Finding Text
Finding Number: 2023‐001
Repeat Finding: Yes, 2022‐001, 2021‐001
Program Name/Assistance Listing Title: Indian School Equalization Program
Assistance Listing Number: 15.042
Federal Agency: U.S Department of Interior
Federal Award Number: A22AV00793
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 Prevention Act 925 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 conduct with, or control over, Indian
children. The individual should be reinvestigated every five years. In addition, individuals in those
positions must meet the required standards of character no less stringent than those prescribed
under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFS part 63).
Condition
The School did not complete character reinvestigations timely for all employees.
Cause
School policies were not always followed and controls were not in place to ensure character
reinvestigations were performed timely.
Effect
The School was not in compliance with the Indian Child Protection and Family Violence Prevention
Act.
Context
During our review of the School’s character investigations, we noted the following:
For 10 of 30 character investigations reviewed, the five year reinvestigation was not
completed timely.
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The School should ensure character investigations are performed in a timely manner 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.
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