Finding Text
Findings and Questioned Costs Related to Federal Awards
Finding Number: 2023‐003
Repeat Finding: No
Program Name/Assistance Listing Title: Indian School Equalization
Assistance Listing Number: 15.042
Federal Agency: U.S Department of Interior
Federal Award Number: A22AV00871
Pass‐Through Agency: Bureau of Indian Affairs
Questioned Costs: N/A
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirement: Special Tests Provisions
Criteria
According to the Indian Child Protection and Family Violence Prevention 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 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).
Condition
Timely background investigations were not retained for all employees.
Cause
School policies were not always followed to ensure timely background investigation were performed.
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. For one of 39 employee
files reviewed, a character investigation was on file, but had not been performed timely. In addition,
for one of 39 employee files reviewed, the School did not maintain a copy of the original FBI
background investigation, and for one of 39 employees, there was no background check on file;
therefore, we were unable to determine if the investigation was performed timely or if the employee
was eligible for employment.
Recommendation
The School should ensure adequate character investigations are performed in a timely manner and
documentation is retained 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.
Page