FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001, 2020-001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to the Indian Child Protection and Family Violence Prevention Act 925 USC ?3201 et. sec.), the School must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFS part 63). CONDITION The School did not complete character reinvestigations timely for all employees. CAUSE School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. EFFECT The School was not in compliance with the Indian Child Protection and Family Violence Prevention Act. CONTEXT During our review of the School?s character investigations, we noted the following: ? For eight of 27 character investigations reviewed, the initial investigation was completed timely; however, an adjudicating official did not certify the results. ? For two of 27 character investigations reviewed, the five year reinvestigation was not completed timely. RECOMMENDATION The School should ensure character investigations are performed in a timely manner and reviewed by an adjudicating official to achieve full compliance with the School?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR ?180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR ?200.320. CONDITION Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. CAUSE The School?s internal controls over procurement of goods and services were not adequate. EFFECT The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. CONTEXT The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to three vendors. Additionally, for three of four vendors paid between $25,000 to $100,000, the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. RECOMMENDATION The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-003 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A19AV00849 n/a Administrative Cost Grants for Indian Schools 15.046 A19AV00849 n/a Twenty-First Century Community Learning Centers 84.287 A19AV00849 n/a Federal Agencies: U.S. Department of Interior, U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Allowable Costs/Cost Principles CRITERIA According to Uniform Guidance 2 CFR 200.430, payroll distribution records must support the distribution of salary or wages among specific activities or cost objectives if an employee works on more than one award or activity. Employees who work on multiple activities or cost objectives must submit monthly activity reports, documenting time worked in each Federal program. CONDITION Time and effort records were not maintained for employees whose time was charges to multiple cost objectives. CAUSE The School?s policies over time and effort reporting were not always followed. EFFECT The School was not in compliance with the time and effort provision of Uniform Guidance 2 CFR 200.430. CONTEXT For two of two employees reviewed that were compensated from funding sources with different multiple cost objectives, time and effort documentation was not maintained to support costs charged to the Federal programs. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should review and implement policies related to time and effort reporting to ensure compliance. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001, 2020-001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to the Indian Child Protection and Family Violence Prevention Act 925 USC ?3201 et. sec.), the School must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFS part 63). CONDITION The School did not complete character reinvestigations timely for all employees. CAUSE School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. EFFECT The School was not in compliance with the Indian Child Protection and Family Violence Prevention Act. CONTEXT During our review of the School?s character investigations, we noted the following: ? For eight of 27 character investigations reviewed, the initial investigation was completed timely; however, an adjudicating official did not certify the results. ? For two of 27 character investigations reviewed, the five year reinvestigation was not completed timely. RECOMMENDATION The School should ensure character investigations are performed in a timely manner and reviewed by an adjudicating official to achieve full compliance with the School?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR ?180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR ?200.320. CONDITION Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. CAUSE The School?s internal controls over procurement of goods and services were not adequate. EFFECT The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. CONTEXT The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to three vendors. Additionally, for three of four vendors paid between $25,000 to $100,000, the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. RECOMMENDATION The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-003 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A19AV00849 n/a Administrative Cost Grants for Indian Schools 15.046 A19AV00849 n/a Twenty-First Century Community Learning Centers 84.287 A19AV00849 n/a Federal Agencies: U.S. Department of Interior, U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Allowable Costs/Cost Principles CRITERIA According to Uniform Guidance 2 CFR 200.430, payroll distribution records must support the distribution of salary or wages among specific activities or cost objectives if an employee works on more than one award or activity. Employees who work on multiple activities or cost objectives must submit monthly activity reports, documenting time worked in each Federal program. CONDITION Time and effort records were not maintained for employees whose time was charges to multiple cost objectives. CAUSE The School?s policies over time and effort reporting were not always followed. EFFECT The School was not in compliance with the time and effort provision of Uniform Guidance 2 CFR 200.430. CONTEXT For two of two employees reviewed that were compensated from funding sources with different multiple cost objectives, time and effort documentation was not maintained to support costs charged to the Federal programs. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should review and implement policies related to time and effort reporting to ensure compliance. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-003 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A19AV00849 n/a Administrative Cost Grants for Indian Schools 15.046 A19AV00849 n/a Twenty-First Century Community Learning Centers 84.287 A19AV00849 n/a Federal Agencies: U.S. Department of Interior, U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Allowable Costs/Cost Principles CRITERIA According to Uniform Guidance 2 CFR 200.430, payroll distribution records must support the distribution of salary or wages among specific activities or cost objectives if an employee works on more than one award or activity. Employees who work on multiple activities or cost objectives must submit monthly activity reports, documenting time worked in each Federal program. CONDITION Time and effort records were not maintained for employees whose time was charges to multiple cost objectives. CAUSE The School?s policies over time and effort reporting were not always followed. EFFECT The School was not in compliance with the time and effort provision of Uniform Guidance 2 CFR 200.430. CONTEXT For two of two employees reviewed that were compensated from funding sources with different multiple cost objectives, time and effort documentation was not maintained to support costs charged to the Federal programs. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should review and implement policies related to time and effort reporting to ensure compliance. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-003 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A19AV00849 n/a Administrative Cost Grants for Indian Schools 15.046 A19AV00849 n/a Twenty-First Century Community Learning Centers 84.287 A19AV00849 n/a Federal Agencies: U.S. Department of Interior, U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Allowable Costs/Cost Principles CRITERIA According to Uniform Guidance 2 CFR 200.430, payroll distribution records must support the distribution of salary or wages among specific activities or cost objectives if an employee works on more than one award or activity. Employees who work on multiple activities or cost objectives must submit monthly activity reports, documenting time worked in each Federal program. CONDITION Time and effort records were not maintained for employees whose time was charges to multiple cost objectives. CAUSE The School?s policies over time and effort reporting were not always followed. EFFECT The School was not in compliance with the time and effort provision of Uniform Guidance 2 CFR 200.430. CONTEXT For two of two employees reviewed that were compensated from funding sources with different multiple cost objectives, time and effort documentation was not maintained to support costs charged to the Federal programs. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should review and implement policies related to time and effort reporting to ensure compliance. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001, 2020-001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to the Indian Child Protection and Family Violence Prevention Act 925 USC ?3201 et. sec.), the School must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFS part 63). CONDITION The School did not complete character reinvestigations timely for all employees. CAUSE School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. EFFECT The School was not in compliance with the Indian Child Protection and Family Violence Prevention Act. CONTEXT During our review of the School?s character investigations, we noted the following: ? For eight of 27 character investigations reviewed, the initial investigation was completed timely; however, an adjudicating official did not certify the results. ? For two of 27 character investigations reviewed, the five year reinvestigation was not completed timely. RECOMMENDATION The School should ensure character investigations are performed in a timely manner and reviewed by an adjudicating official to achieve full compliance with the School?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR ?180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR ?200.320. CONDITION Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. CAUSE The School?s internal controls over procurement of goods and services were not adequate. EFFECT The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. CONTEXT The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to three vendors. Additionally, for three of four vendors paid between $25,000 to $100,000, the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. RECOMMENDATION The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-003 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A19AV00849 n/a Administrative Cost Grants for Indian Schools 15.046 A19AV00849 n/a Twenty-First Century Community Learning Centers 84.287 A19AV00849 n/a Federal Agencies: U.S. Department of Interior, U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Allowable Costs/Cost Principles CRITERIA According to Uniform Guidance 2 CFR 200.430, payroll distribution records must support the distribution of salary or wages among specific activities or cost objectives if an employee works on more than one award or activity. Employees who work on multiple activities or cost objectives must submit monthly activity reports, documenting time worked in each Federal program. CONDITION Time and effort records were not maintained for employees whose time was charges to multiple cost objectives. CAUSE The School?s policies over time and effort reporting were not always followed. EFFECT The School was not in compliance with the time and effort provision of Uniform Guidance 2 CFR 200.430. CONTEXT For two of two employees reviewed that were compensated from funding sources with different multiple cost objectives, time and effort documentation was not maintained to support costs charged to the Federal programs. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should review and implement policies related to time and effort reporting to ensure compliance. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001, 2020-001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to the Indian Child Protection and Family Violence Prevention Act 925 USC ?3201 et. sec.), the School must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFS part 63). CONDITION The School did not complete character reinvestigations timely for all employees. CAUSE School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. EFFECT The School was not in compliance with the Indian Child Protection and Family Violence Prevention Act. CONTEXT During our review of the School?s character investigations, we noted the following: ? For eight of 27 character investigations reviewed, the initial investigation was completed timely; however, an adjudicating official did not certify the results. ? For two of 27 character investigations reviewed, the five year reinvestigation was not completed timely. RECOMMENDATION The School should ensure character investigations are performed in a timely manner and reviewed by an adjudicating official to achieve full compliance with the School?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR ?180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR ?200.320. CONDITION Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. CAUSE The School?s internal controls over procurement of goods and services were not adequate. EFFECT The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. CONTEXT The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to three vendors. Additionally, for three of four vendors paid between $25,000 to $100,000, the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. RECOMMENDATION The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-003 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A19AV00849 n/a Administrative Cost Grants for Indian Schools 15.046 A19AV00849 n/a Twenty-First Century Community Learning Centers 84.287 A19AV00849 n/a Federal Agencies: U.S. Department of Interior, U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Allowable Costs/Cost Principles CRITERIA According to Uniform Guidance 2 CFR 200.430, payroll distribution records must support the distribution of salary or wages among specific activities or cost objectives if an employee works on more than one award or activity. Employees who work on multiple activities or cost objectives must submit monthly activity reports, documenting time worked in each Federal program. CONDITION Time and effort records were not maintained for employees whose time was charges to multiple cost objectives. CAUSE The School?s policies over time and effort reporting were not always followed. EFFECT The School was not in compliance with the time and effort provision of Uniform Guidance 2 CFR 200.430. CONTEXT For two of two employees reviewed that were compensated from funding sources with different multiple cost objectives, time and effort documentation was not maintained to support costs charged to the Federal programs. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should review and implement policies related to time and effort reporting to ensure compliance. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-003 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A19AV00849 n/a Administrative Cost Grants for Indian Schools 15.046 A19AV00849 n/a Twenty-First Century Community Learning Centers 84.287 A19AV00849 n/a Federal Agencies: U.S. Department of Interior, U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Allowable Costs/Cost Principles CRITERIA According to Uniform Guidance 2 CFR 200.430, payroll distribution records must support the distribution of salary or wages among specific activities or cost objectives if an employee works on more than one award or activity. Employees who work on multiple activities or cost objectives must submit monthly activity reports, documenting time worked in each Federal program. CONDITION Time and effort records were not maintained for employees whose time was charges to multiple cost objectives. CAUSE The School?s policies over time and effort reporting were not always followed. EFFECT The School was not in compliance with the time and effort provision of Uniform Guidance 2 CFR 200.430. CONTEXT For two of two employees reviewed that were compensated from funding sources with different multiple cost objectives, time and effort documentation was not maintained to support costs charged to the Federal programs. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should review and implement policies related to time and effort reporting to ensure compliance. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-003 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A19AV00849 n/a Administrative Cost Grants for Indian Schools 15.046 A19AV00849 n/a Twenty-First Century Community Learning Centers 84.287 A19AV00849 n/a Federal Agencies: U.S. Department of Interior, U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Allowable Costs/Cost Principles CRITERIA According to Uniform Guidance 2 CFR 200.430, payroll distribution records must support the distribution of salary or wages among specific activities or cost objectives if an employee works on more than one award or activity. Employees who work on multiple activities or cost objectives must submit monthly activity reports, documenting time worked in each Federal program. CONDITION Time and effort records were not maintained for employees whose time was charges to multiple cost objectives. CAUSE The School?s policies over time and effort reporting were not always followed. EFFECT The School was not in compliance with the time and effort provision of Uniform Guidance 2 CFR 200.430. CONTEXT For two of two employees reviewed that were compensated from funding sources with different multiple cost objectives, time and effort documentation was not maintained to support costs charged to the Federal programs. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should review and implement policies related to time and effort reporting to ensure compliance. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.