Finding 969042 (2023-003)

Finding 2023-003 Material Weakness in Internal Control over Compliance – Eligibility Identification of federal program: 84.299 Indian Education - Special Programs for Indian Children Criteria or specific requirement: The Grant Award Notification states that the grantee must provide services to Indian students meeting the definition of Indian in section 6151 of ESEA. Condition: To ensure that Chugachmiut provides services only to eligible individuals Chugachmiut developed an internal policy in which the Program Manager reviews the participant's application, tribal affiliation, and personal statement of need prior to services being offered to the applicant. We noted that evidence of this review occurring was not retained by Chugachmiut Cause: Chugachmiut did not have controls in place to ensure that all documentation to support participant eligibility was retained. Effect or potential effect: Chugachmiut has a risk of potentially including ineligible participants in the program without sufficient documented oversight of participant applications. Questioned Costs: None Context: It was specifically noted that all participants who participated in the program were found to be eligible for program services. However, it was not evident that the control process established in Chugachmiut’s policies and procedures was operating and there does not appear to be a retention process for key eligibility documentation for the applicants and participants in the program. Identification of Repeat Finding: Not applicable. Recommendations: Management should implement a process to ensure that review of participant applications, participant interviews, and application documents are tracked and retained by Chugachmiut. Views of Responsible Officials: See Corrective Action Plan