Finding Text
Repeat Finding: Yes, 2023‐002, 2022‐003
Program Name/Assistance Listing Title: Indian School Equalization
Assistance Listing Number: 15.042
Federal Agency: U.S. Department of the Interior
Federal Award Number: A23AV00864
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 School 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
School may employee 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
Timely background investigations were not retained for all employees.
Cause
School and federal policies were not always followed or controls were not in place to ensure timely
character investigations are performed and all adequate documentation is maintained. There has
been turnover in various key positions.
Effect
The School was not in compliance with the Indian Child Protection and Family Violence Prevention Act.
Context
The sample was not intended to be, and was not, a statistically valid sample. During our review of the
School’s character investigations, we noted the following:
•For 14 of 40 background investigations reviewed, the reinvestigation was not conducted prior to the expiration of the preceding investigation.
•For four of 40 background investigations reviewed, the investigation did not contain all supporting documentation.
Recommendation
The School should ensure adequate character investigations are performed in a timely manner and
documentation is maintained to achieve full compliance with the School’s policies and the Indian
Child Protection and Family Violence Prevention Act.
Views of Responsible Officials
See Corrective Action Plan.