Finding Text
Finding Number: 2024-001
Repeat Finding: Yes (2023-001, 2021-001)
Program Name/Assistance Listing Title: Indian School Equalization Program
Assistance Listing Number: 15.042
Federal Agency: U.S. Department of Interior
Federal Award Number: A23AV00813
Pass-Through Agency: Bureau of Indian Education
Questioned Costs: N/A
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirement:
CRITERIA
According to the Indian Child Protection and Family Violence Prevention Act 925 USC §3201 et. sec.), the School must conduct a character investigation of each individual who is employed or is being considered for employment in a position that involves regular conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFS part 63).
Condition
The School did not complete character reinvestigations timely for all employees.
Cause
School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely.
Effect
The School was not in compliance with the Indian Child Protection and Family Violence Prevention Act.
Context
During our review of the School’s character investigations, we noted, for seven of 37 character
investigations reviewed, the five year reinvestigation was not completed timely. The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The School should ensure character investigations are performed in a timely manner to achieve full compliance with the School’s policies and the Indian Child Protection and Family Violence Prevention Act.
Views Of Responsible Officials
See Corrective Action Plan.