Finding 393772 (2022-001)

Significant Deficiency

Requirement

Questioned Costs

Year

2022

Accepted

2024-04-19

Audit: 303981

Organization: Little Wound School Board, Inc. (SD)

Auditor: Donna Denker & Associates

AI Summary

Core Issue: The School is not following the Indian Child Protection and Family Violence Prevention Act regarding employee background checks.
Impacted Requirements: Background checks must be completed every five years and adjudicated by a qualified official; 21 out of 41 files were found non-compliant.
Recommended Follow-Up: Implement an independent annual review of background files to ensure compliance and maintain proper adjudicator credentials.

Finding Text

Identification of Major Programs: This finding relates to all major programs. Criteria: 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: Our tests of the sample of background files disclosed 21 instances of no adjudications in the file, untimely background investigations and incomplete or missing adjudications or files. One of the expired background adjudications was for the School’s adjudicator. Context: We tested a sample of 41 files for current employees with 21 exceptions noted. Questioned Costs: None noted. Cause: Oversight of background checks was not being performed to ensure the School was complying with the 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. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: 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. The adjudicator must themselves have a independent clean adjudication on file with the School. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 39.

Corrective Action Plan

2022 Audit Findings: Character Investigations Recommendation: 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. The adjudicator must themselves have an independent clean adjudication on file with the school. Corrective Action Plan: At the completion of the audit, Human Resources office, whom both have clean adjudication certification, will adjudicate the incomplete background files to ensure that previous year files are updated and in compliance with the Indian Child Protection & Family Violence Prevention Act, as well as school policy. A plan to continue to be organized and keep a maintained filing system has already been set in place. Background files will be updated timely and adjudication will be prompt. Responsible party: Whisper Catches, Human Resource Director Planned Completion Date: July 01, 2024

Other Findings in this Audit

393773 2022-001

Significant Deficiency
393774 2022-001

Significant Deficiency
393775 2022-001

Significant Deficiency
393776 2022-001

Significant Deficiency
393777 2022-001

Significant Deficiency
393778 2022-001

Significant Deficiency
393779 2022-001

Significant Deficiency
393780 2022-001

Significant Deficiency
970214 2022-001

Significant Deficiency
970215 2022-001

Significant Deficiency
970216 2022-001

Significant Deficiency
970217 2022-001

Significant Deficiency
970218 2022-001

Significant Deficiency
970219 2022-001

Significant Deficiency
970220 2022-001

Significant Deficiency
970221 2022-001

Significant Deficiency
970222 2022-001

Significant Deficiency

Programs in Audit

ALN	Program Name	Expenditures
15.042	Indian School Equalization Program	$7.01M
15.062	Replacement and Repair of Indian Schools	$2.77M
84.010	Title I Grants to Local Educational Agencies	$2.33M
93.243	Substance Abuse and Mental Health Services_projects of Regional and National Significance	$2.18M
84.425	Education Stabilization Fund	$1.67M
15.046	Administrative Cost Grants for Indian Schools	$1.44M
84.027	Special Education_grants to States	$1.33M
15.044	Indian Schools_student Transportation	$1.09M
15.047	Indian Education Facilities, Operations, and Maintenance	$958,738
84.299	Indian Education -- Special Programs for Indian Children	$527,021
93.665	Emergency Grants to Address Mental and Substance Use Disorders During Covid-19	$490,161
15.043	Indian Child and Family Education	$341,317
84.060	Indian Education_grants to Local Educational Agencies	$223,302
15.149	Focus on Student Achievement Project	$206,175
84.336	Teacher Quality Partnership Grants	$199,500
93.587	Promote the Survival and Continuing Vitality of Native American Languages	$161,681
84.287	Twenty-First Century Community Learning Centers	$158,660
10.553	School Breakfast Program	$107,915
15.959	Education Program Management	$71,300
45.164	Promotion of the Humanities_public Programs	$68,005
84.101	Career and Technical Education - Grants to Native Americans and Alaska Natives	$28,514
10.575	Farm to School Grant Program	$19,745
10.582	Fresh Fruit and Vegetable Program	$16,021
10.555	National School Lunch Program	$11,972
10.558	Child and Adult Care Food Program	$10,584
84.358	Rural Education	$10,500
84.371	Striving Readers	$9,268
84.424	Student Support and Academic Enrichment Program	$1,296