Audit 381997

Finding 2024-005: 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, 2024 Repeat of Prior Year Finding 2023-008 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 6 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 2024-004: Significant Deficiency - Reporting Program: Indian School Equalization; Indian Education Facilities, Operations and Maintenance Assistance Listing Number: 15.042; 15.047 Federal Agency: U.S. Department of the Interior Federal Award Identification Number: N/A Federal Award Year: June 30, 2024 Repeat of Prior Year Finding 2023-004 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. Questioned Costs: None noted. Context: There were three annual SF-425 reports required for the current year, each of which did not have review of the calculation of the amounts in the reports. The sample was not a statistically valid sample. Effect: The report may contain inaccurate information. Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are properly reviewed by someone other than the preparer. 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.