Finding 1241282 (2023-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2026-10-28
Audit: 415407
Organization: Little Wound School Board, Inc. (SD)
Auditor: BLUEARROW CPA

AI Summary

  • Core Issue: Major programs are non-compliant due to incomplete background checks for employees working with Indian children.
  • Impacted Requirements: The Indian Child Protection and Family Violence Prevention Act mandates thorough background investigations every five years, which were not adequately documented.
  • Recommended Follow-Up: Implement an annual independent review of employee background files to ensure compliance and proper documentation.

Finding Text

Identification of Major Programs Affected: This finding relates to all major programs. The matter was identified through follow-up of prior-year Finding 2022-001 and remained unresolved during the current year audit. Criteria or Specific Requirement: The Indian Child Protection and Family Violence Prevention Act requires Indian tribes and tribal organizations that receive funds under the ISDEAA or the Tribally Controlled Schools Act to conduct an investigation of the character of each individual who is employed or is being considered for employment in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Condition: The School did not maintain sufficient documentation to demonstrate that required background investigations were properly completed for certain employees. For the employees tested, the documentation provided was incomplete and did not adequately support that the required background investigation and related review procedures had been performed. Cause: Oversight of background checks was not being performed to ensure the School complied with applicable requirements. The HR Director is in charge of the process but there is no oversight of the background system. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Auditor's Recommendations: We recommend the School implement an independent review of the employee background files at least annually to ensure background check files are being properly completed, updated and maintained.

Corrective Action Plan

Annual Independent Review: An individual independent of the day-to-day background check process will conduct an annual review of employee background investigation files to ensure required documentation is complete and properly maintained. 2. Five-Year Renewal Tracking: The Human Resources will maintain a tracking system to monitor the five-year background investigation requirement and ensure investigations are renewed timely. 3. Adjudication Documentation: The Human Resources will continue to verify that each required background investigation has been reviewed and adjudicated by an appropriately trained and qualified adjudicating official and that the adjudicator has a current adjudicated background check on file. 54 LITTLE WOUND SCHOOL BOARD, INC. CORRECTIVE ACTION PLAN FOR THE YEAR ENDED JUNE 30, 2023 4. File Documentation Checklist: The Human Resources currently has a standardized background investigation checklist to ensure required documentation is consistently included in each employee's file. 5. Ongoing Oversight: The Human Resources will establish a secondary review process so that compliance with background investigation requirements is not solely dependent upon one individual. Any deficiencies identified through the annual review will be documented and corrected in a timely manner. 6. Staff Training: All personnel responsible for background investigations and file maintenance will receive on-going training regarding applicable requirements, documentation standards, renewal requirements, and adjudication procedures. The School is committed to strengthening its internal controls and ensuring that employee background investigation records are complete, current, properly adjudicated, and maintained in accordance with applicable federal requirements. The School will use the annual independent review process to provide continued oversight and reduce the likelihood of similar findings in the future.

Categories

Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1241271 2023-002
    Material Weakness Repeat
  • 1241272 2023-002
    Material Weakness Repeat
  • 1241273 2023-002
    Material Weakness Repeat
  • 1241274 2023-002
    Material Weakness Repeat
  • 1241275 2023-002
    Material Weakness Repeat
  • 1241276 2023-002
    Material Weakness Repeat
  • 1241277 2023-003
    Material Weakness Repeat
  • 1241278 2023-003
    Material Weakness Repeat
  • 1241279 2023-003
    Material Weakness Repeat
  • 1241280 2023-003
    Material Weakness Repeat
  • 1241281 2023-003
    Material Weakness Repeat
  • 1241283 2023-004
    Material Weakness Repeat
  • 1241284 2023-004
    Material Weakness Repeat
  • 1241285 2023-004
    Material Weakness Repeat
  • 1241286 2023-004
    Material Weakness Repeat
  • 1241287 2023-004
    Material Weakness Repeat
  • 1241288 2023-004
    Material Weakness Repeat
  • 1241289 2023-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.042 INDIAN SCHOOL EQUALIZATION $7.45M
84.425 EDUCATION STABILIZATION FUND $4.21M
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $3.60M
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $2.31M
15.046 ADMINISTRATIVE COST GRANTS FOR INDIAN SCHOOLS $1.99M
84.027 SPECIAL EDUCATION GRANTS TO STATES $1.65M
15.044 INDIAN SCHOOLS STUDENT TRANSPORTATION $1.33M
15.047 INDIAN EDUCATION FACILITIES, OPERATIONS, AND MAINTENANCE $1.32M
93.665 EMERGENCY GRANTS TO ADDRESS MENTAL AND SUBSTANCE USE DISORDERS DURING COVID-19 $773,316
15.062 REPLACEMENT AND REPAIR OF INDIAN SCHOOLS $647,201
15.043 INDIAN CHILD AND FAMILY EDUCATION $372,349
10.555 NATIONAL SCHOOL LUNCH PROGRAM $272,349
84.299 INDIAN EDUCATION -- SPECIAL PROGRAMS FOR INDIAN CHILDREN $241,446
84.336 TEACHER QUALITY PARTNERSHIP GRANTS $203,600
84.299A Special Projects Demonstration Grants $150,166
15.149 FOCUS ON STUDENT ACHIEVEMENT $145,916
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $139,686
84.060 INDIAN EDUCATION GRANTS TO LOCAL EDUCATIONAL AGENCIES $129,900
84.101 CAREER AND TECHNICAL EDUCATION - GRANTS TO NATIVE AMERICANS AND ALASKA NATIVES $126,147
10.553 SCHOOL BREAKFAST PROGRAM $93,584
84.415 INDIAN EDUCATION NATIONAL ACTIVITIES (STATE TRIBAL EDUCATION PARTNERSHIP (STEP) AND NATIVE AMERICAN LANGUAGE (NAL) $65,908
84.377 SCHOOL IMPROVEMENT GRANTS $29,895
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $24,931
10.575 FARM TO SCHOOL GRANT PROGRAM $22,341
10.582 FRESH FRUIT AND VEGETABLE PROGRAM $19,166
10.558 CHILD AND ADULT CARE FOOD PROGRAM $17,086
84.358 RURAL EDUCATION $10,900
45.164 PROMOTION OF THE HUMANITIES PUBLIC PROGRAMS $5,122