Finding Text
Finding 2025-004: 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, 2025 Repeat of Prior Year Finding 2024-005 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.