Finding 1019359 (2022-008)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2022
Accepted
2023-03-30
Audit: 312521
Organization: Circle of Nations School INC (ND)
Auditor: Eide Bailly LLP

AI Summary

  • Core Issue: The School failed to comply with federal requirements regarding prevailing wage rates in construction contracts.
  • Impacted Requirements: Noncompliance with 2 CFR 656.40 and 656.41, which outline necessary standards for federal program operations.
  • Recommended Follow-Up: Management should implement stronger controls to ensure adherence to all relevant Uniform Guidance and CFR requirements.

Finding Text

Material Weakness in Internal Control Over Compliance and Material Instance of Noncompliance2022-008 Department of EducationFederal Financial Assistance Listing/CFDA Number 84.425Education Stabilization FundSpecial Tests and ProvisionsCriteria ? Uniform Guidance and 2 CFR 656.40 through 656.41 set forth the standardsnonfederal entities other than states must follow when operating federal programs.Condition ? In our testing of Special Tests and Provisions, it was identified that the School didnot satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The School did not ensureproper inclusion of prevailing wage rate clauses were included in a construction contract andalso did not obtain proper support to ensure required certified payrolls were submitted.Cause ? Lack of oversight, awareness, or understanding of all of the specific requirements underUniform Guidance and applicable CFR sections, and controls were not adequately designed toensure compliance with all of these requirements.Effect ? Lack of compliance to federal requirements increases the overall risk of non-compliance.Questioned Costs ? None reportedContext/Sampling ? All contracts were selected for testing.Repeat Finding from Prior Years ? No.Recommendation ? We recommend that management establish controls to follow all applicablerequirements under Uniform Guidance and applicable CFR sections.View of responsible officials ? There is no disagreement with the finding.

Categories

Internal Control / Segregation of Duties Special Tests & Provisions Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 442917 2022-008
    Material Weakness Repeat
  • 442918 2022-008
    Material Weakness
  • 442919 2022-009
    Material Weakness
  • 1019360 2022-008
    Material Weakness
  • 1019361 2022-009
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
15.042 Indian School Equalization Program $1.82M
84.425 Education Stabilization Fund $1.23M
15.047 Indian Education Facilities, Operations, and Maintenance $1.19M
15.046 Administrative Cost Grants for Indian Schools $704,945
84.027 Special Education_grants to States $367,683
84.010 Title I Grants to Local Educational Agencies $267,302
15.044 Indian Schools_student Transportation $185,161
84.287 Twenty-First Century Community Learning Centers $139,924
10.555 National School Lunch Program $65,942
15.149 Focus on Student Achievement Project $60,870
84.060 Indian Education_grants to Local Educational Agencies $58,985
15.151 Education Program Enhancements $30,024
84.336 Teacher Quality Partnership Grants $23,070
84.196 Education for Homeless Children and Youth $20,175
84.424 Student Support and Academic Enrichment Program $10,125
84.358 Rural Education $1,100