Finding 1200684 (2025-002)

Material Weakness Repeat Finding
Requirement
AB
Questioned Costs
-
Year
2025
Accepted
2026-03-30
Audit: 395714
Organization: American Horse School (SD)

AI Summary

  • Core Issue: The School charged $325,249 in board member payments to federal grants, which may not meet the criteria of being reasonable and necessary.
  • Impacted Requirements: Compliance with 2 CFR Part 200, Subpart E, which outlines the rules for allowable costs under federal awards.
  • Recommended Follow-Up: Review board member expenditures for compliance, provide training on payment approvals, and consider implementing an anonymous whistleblower hotline.

Finding Text

Finding #2025-002: Allowable Costs Charged to Administrative Cost Grants for Indian Schools Federal Program Affected: Administrative Cost Grants for Indian Schools, ALN 15.046 Compliance Requirement: Allowable Costs/Activities Allowed Questioned Costs: Yes. See table below for amounts charged to Board Services for the year ended June 30, 2025. Stipend $165,119 Bonus 51,435 Social Security/Medicare 16,582 Health Insurance 1,684 2% Fee 5 Board Expenses 20,619 Travel/Training 69,805 Total $325,249 Condition and Cause: During our engagement, we were made aware of expenditures to board members that were charged to Administrative Cost Grants for Indian Schools that may not be reasonable and necessary under applicable cost principles contained in 2 CFR Part 200, Subpart E. Specifically, the School charged $325,249 of payments to the federal program, consisting of board stipends, travel reimbursements, per diem payments, bonus, and fringe benefits. The School’s internal policy is to pay board members $250 per board meeting. Total expenditures under the Administrative Cost Grants for Indian School for the year ended June 30, 2025 were $994,330. We tested $152,104 of expenditures based audit sampling guidance. All expenditures tested were supported by underlying documentation such as approved payroll registers or invoices. Additionally, all payroll registers or invoices indicated multiple levels of review and approval. Criteria and Effect: Uniform Guidance, in 2 CFR Part 200, Subpart E establishes the rules for determining allowability of costs chargeable to federal awards, ensuring they are necessary, reasonable, allocable, and documented. Repeat Finding from Prior Year: No Recommendation: Expenditures made to board members should be reviewed for compliance under the Uniform Guidance, specifically, 2 CFR Part 200, Subpart E. Additionally, training for those reviewing and approving board payments should be provided. The board may also consider an anonymous whistleblower reporting hotline to provide employees or others with an option to anonymously report impropriety. Response/Corrective Action Plan: The School agrees with the above Finding. See Correction Action Plan.

Corrective Action Plan

Responsible Individual: Interim School Board Members Corrective Action Plan: The Interim Board of Directors will continue to monitor spending and expenditures charged to the Administrative Cost Grants for Indian Schools, until a newly elected Board of Directors is in place. The Interim Board will provide necessary training to the newly elected Board of Directors. Anticipated Completion Date: June 30, 2026

Categories

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Other Findings in this Audit

  • 1200683 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.042 INDIAN SCHOOL EQUALIZATION $2.94M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $1.26M
15.046 ADMINISTRATIVE COST GRANTS FOR INDIAN SCHOOLS $994,330
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $985,722
15.044 INDIAN SCHOOLS STUDENT TRANSPORTATION $708,642
15.043 INDIAN CHILD AND FAMILY EDUCATION $441,357
15.047 INDIAN EDUCATION FACILITIES, OPERATIONS, AND MAINTENANCE $423,308
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $248,046
84.027 SPECIAL EDUCATION GRANTS TO STATES $174,820
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $161,438
84.425R CORONAVIRUS RESPONSE AND RELIEF SUPPLEMENTAL APPROPRIATIONS ACT, 2021-EMERGENCY ASSISTANCE FOR NON-PUBLIC SCHOOLS (CRRSA EANS) PROGRAM $139,617
10.555 NATIONAL SCHOOL LUNCH PROGRAM $85,788
84.336 TEACHER QUALITY PARTNERSHIP GRANTS $53,975
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $51,476
10.553 SCHOOL BREAKFAST PROGRAM $48,950
84.371 COMPREHENSIVE LITERACY DEVELOPMENT $45,315
84.358 RURAL EDUCATION $4,010
15.151 EDUCATION ENHANCEMENTS $402