Finding Text
Finding Number: 2025‐001 Repeat Finding: Yes, 2024‐001, 2023‐001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency(ies): U.S. Department of Interior Federal Award Number: A24AV00760 Pass‐Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions 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. In addition, the School did not properly document completed character reinvestigations for all employees. Cause School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely and properly documented. 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 the following: - For four of 25 character investigations reviewed, the five year reinvestigation was not completed within five years. Of the four character investigations, two were a repeat finding from the prior year audit. - For three of 25 character investigations reviewed, the School did not maintain evidence that the suitability determination was conducted. Although a character investigation was performed by the FBI and favorable results were communicated to the School, the Certification of Investigation and Adjudication form were not completed and signed by an appropriate adjudicating official until being informed by auditors. 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.