Audit 412850

Finding Number: 2025‐001 Repeat Finding: No Program Name/Assistance Listing Title: Tribal Self Determination Assistance Listing Number: 93.441 Federal Agency: U.S. Department of Health and Human Services Federal Award Number: N/A Pass‐Through Agency: N/A 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 Protection Act (25 USC §3201 et. Sec.), the School Board must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular contact with, or control over, Indian children. The investigation should be reinvestigated every five years. The Act further states that the School Board may employ individuals in those positions only if the individuals meet standards of character, no less stringent than those prescribed under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFR part 63). Condition Timely background investigations were not conducted for all employees. Cause School Board and federal policies were not always followed or controls were not in place to ensure timely character investigations were performed. Effect The School Board was not in compliance with the Indian Child Protection and Family Violence Prevention Act. Context The sample was not intended to be, and was not, a statistically valid sample. During our review of the School’s character investigations, we noted that for four of 12 background investigations reviewed, the investigations were not completed timely after the previous investigation expired. Recommendation The School Board should ensure adequate character investigations are performed in a timely manner to achieve full compliance with the School’s policies and the Indian Child Protection and Family Violence Prevention Act. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2025‐002 Repeat Finding: No Program Name/Assistance Listing Title: Tribal Self Determination Assistance Listing Number: 93.441 Federal Agency: U.S. Department of Health and Human Services Federal Award Number: N/A Pass‐Through Agency: N/A Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Eligibility Criteria According to Indian Health Services (IHS) eligibility requirements, Individuals of Indian descent belonging to the Indian community served by the local facilities and program are eligible to receive services. An individual may be regarded as within the scope of the Indian health and medical service if the individual is regarded as an Indian by the community in which the individual lives as evidenced by such factors as tribal membership, enrollment, residence on tax‐exempt land, ownership of restricted property, active participation in tribal affairs, or other relevant factors in keeping with the general Bureau of Indian Affairs practices in the jurisdiction (42 CFR 136.12(a)). Condition The School Board did not always retain documentation demonstrating that patients met eligibility requirements prior to receiving services. Cause Management procedures for verifying and retaining eligibility documentation were not consistently followed. As a result, required documentation was not maintained for all individuals receiving program services. Effect The School Board was not in compliance with IHS eligibility requirements. Context The sample was not intended to be, and was not, a statistically valid sample. For two of 40 patients tested, the School Board could not provide a Certificate of Indian Blood or other documentation supporting the patients' eligibility for services provided under the program. Recommendation The School Board should ensure adequate documentation demonstrating that patients met eligibility requirements is obtained prior to receiving services to achieve full compliance with IHS eligibility requirements. Finding Number: 2025-002 Views of Responsible Officials See Corrective Action Plan.