Finding 58559 (2022-003)

Material Weakness
Requirement
B
Questioned Costs
-
Year
2022
Accepted
2023-07-31
Audit: 55377
Organization: Sicangu Oyate Ho, INC (SD)

AI Summary

  • Core Issue: The payroll manager has unrestricted access to the payroll system, leading to potential mismanagement of pay rates and leave balances.
  • Impacted Requirements: Failure to comply with OMB's internal control standards and the Indian Child Protection and Family Violence Act due to inadequate record-keeping for employee character investigations.
  • Recommended Follow-Up: Restrict payroll access based on necessity and ensure adherence to policies for character investigations to maintain compliance.

Finding Text

2022-003 Payroll (Material Weakness) New Finding This Year Condition: The payroll manager has unrestricted access to the payroll system and is able to change rates of pay and leave balances. Internal controls to mitigate segregation of duties issues are not effective. Retroactve changes to accrued PTO were made several times in FY22 to make corrections to past pay periods. Criteria: Section 200.303 Internal Controls of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ? The non-Federal entity 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. Cause: A lack of segregation of duties has resulted in the payroll manager having unrestricted access to the payroll system. Effective internal controls to mitigate the related risks have not been implemented. Effect: The School is at risk of not being in compliance with the OMB Uniform Guidance. This weakness in internal controls allows for potential misapplication of PTO and approved pay rates, which could result in unallowable expenditures being charged to federal programs. Recommendation: Management should restrict payroll module access to those with a logical need for such access. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan. (repeat finding 2021-003) Condition: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Criteria: The Office of Management and Budget?s (OMB) Compliance Supplement states, ?The Indian Child Protection and Family Violence 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).? Cause: Management of the School did not adhere to written policy regarding the storage of character investigations (record retention). Effect: The School is not in compliance with the Indian Child Protection and Family Violence Act. Employees who have regular contact with and control over children may not be suitable for such a position. Persons may be employed at the School who may have otherwise been precluded from employment based on a character investigation. Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.

Categories

Internal Control / Segregation of Duties Allowable Costs / Cost Principles Material Weakness Matching / Level of Effort / Earmarking

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
15.042 Indian School Equalization Program $5.41M
84.010 Title I Grants to Local Educational Agencies $2.45M
84.425 Education Stabilization Fund - Arp Act - Elementary K-12 Schools - Covid19 $2.13M
15.046 Administrative Cost Grants for Indian Schools $1.89M
15.047 Indian Education Facilities, Operations, and Maintenance $1.38M
84.425 Education Stabilization Fund - Crrsa Act - Elementary K-12 Schools - Covid19 $1.12M
84.027 Special Education_grants to States $959,937
15.044 Indian Schools_student Transportation $889,745
84.425 Education Stabilization Fund - Cares Act - Instruction - Covid19 $377,929
84.336 Teacher Quality Partnership Grants $374,966
15.043 Indian Child and Family Education $324,428
15.151 Education Program Enhancements $205,102
10.555 National School Lunch Program $196,109
84.060 Indian Education_grants to Local Educational Agencies $169,191
84.425 Education Stabilization Fund - Cares Act - It - Covid19 $110,578
15.130 Indian Education_assistance to Schools $84,871
10.553 School Breakfast Program $75,683
15.149 Focus on Student Achievement Project $49,374
84.196 Education for Homeless Children and Youth $18,893
84.358 Rural Education $7,047
10.582 Fresh Fruit and Vegetable Program $5,500