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
Criteria: Character Investigations by Indian Tribes and Tribal Organizations Compliance
Requirements: The Indian Child Protection and Family Violence Prevention 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), as the Indian tribe or tribal organization establishes.
2 CFR § 200.303 - Internal controls states, the recipient and subrecipient 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 or the “Internal Control Integrated Framework”, issued by the
Committee of Sponsoring Organizations of the Treadway Commission (COSO).
Condition/Context: For 4 of the 4 samples selected for testing, the School did not provide support for
review and approval of the Character Investigations.
[ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness
Cause: Lack of internal controls and management oversight.
Effect: Without an effective internal control system an entity’s objective: operations, reporting, and
compliance cannot be achieved.
Questioned Costs: N/A.
Repeat Finding: Yes, 2020-003.
Recommendation: We recommend that the School establish effective internal controls for the Character
Investigations compliance requirement and adhere to the internal controls.
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.