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Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00933 N/A Education Stabilization Fund 84.425 A19AV00933 N/A Federal Agency: U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Activities Allowed or Unallowed, Allowable Costs/Cost Principles CRITERIA Hall management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure all financial activities are properly processed and reported. Additionally, the Hall is required, except where otherwise authorized by statute, to ensure costs meet the general criteria outlined in 2 CFR 200.403 in order to be allowable under federal awards, including the costs be necessary and reasonable for the performance of the federal award and be allocable thereto under these principles. Indian tribes and tribal organizations may without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (USC 46). These guidelines require internal controls over expenditures, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines. (25 CFR 39; 25 CFR 900). Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self-determination contract for purposes identified in 25?SC 450j-l(k), to the extent that the expenditure of the funds is supportive of a contracted program?25 USC 450j-l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 45; 25 CFR 900). CONDITION The Hall did not follow its Board adopted policies for federal regulations regarding disbursements and payroll to ensure all financial activities were properly processed, recorded in the appropriate fiscal year, and supported. CAUSE The Hall has not always implemented and followed controls over disbursement and payroll transactions. EFFECT The Hall was not in compliance with Board adopted policies for federal regulations and guidelines. CONTEXT The sample was not intended to be, and was not, a statistically valid sample. The following items were noted during our review of disbursement transactions: ? For one of 10 travel reimbursements reviewed, adequate backup was not retained to support the reimbursement. ? For one of 10 travel reimbursements reviewed, there was an overpayment of $33. ? For two of 45 disbursements reviewed, the goods or services were received prior to the issuance and approval of the purchase order. ? For two of 45 disbursements reviewed and two of 14 disbursements reviewed for cutoff, there was no receiving report received; therefore could not be determined if the goods or services were received prior to payment. ? For five of 14 cutoff selections reviewed, the expenditure was recorded in the fiscal year 2023 but should have been in fiscal year 2022. Audit adjustments were required to properly report the financial statements. ? For five of 45 disbursements reviewed, the goods or services were received after the payment was made. ? For one of 45 disbursements reviewed, the quantity on the receiving report did not match the purchase order. ? For one of 40 employee payrolls reviewed, the employee received backpay, but the Hall was unable to provide supporting documentation for the backpay. ? The Department of Treasury guidelines for using ARPA funds for hazard pay at a limit of $25,000 per employee. The Hall had three employees who exceeded this limit during the 2022 fiscal year. ? The Hall had a current year overexpenditure in the Education Stabilization Fund grant by $48,608. ? For one of 40 employee payrolls reviewed, the employee was overpaid by $160.55. RECOMMENDATION The Hall should adhere to its Board adopted policies and federal regulations and ensure all transactions are supported. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.