Audit 346520

Finding Number: 2024-001 Repeat Finding: Yes (2023-001, 2021-001) Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A23AV00813 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: CRITERIA According to the Indian Child Protection and Family Violence Prevention Act 925 USC §3201 et. sec.), the School must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFS part 63). Condition The School did not complete character reinvestigations timely for all employees. Cause School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. Effect The School was not in compliance with the Indian Child Protection and Family Violence Prevention Act. Context During our review of the School’s character investigations, we noted, for seven of 37 character investigations reviewed, the five year reinvestigation was not completed timely. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should ensure character investigations are performed in a timely manner to achieve full compliance with the School’s policies and the Indian Child Protection and Family Violence Prevention Act. Views Of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-002 Repeat Finding: Yes, 2023-002, 2022-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00813 N/A Administrative Cost Grants for Indian Schools 15.046 A23AV00813 N/A Federal Agency(ies): U.S. Department of Interior Pass-Through Agency(ies): Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement and Suspension and Debarment Criteria Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320. Condition Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. Cause The School’s internal controls over procurement of goods and services were not adequate. Effect The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. Context The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to two vendors with the Indian School Equalization Program and four vendors with the Administrative Cost Grants for Indian Schools. Additionally, for three non-cooperative-purchase vendors paid in excess of the small purchase threshold ($10,000), the School did not prepare and maintain documentation for at least 3 written quotes from qualified sources, one instance from the Indian School Equalization Program and two instances from the Administrative Cost Grants for Indian Schools. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-003 Repeat Finding: Yes, 2023-003 Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Interior Federal Award Number: A23AV00813 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment and Real Property Management Criteria Local governments and Indian tribes shall follow 2 CFR 200 for equipment acquired under federal awards received directly from a federal awarding agency. Institutions of higher education, hospitals, and other non-profit organizations shall follow the provisions of Uniform Guidance. The Uniform Guidance requires that equipment be used in the program for which it was acquired or, when appropriate, other federal programs. Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Condition Documentation was not available to review equipment purchases or inventory listings and procedures. Additionally, the School lacked adequate internal controls over its accounting of capital assets and inventory processes. Cause The School has not been able to devote proper resources and training to ensure capital assets are accurate and up to date. Effect The School’s internal controls over capital assets were not adequate to ensure that a misstatement would be prevented and/or detected. The School was not in compliance with requirements set by the federal government. Context During our review of the School’s capital asset schedules we noted the following: • The capital asset listing does not include identification numbers for individual assets. • Capital asset policies appear outdated and need to be updated; this includes adding policies related to finance purchases and lease recognition thresholds. • Physical inventory procedures are not documented, and it is unable to be determined in inventories are done periodically. • The current year capital asset listing was not reconciled to the previous year’s listing. • All assets obtained during the year over $5,000 were not capitalized. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should design and implement effective internal control procedures to ensure the capital assets schedules are prepared in accordance with GAAP and School policy. The School’s personnel should obtain additional training as needed. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-003 Repeat Finding: Yes, 2023-003 Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Interior Federal Award Number: A23AV00813 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment and Real Property Management Criteria Local governments and Indian tribes shall follow 2 CFR 200 for equipment acquired under federal awards received directly from a federal awarding agency. Institutions of higher education, hospitals, and other non-profit organizations shall follow the provisions of Uniform Guidance. The Uniform Guidance requires that equipment be used in the program for which it was acquired or, when appropriate, other federal programs. Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Condition Documentation was not available to review equipment purchases or inventory listings and procedures. Additionally, the School lacked adequate internal controls over its accounting of capital assets and inventory processes. Cause The School has not been able to devote proper resources and training to ensure capital assets are accurate and up to date. Effect The School’s internal controls over capital assets were not adequate to ensure that a misstatement would be prevented and/or detected. The School was not in compliance with requirements set by the federal government. Context During our review of the School’s capital asset schedules we noted the following: • The capital asset listing does not include identification numbers for individual assets. • Capital asset policies appear outdated and need to be updated; this includes adding policies related to finance purchases and lease recognition thresholds. • Physical inventory procedures are not documented, and it is unable to be determined in inventories are done periodically. • The current year capital asset listing was not reconciled to the previous year’s listing. • All assets obtained during the year over $5,000 were not capitalized. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should design and implement effective internal control procedures to ensure the capital assets schedules are prepared in accordance with GAAP and School policy. The School’s personnel should obtain additional training as needed. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-002 Repeat Finding: Yes, 2023-002, 2022-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00813 N/A Administrative Cost Grants for Indian Schools 15.046 A23AV00813 N/A Federal Agency(ies): U.S. Department of Interior Pass-Through Agency(ies): Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement and Suspension and Debarment Criteria Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320. Condition Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. Cause The School’s internal controls over procurement of goods and services were not adequate. Effect The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. Context The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to two vendors with the Indian School Equalization Program and four vendors with the Administrative Cost Grants for Indian Schools. Additionally, for three non-cooperative-purchase vendors paid in excess of the small purchase threshold ($10,000), the School did not prepare and maintain documentation for at least 3 written quotes from qualified sources, one instance from the Indian School Equalization Program and two instances from the Administrative Cost Grants for Indian Schools. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-001 Repeat Finding: Yes (2023-001, 2021-001) Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A23AV00813 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: CRITERIA According to the Indian Child Protection and Family Violence Prevention Act 925 USC §3201 et. sec.), the School must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFS part 63). Condition The School did not complete character reinvestigations timely for all employees. Cause School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. Effect The School was not in compliance with the Indian Child Protection and Family Violence Prevention Act. Context During our review of the School’s character investigations, we noted, for seven of 37 character investigations reviewed, the five year reinvestigation was not completed timely. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should ensure character investigations are performed in a timely manner to achieve full compliance with the School’s policies and the Indian Child Protection and Family Violence Prevention Act. Views Of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-002 Repeat Finding: Yes, 2023-002, 2022-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00813 N/A Administrative Cost Grants for Indian Schools 15.046 A23AV00813 N/A Federal Agency(ies): U.S. Department of Interior Pass-Through Agency(ies): Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement and Suspension and Debarment Criteria Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320. Condition Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. Cause The School’s internal controls over procurement of goods and services were not adequate. Effect The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. Context The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to two vendors with the Indian School Equalization Program and four vendors with the Administrative Cost Grants for Indian Schools. Additionally, for three non-cooperative-purchase vendors paid in excess of the small purchase threshold ($10,000), the School did not prepare and maintain documentation for at least 3 written quotes from qualified sources, one instance from the Indian School Equalization Program and two instances from the Administrative Cost Grants for Indian Schools. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-003 Repeat Finding: Yes, 2023-003 Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Interior Federal Award Number: A23AV00813 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment and Real Property Management Criteria Local governments and Indian tribes shall follow 2 CFR 200 for equipment acquired under federal awards received directly from a federal awarding agency. Institutions of higher education, hospitals, and other non-profit organizations shall follow the provisions of Uniform Guidance. The Uniform Guidance requires that equipment be used in the program for which it was acquired or, when appropriate, other federal programs. Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Condition Documentation was not available to review equipment purchases or inventory listings and procedures. Additionally, the School lacked adequate internal controls over its accounting of capital assets and inventory processes. Cause The School has not been able to devote proper resources and training to ensure capital assets are accurate and up to date. Effect The School’s internal controls over capital assets were not adequate to ensure that a misstatement would be prevented and/or detected. The School was not in compliance with requirements set by the federal government. Context During our review of the School’s capital asset schedules we noted the following: • The capital asset listing does not include identification numbers for individual assets. • Capital asset policies appear outdated and need to be updated; this includes adding policies related to finance purchases and lease recognition thresholds. • Physical inventory procedures are not documented, and it is unable to be determined in inventories are done periodically. • The current year capital asset listing was not reconciled to the previous year’s listing. • All assets obtained during the year over $5,000 were not capitalized. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should design and implement effective internal control procedures to ensure the capital assets schedules are prepared in accordance with GAAP and School policy. The School’s personnel should obtain additional training as needed. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-003 Repeat Finding: Yes, 2023-003 Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Interior Federal Award Number: A23AV00813 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment and Real Property Management Criteria Local governments and Indian tribes shall follow 2 CFR 200 for equipment acquired under federal awards received directly from a federal awarding agency. Institutions of higher education, hospitals, and other non-profit organizations shall follow the provisions of Uniform Guidance. The Uniform Guidance requires that equipment be used in the program for which it was acquired or, when appropriate, other federal programs. Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Condition Documentation was not available to review equipment purchases or inventory listings and procedures. Additionally, the School lacked adequate internal controls over its accounting of capital assets and inventory processes. Cause The School has not been able to devote proper resources and training to ensure capital assets are accurate and up to date. Effect The School’s internal controls over capital assets were not adequate to ensure that a misstatement would be prevented and/or detected. The School was not in compliance with requirements set by the federal government. Context During our review of the School’s capital asset schedules we noted the following: • The capital asset listing does not include identification numbers for individual assets. • Capital asset policies appear outdated and need to be updated; this includes adding policies related to finance purchases and lease recognition thresholds. • Physical inventory procedures are not documented, and it is unable to be determined in inventories are done periodically. • The current year capital asset listing was not reconciled to the previous year’s listing. • All assets obtained during the year over $5,000 were not capitalized. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should design and implement effective internal control procedures to ensure the capital assets schedules are prepared in accordance with GAAP and School policy. The School’s personnel should obtain additional training as needed. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-002 Repeat Finding: Yes, 2023-002, 2022-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00813 N/A Administrative Cost Grants for Indian Schools 15.046 A23AV00813 N/A Federal Agency(ies): U.S. Department of Interior Pass-Through Agency(ies): Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement and Suspension and Debarment Criteria Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320. Condition Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. Cause The School’s internal controls over procurement of goods and services were not adequate. Effect The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. Context The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to two vendors with the Indian School Equalization Program and four vendors with the Administrative Cost Grants for Indian Schools. Additionally, for three non-cooperative-purchase vendors paid in excess of the small purchase threshold ($10,000), the School did not prepare and maintain documentation for at least 3 written quotes from qualified sources, one instance from the Indian School Equalization Program and two instances from the Administrative Cost Grants for Indian Schools. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. Views of Responsible Officials See Corrective Action Plan.