, the School will be printing off evidence of a dated keyword search to demonstrate that a vendor is not listed on the www.SAM.gov suspension/debarment list for procurement purposes.
2022-003 — Single Audit Report Submission – Material Weakness in Internal Control Over Compliance and Noncompliance (Repeat of finding 2021-004)
Federal program information:
Funding agency: Department of Interior and Department of Education
Passed through the Bureau of Indian Education (BIE)
Title: Indian School Equalization Program (ISEP)
Education Stabilization Fund (ESF)
CFDA number: 15.042 and 84.425
Award number: All major program award numbers
Award period: All major program periods
Criteria: The Uniform Guidance 2 CFR 200.512(a) requires the audit package and data collection form be submitted 30 days after receipt of the auditor’s report or 9 months after the end of the fiscal year, whichever comes first.
Condition: The School’s fiscal year 2022 single audit reporting package was not submitted within nine months after the end of the audit period.
Questioned Costs: N/A
Cause: The School did not have appropriate internal control policies and procedures in place to ensure accounting records and financial statements were reconciled timely and the audit conducted to meet compliance requirements.
Effect: The single audit reporting package was submitted after the required reporting time period.
Auditor’s Recommendations: To ensure compliance with the Uniform Guidance, the School should prepare accurate, complete, and timely financial statements and ensure an audit is performed to ensure the timely submission of the single audit reporting package.
Management’s Response: Management does not dispute these findings, however the reason for this goes well beyond the cause noted by the auditors. In March of 2019, it was discovered that the business manager (now former business manager) had not initiated single audits for FY 2016, 2017, 2018, or 2019. The Board terminated that employee. Current administration and management have been feverishly trying to not only catch up on multiple years’ worth of outstanding audits, but to also rectify myriad problems with existing policy, procedures, record keeping, and accounting mechanisms in cooperation with the Indian Board of Education. The School was without a business manager at all for several months, had one individual who resigned after only a year, and are currently utilizing the expertise of consultants to maintain operations. Nearly everything that is business office-related has been completely overhauled at the School since 2019, as we continue to attempt to become current with outstanding single audits. The School is determined to find solid ground and to meet compliance requirements.
2022-004 — Procurement – Material Weakness in Internal Control Over Compliance and Noncompliance
Federal program information:
Funding agency: Department of Interior and Department of Education
Passed through the Bureau of Indian Education (BIE)
Title: Indian School Equalization Program (ISEP)
Education Stabilization Fund (ESF)
CFDA number: 15.042 and 84.425
Award number: All major program award numbers
Award period: All major program periods
Criteria: The Uniform Guidance 2 CFR 200.318-200.326 require verification of suspension and debarment as part of the procurement process.
Condition: The School was unable to provide any evidence of verification of suspension and debarment on one of the vendors.
Questioned Costs: N/A
Cause: The School did not retain evidence of verification of suspension and debarment.
Effect: The School was unable to provide evidence of verification of suspension and debarment.
Auditor’s Recommendations: Evidence of verification of suspension and debarment to be kept.
Management’s Response: Although the PILC verifies the suspension and debarment status of every vendor for potential purchases above $150,000, we had not been routinely printing documentation verifying this process. In the future, the School will be printing off evidence of a dated keyword search to demonstrate that a vendor is not listed on the www.SAM.gov suspension/debarment list for procurement purposes.
2022-003 — Single Audit Report Submission – Material Weakness in Internal Control Over Compliance and Noncompliance (Repeat of finding 2021-004)
Federal program information:
Funding agency: Department of Interior and Department of Education
Passed through the Bureau of Indian Education (BIE)
Title: Indian School Equalization Program (ISEP)
Education Stabilization Fund (ESF)
CFDA number: 15.042 and 84.425
Award number: All major program award numbers
Award period: All major program periods
Criteria: The Uniform Guidance 2 CFR 200.512(a) requires the audit package and data collection form be submitted 30 days after receipt of the auditor’s report or 9 months after the end of the fiscal year, whichever comes first.
Condition: The School’s fiscal year 2022 single audit reporting package was not submitted within nine months after the end of the audit period.
Questioned Costs: N/A
Cause: The School did not have appropriate internal control policies and procedures in place to ensure accounting records and financial statements were reconciled timely and the audit conducted to meet compliance requirements.
Effect: The single audit reporting package was submitted after the required reporting time period.
Auditor’s Recommendations: To ensure compliance with the Uniform Guidance, the School should prepare accurate, complete, and timely financial statements and ensure an audit is performed to ensure the timely submission of the single audit reporting package.
Management’s Response: Management does not dispute these findings, however the reason for this goes well beyond the cause noted by the auditors. In March of 2019, it was discovered that the business manager (now former business manager) had not initiated single audits for FY 2016, 2017, 2018, or 2019. The Board terminated that employee. Current administration and management have been feverishly trying to not only catch up on multiple years’ worth of outstanding audits, but to also rectify myriad problems with existing policy, procedures, record keeping, and accounting mechanisms in cooperation with the Indian Board of Education. The School was without a business manager at all for several months, had one individual who resigned after only a year, and are currently utilizing the expertise of consultants to maintain operations. Nearly everything that is business office-related has been completely overhauled at the School since 2019, as we continue to attempt to become current with outstanding single audits. The School is determined to find solid ground and to meet compliance requirements.
2022-004 — Procurement – Material Weakness in Internal Control Over Compliance and Noncompliance
Federal program information:
Funding agency: Department of Interior and Department of Education
Passed through the Bureau of Indian Education (BIE)
Title: Indian School Equalization Program (ISEP)
Education Stabilization Fund (ESF)
CFDA number: 15.042 and 84.425
Award number: All major program award numbers
Award period: All major program periods
Criteria: The Uniform Guidance 2 CFR 200.318-200.326 require verification of suspension and debarment as part of the procurement process.
Condition: The School was unable to provide any evidence of verification of suspension and debarment on one of the vendors.
Questioned Costs: N/A
Cause: The School did not retain evidence of verification of suspension and debarment.
Effect: The School was unable to provide evidence of verification of suspension and debarment.
Auditor’s Recommendations: Evidence of verification of suspension and debarment to be kept.
Management’s Response: Although the PILC verifies the suspension and debarment status of every vendor for potential purchases above $150,000, we had not been routinely printing documentation verifying this process. In the future, the School will be printing off evidence of a dated keyword search to demonstrate that a vendor is not listed on the www.SAM.gov suspension/debarment list for procurement purposes.