Finding Text
Program Information:
U.S. Department of the Interior
AL # Award Number Award Period Program Name
15.042 A19AV00888 7/1/2020-6/30/2021 Indian School Equalization Program
15.046 A19AV00888 7/1/2020-6/30/2021 Administrative Cost Grants for Indian Schools
Criteria: The cost principles in 2 CFR part 200, subpart E (Cost Principles), prescribe the cost
accounting requirements associated with the administration of Federal awards by:
a. States, local governments, and Indian tribes
b. Institutions of higher education (IHEs)
c. Nonprofit organizations
Except where otherwise authorized by statute, cost must meet the following general criteria in order to be
allowable under Federal awards:
4. Be accorded consistent treatment. A cost may not be assigned to a Federal award as a direct cost if
any other cost incurred for the same purpose in like circumstances has been allocated to the
Federal award as an indirect cost.
7. Be adequately documented.
2 CFR § 200.303 - Internal controls states, the recipient and subrecipient must:
(a) 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 or the “Internal Control
Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway
Commission (COSO).
Condition/Context: During the testing of 15.042, the following was noted:
• 1 of 8 non-payroll samples did not have sufficient supporting documentation.
• 9 of 32 payroll samples did not have indication of management approval on the
timesheet/timecard.
• 5 of 32 payroll samples did not have a Personnel Action Form provided.
• 1 of 32 payroll samples did not have management approval of the employee contract.
• 1 of 32 payroll samples did not have sufficient supporting documentation.
During the testing of 15.046, the following was noted:
• Support was not provided for 2 of 30 non-payroll samples.
• 1 of 3 Individually Important Items and 1 of 30 payroll samples did not have adequate
documentation.
• 4 of 30 payroll samples did not have an approved timesheet.
[ X ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness
Cause: Due to turnover in key personnel and lack of internal controls, the School did not have the ability
to provide supporting documentation.
Effect: Without an effective internal control system an entity’s objective operations, reporting, and
compliance, cannot be achieved. In addition, program funds could be expended on activities or costs that
are deemed unallowable by the funding agency.
Questioned Costs: $1,890 for 15.042, none for 15.046 as the known plus likely questioned costs did not
exceed $25,000.
Repeat Finding: No.
Recommendation: We recommend the School enhances training for grant expenditures on federal cost
allowability requirements, strengthen documentation & approval controls, and improve document
retention practices.
Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding
and has prepared corrective action as detailed in its Corrective Action Plan.