Finding Text
Finding 2024 – 008: Special Tests and Provisions (Compliance; Internal Controls Over Compliance) Significant Deficiency – 93.U01 Title V Criteria: The Title V contract requires the Organization to ensure employees whose duties involve regular contact with or control over Indian children comply with the personnel requirements established under the contract and Public Law 101-630, The Indian Child Protection and Family Violence Prevention Act. These requirements include completing required background investigations and maintaining executed confidentiality agreements, as applicable. Condition: During testing of ten employees subject to the Title V contract requirements, we noted that documentation supporting compliance with certain personnel requirements was not consistently maintained. Specifically, documentation of required background checks was not provided for two employees, and a signed confidentiality agreement was not provided for one employee. Questioned Costs: None. Cause: The Organization did not have adequate internal controls to ensure compliance with the Title V contract requirements, including procedures to verify that required personnel documentation was completed, maintained, and subject to supervisory review. Effect: Without adequate controls and supporting documentation, the Organization cannot demonstrate compliance with the Special Tests and Provisions of the Title V contract. As a result, there is an increased risk of noncompliance with the terms and conditions of the federal award. Recommendation: We recommend management review the Title V contract requirements and strengthen internal controls over compliance by implementing documented procedures and supervisory reviews to ensure required background checks and confidentiality agreements are completed, retained, and periodically monitored in accordance with the contract requirements. Views of Responsible Officials: See the corrective action plan that accompanies the schedule of findings and questioned costs.