Finding 1182817 (2025-007)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-03-25
Audit: 394228
Organization: Circle of Nations School INC (ND)
Auditor: EIDE BAILLY LLP

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over compliance related to allowable costs for federal grants.
  • Impacted Requirements: Expenditures must be properly recorded and allowable under 2 CFR 200.430(i); current procedures fail to identify unallowable costs.
  • Recommended Follow-Up: The School should enhance internal control procedures to ensure thorough review of federal expenditures for compliance with grant requirements.

Finding Text

Department of the Interior Federal Financial Assistance Listing 15.042 Indian School Equalization Allowable Costs/Activities Allowed or Unallowed Significant Deficiency in Internal Control Over Compliance and Immaterial Instance of Noncompliance Criteria – A good system of internal control includes an adequate system for ensuring all expenditures are properly recorded and allowable under the related federal grant in accordance with 2 CFR 200.430(i). Condition – In our testing of allowable costs and activities we noted one instance totaling $3.27 where payroll benefits were not paid in accordance with the employment letter. Cause – Procedures are not in place to adequately identify unallowable costs or activities. Effect – A lack of internal controls over allowable costs and activities could result in the improper use of federal funds and non-compliance with the provisions of applicable grant requirements. Questioned Costs – None reported Context/Sampling – A nonstatistical sample of 60 transactions out of 882 total transactions were selected for testing, which accounted for $26,666 of $2,203,450 of federal program expenditures. Repeat Finding from Prior Years – Yes, 2024-008 Recommendation – The School should review internal control procedures to ensure federal expenditures are being properly reviewed for unallowable costs and activities. Views of Responsible Officials – The School respectfully disagrees with the classification of this matter as a significant deficiency.

Corrective Action Plan

Allowable Costs/Activities Allowed or Unallowed Federal Financial Assistance Listing 15.042 Indian School Equalization Significant Deficiency in Internal Control over Compliance and Immaterial Instances of Noncompliance Findings Summary: During the course of the engagement, Eide Bailly LLP identified an expenditure where payroll benefits were not paid in accordance with the employment letter. Responsible Individuals: Trevor Gourneau, Superintendent Corrective Action Plan: The School will review internal controls surrounding allowable costs and activities to exsure they are adequate to identify unallowable expenditures. Anticipated Completion Date: June 30, 2026

Categories

Allowable Costs / Cost Principles

Programs in Audit

ALN Program Name Expenditures
15.042 INDIAN SCHOOL EQUALIZATION $2.20M
15.047 INDIAN EDUCATION FACILITIES, OPERATIONS, AND MAINTENANCE $1.21M
15.046 ADMINISTRATIVE COST GRANTS FOR INDIAN SCHOOLS $777,476
84.027 SPECIAL EDUCATION GRANTS TO STATES $453,959
15.044 INDIAN SCHOOLS STUDENT TRANSPORTATION $308,035
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $227,611
84.425 EDUCATION STABILIZATION FUND $191,013
10.555 NATIONAL SCHOOL LUNCH PROGRAM $57,836
84.196 EDUCATION FOR HOMELESS CHILDREN AND YOUTH $50,288
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $41,989
84.336 TEACHER QUALITY PARTNERSHIP GRANTS $33,626
15.151 EDUCATION ENHANCEMENTS $31,114
10.553 SCHOOL BREAKFAST PROGRAM $27,726
84.371 COMPREHENSIVE LITERACY DEVELOPMENT $26,000
15.149 FOCUS ON STUDENT ACHIEVEMENT $8,313
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $3,040
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $1,564
84.358 RURAL EDUCATION $1,381
10.560 STATE ADMINISTRATIVE EXPENSES FOR CHILD NUTRITION $1,024