Finding Text
2022-001 Character Investigations (Compliance) (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. (repeat finding 2021-001) Condition: A physical inventory of all equipment and other long term assets owned by the School was not conducted and reconciled to the general fixed asset account group during the year. Criteria: Section 22(G) of the School?s Accountant Policies and Procedures Manual states, ?all equipment and other long term assets owned by the School must be recorded in the general fixed asset account group at cost.? Section 22(H) of the School?s Accountant Policies and Procedures Manual states,?a physical inventory will be taken every year of all equipment and other long term assets owned by the School or under the control of the School. The results of the physical inventory will be used to update the general fixed asset account group.? OMB Uniform Guidance ? 200.313 Equipment (d) (1) states ?Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the FAIN), who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sale price of the property? (d) (2) states ?A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and (d) (3) states ?A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated.? Cause: Management of the School did not adhere to written policy. Effect: Without verification via physical count, balances carried in the School?s fixed asset account group could be materially misstated. Also, the amount of insurance coverage paid for by the School could be excessive or inadequate if based on unsupported property listings. Recommendation: Implement adopted policies requiring the annual physical inventory of fixed assets and the use of the physical inventory to update the general fixed asset account group. Views of Responsible Officials and Planned Corrective Actions: See corrective action plan.