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Finding Number: 2022-003 Repeat Finding: Yes, 2021-003 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Education Federal Award Number: A19AV00933 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 Protection Act (25 USC ?3201 et. sec.), the Hall must conduct a character investigation 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. The investigation should be reinvestigated every five years. The Act further states that the Hall may employ individuals in those positions only if the individuals meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63). CONDITION The Hall did not complete character investigations in a timely manner for all of its employees. CAUSE Hall policies were not always followed or controls were not in place to ensure timely character investigations are performed. EFFECT The Hall was not in compliance with the Indian Child Protection and Family Violence Protection Act. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. For two of nine background investigations reviewed, the Hall did not complete the federal background investigations timely after expiration. RECOMMENDATION The Hall should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Hall?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.