Program Information: U.S. Department of the Interior AL # Award Number Award Period Program Name 15.042 A19AV00888 7/1/2021-6/30/2022 Indian School Equalization Program Criteria: Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property (2 CFR section 200.313(d)(1)). A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years (2 CFR section 200.313(d)(2)). A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated (2 CFR section 200.313(d)(3)). Per 2 CFR § 200.303, recipients must establish and maintain effective internal controls over federal awards to ensure compliance with applicable regulations. Condition/Context: During the audit, we noted that a physical inventory of the School’s property had not been taken and reconciled with the property records within the last two years. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: There was turnover in the School’s key accounting staff. Effect: Property records may not be accurate and proper custodianship of the property is compromised. Questioned Costs: N/A - No questioned costs were identified because the finding relates to property inventory and reconciliation procedures rather than specific unsupported or unallowable federal expenditures. Repeat Finding: Yes, 2021-004. Recommendation: We recommend that the School develop policies and procedures requiring a physical inventory of the School’s property at least once every two years, and reconcile the results of the inventory to the property records. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL # Award Number Award Period Program Name 15.042 A19AV00888 7/1/2021-6/30/2022 Indian School Equalization Program Criteria: Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR part 200. During the review of the School’s procurement policies, the following was noted: • Any purchase of materials, supplies, or equipment having a purchase price exceeding $5,000 shall be purchased only after having requested at least three bids or as needed, advertised for sealed bids for a period of not less than five (5) days. Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the suspension and debarment standards set out at 2 CFR Part 180, which implements Executive Orders 12549 and 12689, “Debarment and Suspension”, federal awarding agency regulations in Title 2 of the CFR adopting/implementing the OMB guidance in 2 CFR Part 180; program legislation; and the terms and conditions of the award. Per 2 CFR § 200.303, recipients must establish and maintain effective internal controls over federal awards to ensure compliance with applicable regulations. Condition/Context: During testing the following was noted: • 1 of 1 Individually Important Items tested did not have bidding documentation or sole source justification. • 2 of 2 samples tested did not have bidding documentation or sole source justification. [ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: The School was not following its policies for purchases that exceed $5,000. Effect: The School could be overpaying for services or items that could be obtained elsewhere for less. Questioned Costs: Known – $35,010. Repeat Finding: Yes, 2021-005. Recommendation: We recommend that the School follow its written procurement policies and maintain proper supporting documentation. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL # Award Number Award Period Program Name 15.042 A19AV00888 7/1/2021-6/30/2022 Indian School Equalization Program Criteria: Per the compliance supplement: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Indian tribe or tribal organization may employ individuals in those positions only if the individuals meet standards of character, no less stringent than those prescribed under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFR part 63), as the Indian tribe or tribal organization establishes. Per 2 CFR § 200.303, recipients must establish and maintain effective internal controls over federal awards to ensure compliance with applicable regulations. Condition/Context: For 1 of the 3 samples selected for testing, the School did not provide support for review and approval of the Character Investigations. [ ] Compliance Finding [ X ] Significant Deficiency [ ] Material Weakness Cause: Lack of internal controls and management oversight. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Questioned Costs: N/A - No questioned costs were identified because the finding relates to the lack of documented review and approval of character investigations rather than specific unsupported or unallowable federal expenditures. Repeat Finding: Yes, 2021-007. Recommendation: We recommend that the School establish effective internal controls for the Character Investigations compliance requirement and adhere to the internal controls. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.
Program Information: U.S. Department of the Interior AL # Award Number Award Period Program Name 15.042 A19AV00888 7/1/2021-6/30/2022 Indian School Equalization Program Criteria: Per the compliance supplement: A tribe, tribal organization, or consortia receiving advance payments under the ISDEAA or the Tribally Controlled Schools Act may invest advance payments (some recipients refer to these advance payments as “deferred revenue”) before such funds are expended for the purposes of the grant, contract, or funding agreement, so long as such funds are (1) invested only in obligations of the United States or in obligations or securities that are guaranteed or insured by the United States, or mutual (or other) funds registered with the Securities and Exchange Commission and which only invest in obligations of the United States or securities that are guaranteed or insured by the United States; or (2) deposited only in accounts that are insured by an agency or instrumentality of the United States, or are fully collateralized to ensure protection of the advance funds, even in the event of a bank failure (25 USC 450e-3). Per 2 CFR § 200.303, recipients must establish and maintain effective internal controls over federal awards to ensure compliance with applicable regulations. Condition/Context: For 3 of the 3 samples selected for testing, the School did not provide support for review and approval of the monthly bank reconciliations. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: Lack of internal controls and management oversight. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Questioned Costs: N/A - No questioned costs were identified because the finding relates to the lack of documented review and approval of monthly bank reconciliations rather than specific unsupported or unallowable federal expenditures. Repeat Finding: No. Recommendation: We recommend that the School establish effective internal controls for the monthly bank reconcialtions and adhere to the internal controls. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.