Audit 350888

Finding Number: 2024-001 Repeat Finding: Yes, 2023-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 N/A Indian Education Facilities, Operations and Maintenance 15.047 A23AV00840 N/A Federal Agency: U.S. Department of the Interior Pass-Through Agency: Bureau of Indian Affairs Type of Finding: Significant Deficiency Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Criteria School management is responsible for establishing and maintaining internal controls over 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 self-determination 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: • For two out five cutoff transactions reviewed, determined the transaction should have been paid in fiscal year 2024. • For one of 40 disbursements reviewed, the expenditure exceeded the authorized PO amount. • For three of 40 disbursements reviewed, the disbursement was not coded in accordance with the School's Chart of Accounts.  For two of 40 disbursements reviewed, the purchase order was issued after the purchase of goods/services.  The School did not pay credit card statements timely, resulting in finance charges of $2,801 and late fees of $75. Recommendation School policies and procedures should be followed to ensure disbursements are properly processed and documented. Views Of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-002 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 N/A Indian Education Facilities, Operation, and Maintenance 15.047 A23AV00840 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: Reporting Criteria The School is required to file the Federal Financial Report, SF-425. Quarterly and semi-annual reports are required to be submitted no later than 30 days after the end of each reporting period. Annual reports are required to be submitted no later than 90 days at the end of each reporting period. The SF-425 should report expenditures for each quarter. Condition Federal reporting deadlines were not met during the year and expenditures are not appropriately reported. Cause The School did not have an adequate system in place to monitor compliance with reporting. Effect The School was not always in compliance with federal regulations and guidelines. Less than full compliance with these reporting requirements could potentially result in a reduction or discontinuation of program awards in the future. Context The sample was not intended to be, and was not, a statistically valid sample. The SF-425 for period ending 12/31/23 was not submitted within 30 days of the end of the reporting period. The SF-425 reports for period ending 3/31/24 and 6/30/24 reported revenues for the period rather than expenditures. Recommendation The School should implement standard procedures for the creation and submission of accurate reports on a timely basis. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024‐003 Repeat Finding: Yes, 2023‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Federal Agency: U.S Department of Interior Federal Award Number: A23AV00840 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 performed 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 nine employee files reviewed, a character investigation was on file, but had not been performed timely based on employee’s start date. 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.

Finding Number: 2024‐004 Repeat Finding: Yes, 2023‐002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 n/a Indian School Student Transportation 15.044 A23AV00840 n/a Federal Agency: U.S. Department of the Interior Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Material Weakness 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 The School had adopted procurement policies mandated under 2 CFR §215.43, but did not perform some of the procedures outlined for purchases. Cause Proper documentation was not obtained or maintained by the School. The School has not implemented controls to perform the collection of quotes, suspension and debarment checks for vendors, and maintaining conflict of interest files. Effect The School was not always in compliance with Board adopted policies and federal regulations and guidelines. 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 maintain suspension and debarment for purchases over $25,000 during the year.  For three of five purchases reviewed in the written quote range, written quotes for purchases over $2,500 were not obtained.  For three sealed proposals reviewed, the District did not maintain documentation.  For one of five purchases reviewed in the written quote range, the expenditure was not reviewed/approved by an authorized person prior to the purchase date. Recommendation The School should follow its adopted procurement procedures to ensure full and open competition among prospective vendors and adherence to federal rules and regulations. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024‐004 Repeat Finding: Yes, 2023‐002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 n/a Indian School Student Transportation 15.044 A23AV00840 n/a Federal Agency: U.S. Department of the Interior Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Material Weakness 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 The School had adopted procurement policies mandated under 2 CFR §215.43, but did not perform some of the procedures outlined for purchases. Cause Proper documentation was not obtained or maintained by the School. The School has not implemented controls to perform the collection of quotes, suspension and debarment checks for vendors, and maintaining conflict of interest files. Effect The School was not always in compliance with Board adopted policies and federal regulations and guidelines. 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 maintain suspension and debarment for purchases over $25,000 during the year.  For three of five purchases reviewed in the written quote range, written quotes for purchases over $2,500 were not obtained.  For three sealed proposals reviewed, the District did not maintain documentation.  For one of five purchases reviewed in the written quote range, the expenditure was not reviewed/approved by an authorized person prior to the purchase date. Recommendation The School should follow its adopted procurement procedures to ensure full and open competition among prospective vendors and adherence to federal rules and regulations. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-001 Repeat Finding: Yes, 2023-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 N/A Indian Education Facilities, Operations and Maintenance 15.047 A23AV00840 N/A Federal Agency: U.S. Department of the Interior Pass-Through Agency: Bureau of Indian Affairs Type of Finding: Significant Deficiency Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Criteria School management is responsible for establishing and maintaining internal controls over 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 self-determination 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: • For two out five cutoff transactions reviewed, determined the transaction should have been paid in fiscal year 2024. • For one of 40 disbursements reviewed, the expenditure exceeded the authorized PO amount. • For three of 40 disbursements reviewed, the disbursement was not coded in accordance with the School's Chart of Accounts.  For two of 40 disbursements reviewed, the purchase order was issued after the purchase of goods/services.  The School did not pay credit card statements timely, resulting in finance charges of $2,801 and late fees of $75. Recommendation School policies and procedures should be followed to ensure disbursements are properly processed and documented. Views Of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-002 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 N/A Indian Education Facilities, Operation, and Maintenance 15.047 A23AV00840 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: Reporting Criteria The School is required to file the Federal Financial Report, SF-425. Quarterly and semi-annual reports are required to be submitted no later than 30 days after the end of each reporting period. Annual reports are required to be submitted no later than 90 days at the end of each reporting period. The SF-425 should report expenditures for each quarter. Condition Federal reporting deadlines were not met during the year and expenditures are not appropriately reported. Cause The School did not have an adequate system in place to monitor compliance with reporting. Effect The School was not always in compliance with federal regulations and guidelines. Less than full compliance with these reporting requirements could potentially result in a reduction or discontinuation of program awards in the future. Context The sample was not intended to be, and was not, a statistically valid sample. The SF-425 for period ending 12/31/23 was not submitted within 30 days of the end of the reporting period. The SF-425 reports for period ending 3/31/24 and 6/30/24 reported revenues for the period rather than expenditures. Recommendation The School should implement standard procedures for the creation and submission of accurate reports on a timely basis. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-001 Repeat Finding: Yes, 2023-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 N/A Indian Education Facilities, Operations and Maintenance 15.047 A23AV00840 N/A Federal Agency: U.S. Department of the Interior Pass-Through Agency: Bureau of Indian Affairs Type of Finding: Significant Deficiency Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Criteria School management is responsible for establishing and maintaining internal controls over 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 self-determination 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: • For two out five cutoff transactions reviewed, determined the transaction should have been paid in fiscal year 2024. • For one of 40 disbursements reviewed, the expenditure exceeded the authorized PO amount. • For three of 40 disbursements reviewed, the disbursement was not coded in accordance with the School's Chart of Accounts.  For two of 40 disbursements reviewed, the purchase order was issued after the purchase of goods/services.  The School did not pay credit card statements timely, resulting in finance charges of $2,801 and late fees of $75. Recommendation School policies and procedures should be followed to ensure disbursements are properly processed and documented. Views Of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-002 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 N/A Indian Education Facilities, Operation, and Maintenance 15.047 A23AV00840 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: Reporting Criteria The School is required to file the Federal Financial Report, SF-425. Quarterly and semi-annual reports are required to be submitted no later than 30 days after the end of each reporting period. Annual reports are required to be submitted no later than 90 days at the end of each reporting period. The SF-425 should report expenditures for each quarter. Condition Federal reporting deadlines were not met during the year and expenditures are not appropriately reported. Cause The School did not have an adequate system in place to monitor compliance with reporting. Effect The School was not always in compliance with federal regulations and guidelines. Less than full compliance with these reporting requirements could potentially result in a reduction or discontinuation of program awards in the future. Context The sample was not intended to be, and was not, a statistically valid sample. The SF-425 for period ending 12/31/23 was not submitted within 30 days of the end of the reporting period. The SF-425 reports for period ending 3/31/24 and 6/30/24 reported revenues for the period rather than expenditures. Recommendation The School should implement standard procedures for the creation and submission of accurate reports on a timely basis. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024‐003 Repeat Finding: Yes, 2023‐003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Federal Agency: U.S Department of Interior Federal Award Number: A23AV00840 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 performed 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 nine employee files reviewed, a character investigation was on file, but had not been performed timely based on employee’s start date. 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.

Finding Number: 2024‐004 Repeat Finding: Yes, 2023‐002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 n/a Indian School Student Transportation 15.044 A23AV00840 n/a Federal Agency: U.S. Department of the Interior Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Material Weakness 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 The School had adopted procurement policies mandated under 2 CFR §215.43, but did not perform some of the procedures outlined for purchases. Cause Proper documentation was not obtained or maintained by the School. The School has not implemented controls to perform the collection of quotes, suspension and debarment checks for vendors, and maintaining conflict of interest files. Effect The School was not always in compliance with Board adopted policies and federal regulations and guidelines. 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 maintain suspension and debarment for purchases over $25,000 during the year.  For three of five purchases reviewed in the written quote range, written quotes for purchases over $2,500 were not obtained.  For three sealed proposals reviewed, the District did not maintain documentation.  For one of five purchases reviewed in the written quote range, the expenditure was not reviewed/approved by an authorized person prior to the purchase date. Recommendation The School should follow its adopted procurement procedures to ensure full and open competition among prospective vendors and adherence to federal rules and regulations. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024‐004 Repeat Finding: Yes, 2023‐002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 n/a Indian School Student Transportation 15.044 A23AV00840 n/a Federal Agency: U.S. Department of the Interior Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Material Weakness 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 The School had adopted procurement policies mandated under 2 CFR §215.43, but did not perform some of the procedures outlined for purchases. Cause Proper documentation was not obtained or maintained by the School. The School has not implemented controls to perform the collection of quotes, suspension and debarment checks for vendors, and maintaining conflict of interest files. Effect The School was not always in compliance with Board adopted policies and federal regulations and guidelines. 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 maintain suspension and debarment for purchases over $25,000 during the year.  For three of five purchases reviewed in the written quote range, written quotes for purchases over $2,500 were not obtained.  For three sealed proposals reviewed, the District did not maintain documentation.  For one of five purchases reviewed in the written quote range, the expenditure was not reviewed/approved by an authorized person prior to the purchase date. Recommendation The School should follow its adopted procurement procedures to ensure full and open competition among prospective vendors and adherence to federal rules and regulations. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-001 Repeat Finding: Yes, 2023-001 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 N/A Indian Education Facilities, Operations and Maintenance 15.047 A23AV00840 N/A Federal Agency: U.S. Department of the Interior Pass-Through Agency: Bureau of Indian Affairs Type of Finding: Significant Deficiency Compliance Requirements: Activities Allowed or Unallowed, Allowable Costs/Cost Principles Criteria School management is responsible for establishing and maintaining internal controls over 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 self-determination 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: • For two out five cutoff transactions reviewed, determined the transaction should have been paid in fiscal year 2024. • For one of 40 disbursements reviewed, the expenditure exceeded the authorized PO amount. • For three of 40 disbursements reviewed, the disbursement was not coded in accordance with the School's Chart of Accounts.  For two of 40 disbursements reviewed, the purchase order was issued after the purchase of goods/services.  The School did not pay credit card statements timely, resulting in finance charges of $2,801 and late fees of $75. Recommendation School policies and procedures should be followed to ensure disbursements are properly processed and documented. Views Of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-002 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00840 N/A Indian Education Facilities, Operation, and Maintenance 15.047 A23AV00840 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: Reporting Criteria The School is required to file the Federal Financial Report, SF-425. Quarterly and semi-annual reports are required to be submitted no later than 30 days after the end of each reporting period. Annual reports are required to be submitted no later than 90 days at the end of each reporting period. The SF-425 should report expenditures for each quarter. Condition Federal reporting deadlines were not met during the year and expenditures are not appropriately reported. Cause The School did not have an adequate system in place to monitor compliance with reporting. Effect The School was not always in compliance with federal regulations and guidelines. Less than full compliance with these reporting requirements could potentially result in a reduction or discontinuation of program awards in the future. Context The sample was not intended to be, and was not, a statistically valid sample. The SF-425 for period ending 12/31/23 was not submitted within 30 days of the end of the reporting period. The SF-425 reports for period ending 3/31/24 and 6/30/24 reported revenues for the period rather than expenditures. Recommendation The School should implement standard procedures for the creation and submission of accurate reports on a timely basis. Views of Responsible Officials See Corrective Action Plan.