Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-008: Significant Deficiency – Special Tests and Provisions
Program: Indian School Equalization
Assistance Listing Number: 15.042
Federal Agency: U.S. Department of the Interior
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2023
Criteria: 25 CFR section 63.17 requires that Indian Tribes and tribal organizations perform adjudication to determine suitability for employment and efficiency of service. The adjudication process protects the interests of the employer and the rights of applicants and employees. Adjudication requires uniform evaluation to ensure fair and consistent judgment.
Condition: While documentation exists that a background investigation was completed, no documentation was maintained that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation.
Questioned Costs: None noted.
Context: No documentation was available that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation for 4 of the 40 employees selected for testing. The sample was not considered statistically valid.
Effect: When comparison of background investigations and suitability determinations are not performed, employees may be hired who do not meet laws and regulations to work in a school environment or employees may be hired who are not suitable to perform the positions they were hired for.
Cause: Documentation that the background investigations were compared to the employment application and that a suitability determination was conducted by an appropriate adjudicating official was not maintained.
Recommendation: It is recommended that the Club updates its Employment Suitability Investigations policy to accurately reflect the process for performing background investigations and employment suitability. Within that policy, the Club should ensure that a process is put in place to ensure documentation of the background investigations and employment suitability assessment is maintained in employee files.
Management’s Response: The Club and Cherokee Central Schools (CCS) agree with this finding and CCS notes that its Employment Suitability Investigations policy was updated and formally adopted on July 22, 2019. The audit included a sample of employee files from prior years, before the policy was implemented and before consistent personnel changes were made. Since the policy's adoption, appropriate procedures have been put in place to ensure background investigations and employment suitability assessments are conducted and properly documented. CCS will continue to monitor compliance with the policy and ensure that documentation is consistently maintained in employee personnel files moving forward. Current updates to be enacted immediately include documentation that the Superintendent has reviewed the files.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-006: Significant Deficiency – Allowable Costs/Cost Principles
Program: Indian Schools Student Transportation
Assistance Listing Number: 15.044
Federal Agency: U.S. Department of the Interior
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that a review and approval of all expenditures occurs and that appropriate documentation of that review and approval is maintained.
Condition: Documentation of the review and approval of certain expenditures was unable to be located.
Questioned Costs: None noted.
Context: The documentation of the review and approval of expenditures was not able to be located for two of the six expenditures selected for testing. There were a total of 23 expenditures charged to the program during fiscal year 2023. The sample was not considered statistically valid.
Effect: When expenditures are not properly reviewed and approved, unallowable costs could be charged to federal programs.
Cause: The Club has not implemented an effective system of internal controls over maintaining documentation of the review and approval of program expenditures.
Recommendation: It is recommended that the Club ensures that internal controls are adequately maintained to ensure that the review and approval of program expenditures occurs and that the documentation of that review and approval is appropriately maintained.
Management’s Response: The Club agrees with this finding and has established procedures to ensure that all required signatures are obtained before posting intercompany expenses for transportation. The Assistant Finance Director receives the monthly invoices from the Bus Department and forwards them to the Cherokee Central Schools Finance Director for approval before completing the monthly posting.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-008: Significant Deficiency – Special Tests and Provisions
Program: Indian School Equalization
Assistance Listing Number: 15.042
Federal Agency: U.S. Department of the Interior
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2023
Criteria: 25 CFR section 63.17 requires that Indian Tribes and tribal organizations perform adjudication to determine suitability for employment and efficiency of service. The adjudication process protects the interests of the employer and the rights of applicants and employees. Adjudication requires uniform evaluation to ensure fair and consistent judgment.
Condition: While documentation exists that a background investigation was completed, no documentation was maintained that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation.
Questioned Costs: None noted.
Context: No documentation was available that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation for 4 of the 40 employees selected for testing. The sample was not considered statistically valid.
Effect: When comparison of background investigations and suitability determinations are not performed, employees may be hired who do not meet laws and regulations to work in a school environment or employees may be hired who are not suitable to perform the positions they were hired for.
Cause: Documentation that the background investigations were compared to the employment application and that a suitability determination was conducted by an appropriate adjudicating official was not maintained.
Recommendation: It is recommended that the Club updates its Employment Suitability Investigations policy to accurately reflect the process for performing background investigations and employment suitability. Within that policy, the Club should ensure that a process is put in place to ensure documentation of the background investigations and employment suitability assessment is maintained in employee files.
Management’s Response: The Club and Cherokee Central Schools (CCS) agree with this finding and CCS notes that its Employment Suitability Investigations policy was updated and formally adopted on July 22, 2019. The audit included a sample of employee files from prior years, before the policy was implemented and before consistent personnel changes were made. Since the policy's adoption, appropriate procedures have been put in place to ensure background investigations and employment suitability assessments are conducted and properly documented. CCS will continue to monitor compliance with the policy and ensure that documentation is consistently maintained in employee personnel files moving forward. Current updates to be enacted immediately include documentation that the Superintendent has reviewed the files.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-006: Significant Deficiency – Allowable Costs/Cost Principles
Program: Indian Schools Student Transportation
Assistance Listing Number: 15.044
Federal Agency: U.S. Department of the Interior
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that a review and approval of all expenditures occurs and that appropriate documentation of that review and approval is maintained.
Condition: Documentation of the review and approval of certain expenditures was unable to be located.
Questioned Costs: None noted.
Context: The documentation of the review and approval of expenditures was not able to be located for two of the six expenditures selected for testing. There were a total of 23 expenditures charged to the program during fiscal year 2023. The sample was not considered statistically valid.
Effect: When expenditures are not properly reviewed and approved, unallowable costs could be charged to federal programs.
Cause: The Club has not implemented an effective system of internal controls over maintaining documentation of the review and approval of program expenditures.
Recommendation: It is recommended that the Club ensures that internal controls are adequately maintained to ensure that the review and approval of program expenditures occurs and that the documentation of that review and approval is appropriately maintained.
Management’s Response: The Club agrees with this finding and has established procedures to ensure that all required signatures are obtained before posting intercompany expenses for transportation. The Assistant Finance Director receives the monthly invoices from the Bus Department and forwards them to the Cherokee Central Schools Finance Director for approval before completing the monthly posting.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-004: Significant Deficiency - Reporting
Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund
Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425
Federal Agency: U.S. Department of the Interior; U.S. Department of Education
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2019; June 30, 2023
Repeat of Prior Year Finding 2022-003
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023.
Questioned Costs: None noted.
Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample.
Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely.
Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request.
Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing.
Questioned Costs: None noted.
Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid.
Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program.
Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process.
Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation.
Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-007: Significant Deficiency – Reporting
Program: CCDF Cluster
Assistance Listing Number: 93.575; 93.596
Federal Agency: U.S. Department of Health and Human Services
Federal Award Identification Number: N/A
Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023
Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors.
Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports.
Questioned Costs: None noted.
Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample.
Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information.
Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports.
Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained.
Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.