2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?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 FAIN), who holds title, the acquisition date, and 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 sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?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.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.
2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.
2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.
2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.