Audit 415407

FY End
2023-06-30
Total Expended
$27.35M
Findings
19
Programs
28
Organization: Little Wound School Board, Inc. (SD)
Year: 2023 Accepted: 2026-10-28
Auditor: BLUEARROW CPA

Organization Exclusion Status:

Checking exclusion status...

Findings

ID Ref Severity Repeat Requirement
1241271 2023-002 Material Weakness Yes I
1241272 2023-002 Material Weakness Yes I
1241273 2023-002 Material Weakness Yes I
1241274 2023-002 Material Weakness Yes I
1241275 2023-002 Material Weakness Yes I
1241276 2023-002 Material Weakness Yes I
1241277 2023-003 Material Weakness Yes N
1241278 2023-003 Material Weakness Yes N
1241279 2023-003 Material Weakness Yes N
1241280 2023-003 Material Weakness Yes N
1241281 2023-003 Material Weakness Yes N
1241282 2023-003 Material Weakness Yes N
1241283 2023-004 Material Weakness Yes P
1241284 2023-004 Material Weakness Yes P
1241285 2023-004 Material Weakness Yes P
1241286 2023-004 Material Weakness Yes P
1241287 2023-004 Material Weakness Yes P
1241288 2023-004 Material Weakness Yes P
1241289 2023-005 Material Weakness Yes M

Programs

ALN Program Spent Major Findings
15.042 INDIAN SCHOOL EQUALIZATION $7.45M Yes 0
84.425 EDUCATION STABILIZATION FUND $4.21M Yes 3
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $3.60M Yes 4
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $2.31M Yes 0
15.046 ADMINISTRATIVE COST GRANTS FOR INDIAN SCHOOLS $1.99M Yes 0
84.027 SPECIAL EDUCATION GRANTS TO STATES $1.65M Yes 3
15.044 INDIAN SCHOOLS STUDENT TRANSPORTATION $1.33M Yes 3
15.047 INDIAN EDUCATION FACILITIES, OPERATIONS, AND MAINTENANCE $1.32M Yes 0
93.665 EMERGENCY GRANTS TO ADDRESS MENTAL AND SUBSTANCE USE DISORDERS DURING COVID-19 $773,316 Yes 3
15.062 REPLACEMENT AND REPAIR OF INDIAN SCHOOLS $647,201 Yes 3
15.043 INDIAN CHILD AND FAMILY EDUCATION $372,349 Yes 0
10.555 NATIONAL SCHOOL LUNCH PROGRAM $272,349 Yes 0
84.299 INDIAN EDUCATION -- SPECIAL PROGRAMS FOR INDIAN CHILDREN $241,446 Yes 0
84.336 TEACHER QUALITY PARTNERSHIP GRANTS $203,600 Yes 0
84.299A Special Projects Demonstration Grants $150,166 Yes 0
15.149 FOCUS ON STUDENT ACHIEVEMENT $145,916 Yes 0
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $139,686 Yes 0
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $129,900 Yes 0
84.101 CAREER AND TECHNICAL EDUCATION - GRANTS TO NATIVE AMERICANS AND ALASKA NATIVES $126,147 Yes 0
10.553 SCHOOL BREAKFAST PROGRAM $93,584 Yes 0
84.415 INDIAN EDUCATION NATIONAL ACTIVITIES (STATE TRIBAL EDUCATION PARTNERSHIP (STEP) AND NATIVE AMERICAN LANGUAGE (NAL) $65,908 Yes 0
84.377 SCHOOL IMPROVEMENT GRANTS $29,895 Yes 0
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $24,931 Yes 0
10.575 FARM TO SCHOOL GRANT PROGRAM $22,341 Yes 0
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $19,166 Yes 0
10.558 CHILD AND ADULT CARE FOOD PROGRAM $17,086 Yes 0
84.358 RURAL EDUCATION $10,900 Yes 0
45.164 PROMOTION OF THE HUMANITIES PUBLIC PROGRAMS $5,122 Yes 0

Contacts

Name Title Type
M2GVXNYCYZK7 Paula Pourier Auditee
6054556173 Sanwar Harshwal Auditor
No contacts on file

Notes to SEFA

The accompanying schedule of expenditures of federal awards (the "Schedule") includes the federal grant activity of Little Wound School Board, Inc. (the "School") under programs of the federal government for the year ended June 30, 2023. The information in the Schedule is presented in accordance with the requirements of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). Because the Schedule presents only a selected portion of the operations of the School, it is not intended to and does not present the financial position, changes in net position or cash flows of the School.
Expenditures reported on the Schedule are reported on the modified accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the applicable Uniform Guidance cost principles, wherein certain types of expenditures are not allowable or are limited as to reimbursement.
The School elected to use the 10-percent de minimis indirect cost rate as allowed under the Uniform Guidance for its Department of Education grants and Department of Health and Human Services grants.
The School provided federal awards totaling $1,635,596 to subrecipients during the fiscal year ended June 30, 2023.

Finding Details

Identification of Major Programs Affected: This finding relates to all major programs Criteria: Title 2, U.S. Code of Federal Regulations (CFR), Part 200 establishes procurement requirements applicable to purchases made with Federal awards. 2 CFR § 200.318(i) requires the School to maintain records sufficient to detail the history of procurement transactions. Such records should include, as applicable, the rationale for the method of procurement, selection of the contractor, reasons for contractor selection or rejection, and the basis for the contract price. Additionally, 2 CFR § 200.214 requires compliance with the suspension and debarment requirements contained in 2 CFR Part 180. Under 2 CFR § 180.300, prior to entering into an applicable covered transaction, the School is required to verify that the prospective contractor or vendor is not excluded or disqualified from participation in Federal programs. Verification may be accomplished by reviewing the System for Award Management (SAM.gov), obtaining an appropriate certification from the vendor, or including an applicable clause or condition in the transaction. According to 2 CFR section 200.319, all procurement transactions for acquiring property or services required under a Federal award must be conducted with full and open competition. This ensures fairness and transparency in the procurement process, consistent with the standards outlined in this section and § 200.320. Condition: During our testing of procurement transactions charged to the Federal program, we noted that the School did not maintain sufficient documentation to demonstrate that suspension and debarment verification was performed at the time applicable contracts or covered transactions were entered into. In addition, for certain noncompetitive procurements, the School was unable to provide documentation supporting the sole-source justification or demonstrating that an allowable condition for noncompetitive procurement was met. Cause: The School did not have adequate procedures in place to ensure that suspension and debarment verification and documentation supporting sole-source procurements were completed and retained prior to entering into federally funded contracts. Effect: Noncompliance with procurement requirements under Uniform Guidance and School procurement policy. The lack of adequate procurement documentation increases the risk that purchases made with Federal funds may not comply with Federal procurement requirements or may not be obtained through appropriate competition. Additionally, failure to document suspension and debarment verification increases the risk that the School could enter into a covered transaction with a vendor that is suspended, debarred, or otherwise excluded from participation in Federal programs. Auditor's Recommendations: The School should strengthen its vendor selection procedures and ensure adherence to procurement policies to minimize risks and enhance efficiency. Noncompetitive or sole-source procurements should include written documentation supporting the applicable allowable circumstance under 2 CFR § 200.320. The rationale for the procurement method, vendor selection, and basis for the contract price should be retained in the procurement file. Suspension and debarment status is verified prior to entering into applicable covered transactions using one of the methods permitted under 2 CFR Part 180, and evidence of such verification is retained.
Identification of Major Programs Affected: This finding relates to all major programs. The matter was identified through follow-up of prior-year Finding 2022-001 and remained unresolved during the current year audit. Criteria or Specific Requirement: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: The School did not maintain sufficient documentation to demonstrate that required background investigations were properly completed for certain employees. For the employees tested, the documentation provided was incomplete and did not adequately support that the required background investigation and related review procedures had been performed. Cause: Oversight of background checks was not being performed to ensure the School complied with applicable requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Auditor's Recommendations: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained.
Identification of Major Programs Affected: This finding relates to all major programs. Criteria or Specific Requirement: The Uniform Guidance 2 CFR 200.512(a) requires the audit package and data collection form be submitted 30 days after receipt of the auditor's report or 9 months after the end of the fiscal year, whichever comes first. Condition: The School did not complete its audit package and data collection form within the nine months after June 30, 2023. Cause: The School was unable to furnish the necessary audit documentation to ensure timely and accurate reporting. Effect: The School is not in compliance with Uniform Guidance 2 CFR 200.512(a). Auditor's Recommendations: We recommend the School obtain necessary resources to allow for completion of the annual financial report on a timely basis.
Funding Agency U.S. Department of Health and Human Services Criteria: Title Substance Abuse and Mental Health Services Projects of Regional and National Significance Federal Assistance Listing Number: 93.243 Under 2 CFR § 200.332, a pass-through entity is required to clearly identify Federal awards to subrecipients at the time of the subaward and communicate all applicable Federal award information, terms, and conditions through the subaward agreement. The pass-through entity is also responsible for evaluating each subrecipient’s risk of noncompliance and monitoring subrecipient activities to ensure that Federal funds are used for authorized purposes, in compliance with applicable Federal statutes, regulations, and the terms and conditions of the subaward, and that program performance objectives are achieved. Accordingly, the pass-through entity should maintain adequate documentation supporting its subrecipient relationships, including properly executed subrecipient agreements, applicable amendments, approved budgets when required by the agreement, and other relevant monitoring documentation. Such documentation should be current, executed in a timely manner, and retained for the period during which Federal funds are provided to and administered by the subrecipient. Condition: During our testing of five subrecipients for the fiscal year ended June 30, 2023, we noted the following deficiencies:  Three of five subrecipient agreements were executed after the fiscal year end. Therefore, the agreements were not timely executed during the period in which the subrecipients were carrying out activities under the Federal awards.  For the remaining two of five subrecipients, amendments applicable to the current fiscal year were not available for audit examination. Accordingly, we were unable to verify the current-year terms, funding amounts, periods of performance, and other applicable provisions of the subaward arrangements.  Approved budgets required under the applicable subrecipient agreements were not provided for audit examination. As a result, we were unable to verify that subrecipient expenditures were incurred in accordance with the approved budgets and the terms and conditions of the respective agreements. As a result, the School did not maintain sufficient supporting documentation demonstrating that complete and current subaward agreements, amendments, and required approved budgets were in place and available for monitoring purposes during the fiscal year. Cause: The School did not have adequate procedures in place to ensure that subrecipient agreements and amendments were executed timely and that all required supporting documentation, including approved budgets, was obtained, retained, and available as part of the subrecipient monitoring process. Effect: The School is not in compliance with federal requirements related to subrecipient monitoring. Auditor's Recommendations: We recommend that the School establish and implement formal procedures to ensure that:  Subrecipient agreements are fully executed before subrecipients begin performing activities or incurring expenditures under the applicable Federal award;  Amendments are prepared and executed timely whenever funding amounts, periods of performance, budgets, or other terms of the agreement change;  Approved budgets required by the subrecipient agreements are obtained, formally approved, and retained for each applicable fiscal year;  Subrecipient expenditures are periodically compared to the approved budgets as part of the School's monitoring procedures; and  All executed agreements, amendments, approved budgets, and other monitoring documentation are centrally maintained and readily available for audit examination.