Finding 524400 (2021-007)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2021
Accepted
2025-02-24
Audit: 343636
Organization: Quileute Tribal School (WA)

AI Summary

  • Core Issue: The School failed to provide documentation for character investigations required for employees working with Indian children.
  • Impacted Requirements: This violates the Indian Child Protection and Family Violence Prevention Act and 2 CFR § 200.303 regarding internal controls.
  • Recommended Follow-Up: The School should implement effective internal controls for compliance with character investigation requirements and follow its Corrective Action Plan.

Finding Text

Program Information: U.S. Department of the Interior AL # Award Number Award Period Program Name 15.042 A19AV00888 7/1/2020-6/30/2021 Indian School Equalization Program Criteria: Character Investigations by Indian Tribes and Tribal Organizations Compliance Requirements: The Indian Child Protection and Family Violence Prevention Act (25 USC 3201 et seq.) 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 by such Indian tribe or tribal organization in a position that involves regular contact with, or control over, Indian children. The Act further states that the Indian tribe or tribal organization 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), as the Indian tribe or tribal organization establishes. 2 CFR § 200.303 - Internal controls states, the recipient and subrecipient must: Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition/Context: For 4 of the 4 samples selected for testing, the School did not provide support for review and approval of the Character Investigations. [ ] Compliance Finding [ ] Significant Deficiency [ X ] Material Weakness Cause: Lack of internal controls and management oversight. Effect: Without an effective internal control system an entity’s objective: operations, reporting, and compliance cannot be achieved. Questioned Costs: N/A. Repeat Finding: Yes, 2020-003. Recommendation: We recommend that the School establish effective internal controls for the Character Investigations compliance requirement and adhere to the internal controls. Views of Responsible Officials and Planned Corrective Action: Management agrees with the finding and has prepared corrective action as detailed in its Corrective Action Plan.

Corrective Action Plan

Persons responsible for corrective action: Bob Harmon, Superintendent Corrective Action: During the 2021 fiscal year there were superintendent vacancies. The School currently has a superintendent that is knowledgeable of this requirement. Implementation date: June 30, 2025

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring Material Weakness Reporting Significant Deficiency Matching / Level of Effort / Earmarking

Other Findings in this Audit

  • 524394 2021-003
    Material Weakness
  • 524395 2021-003
    Material Weakness
  • 524396 2021-004
    Material Weakness Repeat
  • 524397 2021-005
    Material Weakness Repeat
  • 524398 2021-005
    Material Weakness
  • 524399 2021-006
    Material Weakness
  • 1100836 2021-003
    Material Weakness
  • 1100837 2021-003
    Material Weakness
  • 1100838 2021-004
    Material Weakness Repeat
  • 1100839 2021-005
    Material Weakness Repeat
  • 1100840 2021-005
    Material Weakness
  • 1100841 2021-006
    Material Weakness
  • 1100842 2021-007
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
15.042 Indian School Equalization Program $827,317
15.046 Administrative Cost Grants for Indian Schools $456,591
84.027 Special Education Grants to States $449,604
15.047 Indian Education Facilities Operations and Maintenance $297,662
84.425 Covid-19 Bie K-12 Cares Act 2 $148,155
84.010 Title I Grants to Local Educational Agencies $136,120
84.287 21st Century $123,699
84.336 Title II Teacher Quality $90,315
10.559 Summer Food $48,532
15.044 Indian Schools Student Transportation $45,445
84.425 Covid-19 Bie Crrsa (cares 3) $8,910
15.151 Bie- 2019-2020 Enhancement $7,974
84.425 Covid-19 Bie- Geer Funding (cares 1) $7,875
15.062 Replacement and Repair of Indian Schools $-42
15.130 Johnson O'Malley $-1,123