Finding 1149000 (2023-008)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2025-08-05
Audit: 363709
Organization: Cherokee Boys Club, Inc. (NC)

AI Summary

  • Core Issue: Lack of documentation showing that background investigation results were compared to employment applications and that suitability determinations were made by qualified officials.
  • Impacted Requirements: Non-compliance with 25 CFR section 63.17, risking hiring unsuitable employees for school positions.
  • Recommended Follow-Up: Update the Employment Suitability Investigations policy to ensure proper documentation and adherence to background check processes moving forward.

Finding Text

Finding 2023-008: Significant Deficiency – Special Tests and Provisions Program: Indian School Equalization Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Identification Number: N/A Federal Award Year: June 30, 2023 Criteria: 25 CFR section 63.17 requires that Indian Tribes and tribal organizations perform adjudication to determine suitability for employment and efficiency of service. The adjudication process protects the interests of the employer and the rights of applicants and employees. Adjudication requires uniform evaluation to ensure fair and consistent judgment. Condition: While documentation exists that a background investigation was completed, no documentation was maintained that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation. Questioned Costs: None noted. Context: No documentation was available that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation for 4 of the 40 employees selected for testing. The sample was not considered statistically valid. Effect: When comparison of background investigations and suitability determinations are not performed, employees may be hired who do not meet laws and regulations to work in a school environment or employees may be hired who are not suitable to perform the positions they were hired for. Cause: Documentation that the background investigations were compared to the employment application and that a suitability determination was conducted by an appropriate adjudicating official was not maintained. Recommendation: It is recommended that the Club updates its Employment Suitability Investigations policy to accurately reflect the process for performing background investigations and employment suitability. Within that policy, the Club should ensure that a process is put in place to ensure documentation of the background investigations and employment suitability assessment is maintained in employee files. Management’s Response: The Club and Cherokee Central Schools (CCS) agree with this finding and CCS notes that its Employment Suitability Investigations policy was updated and formally adopted on July 22, 2019. The audit included a sample of employee files from prior years, before the policy was implemented and before consistent personnel changes were made. Since the policy's adoption, appropriate procedures have been put in place to ensure background investigations and employment suitability assessments are conducted and properly documented. CCS will continue to monitor compliance with the policy and ensure that documentation is consistently maintained in employee personnel files moving forward. Current updates to be enacted immediately include documentation that the Superintendent has reviewed the files.

Categories

Special Tests & Provisions Significant Deficiency

Other Findings in this Audit

  • 572557 2023-004
    Significant Deficiency Repeat
  • 572558 2023-008
    Significant Deficiency
  • 572559 2023-004
    Significant Deficiency Repeat
  • 572560 2023-006
    Significant Deficiency
  • 572561 2023-004
    Significant Deficiency Repeat
  • 572562 2023-004
    Significant Deficiency Repeat
  • 572563 2023-004
    Significant Deficiency Repeat
  • 572564 2023-004
    Significant Deficiency Repeat
  • 572565 2023-004
    Significant Deficiency Repeat
  • 572566 2023-005
    Significant Deficiency
  • 572567 2023-007
    Significant Deficiency
  • 572568 2023-005
    Significant Deficiency
  • 572569 2023-007
    Significant Deficiency
  • 572570 2023-005
    Significant Deficiency
  • 572571 2023-007
    Significant Deficiency
  • 572572 2023-005
    Significant Deficiency
  • 572573 2023-007
    Significant Deficiency
  • 572574 2023-005
    Significant Deficiency
  • 572575 2023-007
    Significant Deficiency
  • 572576 2023-005
    Significant Deficiency
  • 572577 2023-007
    Significant Deficiency
  • 572578 2023-005
    Significant Deficiency
  • 572579 2023-007
    Significant Deficiency
  • 1148999 2023-004
    Significant Deficiency Repeat
  • 1149001 2023-004
    Significant Deficiency Repeat
  • 1149002 2023-006
    Significant Deficiency
  • 1149003 2023-004
    Significant Deficiency Repeat
  • 1149004 2023-004
    Significant Deficiency Repeat
  • 1149005 2023-004
    Significant Deficiency Repeat
  • 1149006 2023-004
    Significant Deficiency Repeat
  • 1149007 2023-004
    Significant Deficiency Repeat
  • 1149008 2023-005
    Significant Deficiency
  • 1149009 2023-007
    Significant Deficiency
  • 1149010 2023-005
    Significant Deficiency
  • 1149011 2023-007
    Significant Deficiency
  • 1149012 2023-005
    Significant Deficiency
  • 1149013 2023-007
    Significant Deficiency
  • 1149014 2023-005
    Significant Deficiency
  • 1149015 2023-007
    Significant Deficiency
  • 1149016 2023-005
    Significant Deficiency
  • 1149017 2023-007
    Significant Deficiency
  • 1149018 2023-005
    Significant Deficiency
  • 1149019 2023-007
    Significant Deficiency
  • 1149020 2023-005
    Significant Deficiency
  • 1149021 2023-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
15.042 Indian School Equalization $10.41M
84.010 Title I Grants to Local Educational Agencies $3.16M
15.046 Administrative Cost Grants for Indian Schools $2.53M
15.047 Indian Education Facilities, Operations, and Maintenance $1.56M
84.425 Education Stabilization Fund $1.49M
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $1.41M
15.044 Indian Schools Student Transportation $794,727
84.101 Career and Technical Education - Grants to Native Americans and Alaska Natives $431,511
15.144 Indian Child Welfare Act Title II Grants $308,831
93.558 Temporary Assistance for Needy Families $172,095
84.336 Teacher Quality Partnership Grants $171,067
84.371 Comprehensive Literacy Development $73,085
12.357 Rotc Language and Culture Training Grants $68,876
10.558 Child and Adult Care Food Program $51,201
93.575 Child Care and Development Block Grant $23,675
84.027 Special Education Grants to States $20,840
84.181 Special Education-Grants for Infants and Families $11,431
84.173 Special Education Preschool Grants $6,659
84.060 Indian Education Grants to Local Educational Agencies $6,352