Sicangu Oyate Ho, Inc.

EIN: 237116414

UEI: VHF9G87MG5Z5

Data as of August 23, 2026

Sicangu Oyate Ho, Inc.10 audit years35 findings28 repeat
10
Audit Years
35
Total Findings
28
Repeat Findings

FY 2025-06-30

Management decision deadline — for entities that funded this organization

The FAC accepted this audit on July 6, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by January 6, 2027 (136 days from today).

What is a management decision? →
2025-001
Other
MATERIAL WEAKNESSREPEAT

During our review of the School’s accounting records and internal control processes, we identified that internal controls over financial reporting were not adequately designed or effectively implemented. The School lacks an effective internal control structure over its year-end financial close and reporting process, including controls over the timely and accurate recording and reconciliation of unearned revenue, grant receivable, and capital assets. Audit adjustments were recorded for unearned revenue, grant revenue, and accounts receivable to correct material misstatements identified during testing. Cause: The School’s policies and procedures related to financial reporting were not adequately established or implemented to ensure timely and accurate financial reporting. There was a lack of established internal controls and procedures over accounting records. The School staff did not ensure that all of the required documentation and procedures were in place. Effect: The lack of implementing adequate policies and procedures over accounting records may result in nonauthorized or incorrect calculation of invoices. Also, the probability that fraud or material errors will occur and go undetected generally increases. Without established and adequate internal controls over financial reporting and year-end reconciliation procedures, the School's balances lack certainty about the accuracy of the balances. Auditor's Recommendation: We recommend management to design and implement effective internal control procedures to ensure the accuracy and completeness of the general ledger and financial statements.

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2025-001 Internal Control over Financial Reporting and Accounting Records (Material Weakness) - Repeated and Modified (Prior Year Finding 2024-001) Criteria or Specific Requirements: According to generally accepted accounting principles (GAAP), the School management is responsible for establishing and maintaining a system of internal controls over financial reporting. The School’s systems of internal controls must extend beyond the cash basis general ledger and the supporting schedules prepared by the School; rather, it must also include controls over the GAAP basis financial statements to ensure that a material misstatement would be prevented and/or detected. The School's management is responsible for the design and implementation of internal controls over the recording of activity in the accounting records, account balances, and financial statement disclosures. This internal control structure is established to ensure misstatements in the financial statements are prevented and/or detected. Maintenance of adequate supporting documentation is an integral part of a sound internal control system to safeguard assets and accomplish timely preparation and submission of financial reports. Good accounting and internal control practices require that all transactions must originate with authorizing documents and be supported by properly approved documents such as purchase orders, bills, petty cash reimbursement forms, payroll and time records, contracts, or other supporting documents. Additionally, regular and timely reconciliation of general ledger accounts to subsidiary ledgers and supporting documents is essential to ensure accuracy and integrity of financial information. Condition: During our review of the School’s accounting records and internal control processes, we identified that internal controls over financial reporting were not adequately designed or effectively implemented. The School lacks an effective internal control structure over its year-end financial close and reporting process, including controls over the timely and accurate recording and reconciliation of unearned revenue, grant receivable, and capital assets. Audit adjustments were recorded for unearned revenue, grant revenue, and accounts receivable to correct material misstatements identified during testing. Cause: The School’s policies and procedures related to financial reporting were not adequately established or implemented to ensure timely and accurate financial reporting. There was a lack of established internal controls and procedures over accounting records. The School staff did not ensure that all of the required documentation and procedures were in place. Effect: The lack of implementing adequate policies and procedures over accounting records may result in nonauthorized or incorrect calculation of invoices. Also, the probability that fraud or material errors will occur and go undetected generally increases. Without established and adequate internal controls over financial reporting and year-end reconciliation procedures, the School's balances lack certainty about the accuracy of the balances. Auditor's Recommendation: We recommend management to design and implement effective internal control procedures to ensure the accuracy and completeness of the general ledger and financial statements.

Corrective Action Plan

Management Response: Management agrees with the finding and is committed to strengthening internal controls over financial reporting. We have discussed updating what we can complete in house to improve documentation, reconciliations and staff training. We use an outside accounting firm to provide accounting oversight and financial reporting, the firm provides technical expertise, reviews financial records for accuracy and completeness, assists with financial preparation and offers guidance on compliance with applicable accounting standards and regulatory requirements. Anticipated Completion Date: Immediately upon the start of the new Fiscal Year on July 1. Management anticipates full implementation by June 30, 2027. Responsible Party: Business Manager, Accounting Tech and the outside Accounting Firm.

Prior Finding References

2024-001

About Other →
2025-002
Other
REPEAT

The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2026). Cause: The School was unable to provide the necessary audit documentation timely due to improper record retention. Effect: Noncompliance with the Office of Management and Budget’s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high-risk status by a federal and/or state agency. Auditor's Recommendation: Management should develop and implement policies regarding the retention of records and audit documentation.

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2025-002 Late Single Audit Submission - (Significant Deficiency) - Repeated (Prior Year Finding 2024- 002) Criteria or Specific Requirements: Section 200.512(a)(1) Report Submission of the Office of Management and Budget’s Uniform Guidance outlines the following requirement: “The audit must be completed, and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period.” Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2026). Cause: The School was unable to provide the necessary audit documentation timely due to improper record retention. Effect: Noncompliance with the Office of Management and Budget’s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high-risk status by a federal and/or state agency. Auditor's Recommendation: Management should develop and implement policies regarding the retention of records and audit documentation.

Corrective Action Plan

Management Response: Management acknowledges the audit finding related to the late submission of the Single Audit, which was identified as a significant deficiency. We recognize the importance of timely submission in accordance with federal audit requirements and applicable regulatory deadlines. Management has evaluated the audit timeline process and identified delays in the coordination of year-end financial reporting, supporting documentation, and audit fieldwork completion. We have reviewed our processes for fiscal year end closing and are committed to ensuring timely completion and submission of future Single Audits. Anticipated Completion Date: Immediately upon the start of the new Fiscal Year on July 1.Management anticipates full implementation by July 30, 2027. Responsible Party: All Business Office Staff. 39

Prior Finding References

2024-002

About Other →
2025-003
Activities Allowed or Unallowed
REPEAT

During our review of internal controls over payroll processing, we selected 194 payroll transactions across seven major programs for testing. Exceptions were identified in 7 transactions. The School did not fully comply with its own adopted policies or applicable federal regulations concerning payroll documentation and processing. Cause: The deficiencies appear to be due to a lack of consistent personnel file maintenance and insufficient internal controls over payroll documentation, record retention, and post-hiring compliance reviews. Effect: The lack of complete personnel documentation increases the risk of charging unallowable or unsupported costs to federal awards. It also affects the ability to verify employee eligibility, compensation accuracy, and the proper use of federal funds, potentially resulting in questioned costs and potential repayment obligations to granting agencies. Auditor's Recommendation: We recommend that the School implement enhanced internal controls and standardized procedures to ensure complete and accurate personnel records are maintained. This should include routine documentation checks to ensure that all required items, such as offer letters, contracts, paystubs, pay rate verifications, timesheets, and termination letters, are present and properly filed. Management should also provide training to relevant staff on federal compliance requirements related to payroll and personnel documentation.

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2025-003 Internal Control over Payroll – (Significant Deficiency) - Repeated and Modified (Prior Year Finding 2024-003) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2024; A24AV00744 U.S. Department of Interior Indian Schools Student Transportation 15.044 2024; A24AV00744 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2024; A24AV00744 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2024; A24AV00744 U.S. Department of Education Title I Grants to Local Educational Agencies 84.010 2024; A24AV00744 U.S. Department of Education Special Education Grants to States 84.027 2024; A24AV00744 U.S. Department of Education Education Stabilization Fund 84.425 2024; A24AV00744 Criteria or Specific Requirements: In accordance with 2 CFR § 200.302(b)(3) and § 200.430(i), recipients of federal funds must maintain documentation that supports the allowability and allocability of compensation costs. Personnel expenses must be supported by records that accurately reflect the work performed, and documentation must be maintained for each employee, including executed contracts, offer letters, pay rate approvals, timesheets, and separation documentation. Adequate support is necessary to demonstrate that federal funds were used in compliance with award conditions. Condition: During our review of internal controls over payroll processing, we selected 194 payroll transactions across seven major programs for testing. Exceptions were identified in 7 transactions. The School did not fully comply with its own adopted policies or applicable federal regulations concerning payroll documentation and processing. Cause: The deficiencies appear to be due to a lack of consistent personnel file maintenance and insufficient internal controls over payroll documentation, record retention, and post-hiring compliance reviews. Effect: The lack of complete personnel documentation increases the risk of charging unallowable or unsupported costs to federal awards. It also affects the ability to verify employee eligibility, compensation accuracy, and the proper use of federal funds, potentially resulting in questioned costs and potential repayment obligations to granting agencies. Auditor's Recommendation: We recommend that the School implement enhanced internal controls and standardized procedures to ensure complete and accurate personnel records are maintained. This should include routine documentation checks to ensure that all required items, such as offer letters, contracts, paystubs, pay rate verifications, timesheets, and termination letters, are present and properly filed. Management should also provide training to relevant staff on federal compliance requirements related to payroll and personnel documentation.

Corrective Action Plan

Management Response: Management agrees with the audit finding regarding internal controls over payroll. To strengthen payroll controls and ensure the accuracy and integrity of payroll processing, the organization has implemented and will continue to enhance the following procedures: Payroll is processed based on approved employee contracts, work agreements and authorized timesheets. Supervisors are responsible for reviewing and approving employee timesheets before payroll is processed. We have a new payroll manager who is ensuring that all required documentation is on file and works closely with the HR Department. We acknowledge that HR Files were incomplete due to previous staff disassembling files for HR Audits and not replacing documents to original folders. Anticipated Completion Date: In process for FY2026, we have a new payroll manager and HR Director that started in May of 2025 and both are ensuring all proper documentation is in place. Management anticipates full implementation by June 30, 2026. Responsible Party: Business Manager, Payroll Manager, Accounting Tech & HR Director.

Prior Finding References

2024-003

About Activities Allowed or Unallowed →
2025-004
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT

The School was unable to locate records indicating character investigations had been performed for two out of ten employees in positions that involve regular contact with children. Cause: The School did not adhere to written policy regarding the storage of character investigation. Effect: The School is not in compliance with the Indian Child Protection and Family Violence Prevention Act requirements. Auditor's Recommendations: The School should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Indian Child Protection and Family Violence Prevention Act.

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2025-004 Special Tests and Provisions Compliance Requirement (Material Weakness) - Repeated and Modified (Prior Year Finding 2024-004) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2024; A24AV00744 U.S. Department of Interior Indian Schools Student Transportation 15.044 2024; A24AV00744 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2024; A24AV00744 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2024; A24AV00744 U.S. Department of Education Title I Grants to Local Educational Agencies 84.010 2024; A24AV00744 U.S. Department of Education Special Education Grants to States 84.027 2024; A24AV00744 U.S. Department of Education Education Stabilization Fund 84.425 2024; A24AV00744 Criteria or Specific Requirement: In accordance with the Indian Child Protection and Family Violence Prevention Act, the School is required to conduct an investigation of the character of each individual who is employed or is being considered for employment by the School in a position that involves regular contact with or control over Indian children. The individual should be re-investigated 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: The School was unable to locate records indicating character investigations had been performed for two out of ten employees in positions that involve regular contact with children. Cause: The School did not adhere to written policy regarding the storage of character investigation. Effect: The School is not in compliance with the Indian Child Protection and Family Violence Prevention Act requirements. Auditor's Recommendations: The School should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Indian Child Protection and Family Violence Prevention Act.

Corrective Action Plan

Management Response: Management acknowledges the audit finding related to Special Tests and Provisions requirements for Federal programs. We recognize the importance of adhering to all applicable federal regulations, grant requirements, and program-specific compliance standards. We have new HR Personnel who are committed to ensuring all files are up to date and all background checks have been completed for all personnel. As previously stated Personnel files were disassembled by previous Management and not replaced. Our HR Staff have worked diligently on an HR File Audit to ensure all documents are in place and that we are in compliance with the Indian Child Protection and Family Violence Prevention Act. Anticipated Completion Date: In process already for the current fiscal year (2026), Management anticipates full implementation by August 31, 2026. Management is monitoring progress and ensuring timely completion, we have four (4) Certified background screeners and adjudicators on staff aside from using an outside adjudicator to complete background checks and adjudication. Responsible Party: Business Manager, HR Director and staff.

Prior Finding References

2024-004

About Special Tests and Provisions →

FY 2024-06-30

FAC accepted this audit on August 19, 2025 — management decision was due February 19, 2026.

2024-001
Other
MATERIAL WEAKNESSREPEAT

During our review of the School’s accounting records and internal control processes, we identified that internal controls over financial reporting were not adequately designed or effectively implemented. The School lacks an effective internal control structure over its year-end financial close and reporting process, including controls over the timely and accurate recording and reconciliation of unearned revenue, grant revenue, and accounts receivable. The following exceptions were noted:  Bank reconciliations were not reviewed or cleared on a timely basis throughout the fiscal year.  For 15 search for unrecorded liabilities samples reviewed, it was observed that the cut-off procedure for 4 samples was not followed, leading to the inaccurate recording of current fiscal year expenses.  Audit adjustments were recorded for unearned revenue, grant revenue, and accounts receivable to correct material misstatements identified during testing. Cause: The School’s policies and procedures related to financial reporting were not adequately established or implemented to ensure timely and accurate financial reporting. There was a lack of established internal controls and procedures over accounting records. The School staff did not ensure that all of the required documentation and procedures were in place. Effect: The lack of implementing adequate policies and procedures over accounting records may result in nonauthorized or incorrect calculation of invoices. Also, the probability that fraud or material errors will occur and go undetected generally increases. Without established and adequate internal controls over financial reporting and year-end reconciliation procedures, the School's balances lack certainty about accuracy of the balances. Auditor's Recommendation: We recommend management to design and implement effective internal control procedures to ensure the accuracy and completeness of the general ledger and financial statements. Management should ensure timely completion of bank reconciliations to effectively monitor cash balances. We recommend that the management reaffirm adherence to approved policies and procedures regarding the process of journal entries.

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2024-001 Internal Control over Financial Reporting and Accounting Records (Material Weakness) - Repeated and Modified (Prior Year Finding 2023-001) Criteria or Specific Requirements: According to generally accepted accounting principles (GAAP), the School management is responsible for establishing and maintaining a system of internal controls over financial reporting. The School’s systems of internal controls must extend beyond the cash basis general ledger and the supporting schedules prepared by the School; rather, it must also include controls over the GAAP basis financial statements to ensure that a material misstatement would be prevented and/or detected. The School's management is responsible for the design and implementation of internal controls over the recording of activity in the accounting records, account balances, and financial statement disclosures. This internal control structure is established to ensure misstatements in the financial statements are prevented and/or detected. Maintenance of adequate supporting documentation is an integral part of a sound internal control system to safeguard assets and accomplish timely preparation and submission of financial reports. Good accounting and internal control practices require that all transactions must originate with authorizing documents and be supported by properly approved documents such as purchase orders, bills, petty cash reimbursement forms, payroll and time records, contracts, or other supporting documents. Additionally, regular and timely reconciliation of general ledger accounts to subsidiary ledgers and supporting documents is essential to ensure accuracy and integrity of financial information. Condition: During our review of the School’s accounting records and internal control processes, we identified that internal controls over financial reporting were not adequately designed or effectively implemented. The School lacks an effective internal control structure over its year-end financial close and reporting process, including controls over the timely and accurate recording and reconciliation of unearned revenue, grant revenue, and accounts receivable. The following exceptions were noted:  Bank reconciliations were not reviewed or cleared on a timely basis throughout the fiscal year.  For 15 search for unrecorded liabilities samples reviewed, it was observed that the cut-off procedure for 4 samples was not followed, leading to the inaccurate recording of current fiscal year expenses.  Audit adjustments were recorded for unearned revenue, grant revenue, and accounts receivable to correct material misstatements identified during testing. Cause: The School’s policies and procedures related to financial reporting were not adequately established or implemented to ensure timely and accurate financial reporting. There was a lack of established internal controls and procedures over accounting records. The School staff did not ensure that all of the required documentation and procedures were in place. Effect: The lack of implementing adequate policies and procedures over accounting records may result in nonauthorized or incorrect calculation of invoices. Also, the probability that fraud or material errors will occur and go undetected generally increases. Without established and adequate internal controls over financial reporting and year-end reconciliation procedures, the School's balances lack certainty about accuracy of the balances. Auditor's Recommendation: We recommend management to design and implement effective internal control procedures to ensure the accuracy and completeness of the general ledger and financial statements. Management should ensure timely completion of bank reconciliations to effectively monitor cash balances. We recommend that the management reaffirm adherence to approved policies and procedures regarding the process of journal entries.

Corrective Action Plan

Management Response: Our CPA will train our Accounting Tech to complete bank reconciliations. A huge part of the GL not being updated is due to credit card expenditures and not utilizing the software to update when there is credit card usage. We will begin using the School Accounting Software to track credit card expenditures so we won't have to wait until we get credit card statements to reconcile. Anticipated Completion Date: September 30, 2025 - we will begin utilizing the credit card feature in the Accounting Software immediately. Responsible Party: Accounts Payable Personnel; Accounting Tech will work with CPA's ; Business Manager will have oversight for completion.

Prior Finding References

2023-001

About Other →
2024-002
Other
REPEAT

The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2025). Cause: The School was unable to provide necessary audit documentation timely due to improper record retention. Effect: Noncompliance with the Office of Management and Budget’s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high-risk status by a federal and/or state agency. Auditor's Recommendation: Management should develop and implement policies regarding the retention of records and audit documentation.

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2024-002 Late Single Audit Submission (Significant Deficiency) - Repeated (Prior Year Finding 2023- 002) Criteria or Specific Requirements: Section 200.512(a)(1) Report Submission of the Office of Management and Budget’s Uniform Guidance outlines the following requirement: “The audit must be completed, and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period.” Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2025). Cause: The School was unable to provide necessary audit documentation timely due to improper record retention. Effect: Noncompliance with the Office of Management and Budget’s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high-risk status by a federal and/or state agency. Auditor's Recommendation: Management should develop and implement policies regarding the retention of records and audit documentation.

Corrective Action Plan

Management Response: Our CPA will train our Accounting Tech to complete bank reconciliations. A huge part of the GL not being updated is due to credit card expenditures and not utilizing the software to update when there is credit card usage. We will begin using the School Accounting Software to track credit card expenditures so we won't have to wait until we get credit card statements to reconcile. Anticipated Completion Date: September 30, 2025 - we will begin utilizing the credit card feature in the Accounting Software immediately. Responsible Party: Accounts Payable Personnel; Accounting Tech will work with CPA's ; Business Manager will have oversight for completion.

Prior Finding References

2023-002

About Other →
2024-003
Other

During our review of internal controls over payroll processing, we selected 102 payroll transactions across four major programs. The School did not fully comply with its own adopted policies or applicable federal regulations concerning payroll documentation and processing. The following exceptions were identified:  Termination letters were not provided for 5 samples.  Adequate supporting document was not provided for 1 sample.  Timesheet was not provided for 1 sample. Cause: The deficiencies appear to be due to a lack of consistent personnel file maintenance and insufficient internal controls over payroll documentation, record retention, and post-hiring compliance reviews. Effect: The lack of complete personnel documentation increases the risk of charging unallowable or unsupported costs to federal awards. It also affects the ability to verify employee eligibility, compensation accuracy, and the proper use of federal funds, potentially resulting in questioned costs and potential repayment obligations to granting agencies. Auditor's Recommendation: We recommend that the School implement enhanced internal controls and standardized procedures to ensure complete and accurate personnel records are maintained. This should include routine documentation checks to ensure that all required items, such as offer letters, contracts, paystubs, pay rate verifications, timesheets, and termination letters, are present and properly filed. Management should also provide training to relevant staff on federal compliance requirements related to payroll and personnel documentation.

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2024-003 Internal Controls over Payroll – (Significant Deficiency) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2023; A23AV00801 U.S. Department of Interior Indian Schools Student Transportation 15.044 2023; A23AV00801 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2023; A23AV00801 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2023; A23AV00801 Criteria or Specific Requirements: In accordance with 2 CFR § 200.302(b)(3) and § 200.430(i), recipients of federal funds must maintain documentation that supports the allowability and allocability of compensation costs. Personnel expenses must be supported by records that accurately reflect the work performed, and documentation must be maintained for each employee, including executed contracts, offer letters, pay rate approvals, timesheets, and separation documentation. Adequate support is necessary to demonstrate that federal funds were used in compliance with award conditions. Condition: During our review of internal controls over payroll processing, we selected 102 payroll transactions across four major programs. The School did not fully comply with its own adopted policies or applicable federal regulations concerning payroll documentation and processing. The following exceptions were identified:  Termination letters were not provided for 5 samples.  Adequate supporting document was not provided for 1 sample.  Timesheet was not provided for 1 sample. Cause: The deficiencies appear to be due to a lack of consistent personnel file maintenance and insufficient internal controls over payroll documentation, record retention, and post-hiring compliance reviews. Effect: The lack of complete personnel documentation increases the risk of charging unallowable or unsupported costs to federal awards. It also affects the ability to verify employee eligibility, compensation accuracy, and the proper use of federal funds, potentially resulting in questioned costs and potential repayment obligations to granting agencies. Auditor's Recommendation: We recommend that the School implement enhanced internal controls and standardized procedures to ensure complete and accurate personnel records are maintained. This should include routine documentation checks to ensure that all required items, such as offer letters, contracts, paystubs, pay rate verifications, timesheets, and termination letters, are present and properly filed. Management should also provide training to relevant staff on federal compliance requirements related to payroll and personnel documentation.

Corrective Action Plan

Management Response: We have had significant turnover in HR and Payroll and documentation was not maintained properly. We have a new HR Director and new Payroll Manager who will work closely together and are aware of record keeping and maintaining files for compliance. A checklist has been created to ensure all required documents are on file. Anticipated Completion Date: We are conducting a file review and will ensure all documents are in order by September 30, 2025. Responsible Party: HR Director, Payroll Manager, Benefits Coordinator and Business Manager will have oversight.

About Other →
2024-004
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT

The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Cause: The School did not adhere to written policy regarding the storage of character investigation. Effect: The School is not in compliance with the Indian Child Protection and Family Violence Prevention Act requirements. Auditor's Recommendations: The School should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Indian Child Protection and Family Violence Prevention Act.

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2024-004 Special Tests and Provisions Compliance Requirement (Material Weakness) - Repeated and Modified (Prior Year Finding 2023-003) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2023; A23AV00801 U.S. Department of Interior Indian Schools Student Transportation 15.044 2023; A23AV00801 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2023; A23AV00801 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2023; A23AV00801 U.S. Department of Education Title I Grants to Local Educational Agencies 84.010 2023; A23AV00801 U.S. Department of Education Special Education Grants to States 84.027 2023; A23AV00801 U.S. Department of Education Education Stabilization Fund 84.425 2023; A23AV00801 Criteria or Specific Requirement: In accordance with the Indian Child Protection and Family Violence Protection Act, the School is required to conduct an investigation of the character of each individual who is employed or is being considered for employment by the School in a position that involves regular contact with or control over Indian children. The individual should be re-investigated 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: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Cause: The School did not adhere to written policy regarding the storage of character investigation. Effect: The School is not in compliance with the Indian Child Protection and Family Violence Prevention Act requirements. Auditor's Recommendations: The School should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Indian Child Protection and Family Violence Prevention Act.

Corrective Action Plan

Management Response: With new procedures in place when accepting applications a drug test, finger prints and background checks are completed prior to hiring. We utilize and outside adjudicator to conduct an investigation and adjudicate the backgrounds and provide a report to the Superintendent in a timely manner. Anticipated Completion Date: On going process, a file review is being completed to ensure current files and backgrounds have been completed and updated. Anticipated completion by September 30, 2025. Responsible Party: HR Director, Payroll Manager, Benefits Coordinator and Business Manager will have oversight.

Prior Finding References

2023-003

About Special Tests and Provisions →

FY 2023-06-30

FAC accepted this audit on April 5, 2024 — management decision was due October 5, 2024.

2023-002
Other
REPEAT

The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2024). Cause: The School was unable to provide necessary audit documentation timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget’s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Auditor's Recommendation: Management should develop and implement policies regarding the retention of records and audit documentation.

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2023-002 Late Single Audit Submission (Significant Deficiency) - Repeated and Modified (Prior Year Finding 2022-004) Criteria or Specific Requirement: Section 200.512(a)(1) Report Submission of the Office of Management and Budget’s Uniform Guidance outlines the following requirement: “The audit must be completed and the data collection form must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period.” Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2024). Cause: The School was unable to provide necessary audit documentation timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget’s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Auditor's Recommendation: Management should develop and implement policies regarding the retention of records and audit documentation.

Corrective Action Plan

Management Response: The School will ensure that the Single Audit reporting package is completed and submitted within the timeline as required by Uniform Guidance. Anticipated Completion Date: March 31, 2025 Responsible Party: Maria Walking Eagle, Business Manager

Prior Finding References

2022-004

About Other →
2023-003
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT

The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Cause: Turnover in School adjudicators led to a lapse in the required performance and documentation of background investigations. The School did not adhere to written policy regarding the storage of character investigation. Effect: The School is not in compliance with the Indian Child Protection and Family Violence Prevention Act requirements. Auditor's Recommendations: The School should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Indian Child Protection and Family Violence Prevention Act.

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2023-003 Special Tests and Provisions Compliance Requirement (Material Weakness) - Repeated and Modified (Prior Year Finding 2022-001) Federal Program Information: Funding Agency Title Federal Assistance Listing Number(s) Award Year and Number U.S. Department of Interior Indian School Equalization Program 15.042 2022; A22AV00769 U.S. Department of Interior Indian Schools Student Transportation 15.044 2022; A22AV00769 U.S. Department of Interior Administrative Cost Grants for Indian Schools 15.046 2022; A22AV00769 U.S. Department of Interior Indian Education Facilities, Operations, and Maintenance 15.047 2022; A22AV00769 U.S. Department of Education Title I Grants to Local Educational Agencies 84.010 2022; A22AV00769 U.S. Department of Education Special Education Grants to States 84.027 2022; A22AV00769 U.S. Department of Education Education Stabilization Fund 84.425 2022; A22AV00769 Criteria or Specific Requirement: In accordance with the Indian Child Protection and Family Violence Protection Act, the School is required to conduct an investigation of the character of each individual who is employed or is being considered for employment by the School in a position that involves regular contact with, or control over, Indian children. The individual should be re-investigated 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: The School was unable to locate records indicating character investigations had been performed for all employees in positions that involve regular contact with children. Cause: Turnover in School adjudicators led to a lapse in the required performance and documentation of background investigations. The School did not adhere to written policy regarding the storage of character investigation. Effect: The School is not in compliance with the Indian Child Protection and Family Violence Prevention Act requirements. Auditor's Recommendations: The School should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the Indian Child Protection and Family Violence Prevention Act.

Corrective Action Plan

Management Response: Local background checks were completed, however when a consultant was hired to complete the federal background checks, the files were stalled at the adjudicator’s office in Albuquerque, NM due to some billing issues with the Tribe. We have 3 trained staff who are certified adjudicators however it was recommended to use an outside adjudicator and we were able to locate someone locally who agreed to perform the federal background checks. Anticipated Completion Date: Currently in progress March 31, 2024 Responsible Party: Troy Lunderman, HR Director Leah Running Bear, HR Assistant Independent adjudicator Jodee Wike

Prior Finding References

2022-001

About Special Tests and Provisions →

FY 2022-06-30

FAC accepted this audit on July 31, 2023 — management decision was due January 31, 2024.

2022-001
Special Tests & Provisions
REPEAT

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.

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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.

Corrective Action Plan

2022-001 Character Investigations (Compliance) (repeat finding 2021-003) Recommendation: Implement existing policies that reflect the requirements of the Indian Child Protection and Family Violence Act. Action Taken: Our Job Applications state that background checks and fingerprinting will take place due the Indian Child Protection and Family Violence Act. It is also in our personnel policies that we follow the guidelines.

Prior Finding References

2021-003

About Special Tests and Provisions →
2022-002
Other
MATERIAL WEAKNESS

The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.

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2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. (repeat finding 2021-002) Condition: SF-425?s were not filed within 90 calendar days of the fiscal year end. Criteria: Section 200.329(c)(1) Monitoring and Reporting Program Performance of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The non-Federal entity must submit performance reports at the interval required by the Federal awarding agency or pass-through entity to best inform improvements in program outcomes and productivity. Intervals must be no less frequent than annually nor more frequent than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes. Reports submitted annually by the non-Federal entity and/or pass-through entity must be due no later than 90 calendar days after the reporting period. Reports submitted quarterly or semiannually must be due no later than 30 calendar days after the reporting period. Alternatively, the Federal awarding agency or pass-through entity may require annual reports before the anniversary dates of multiple year Federal awards. The final performance report submitted by the non-Federal entity and/or pass-through entity must be due no later than 120 calendar days after the period of performance end date.? Section 24(G) of the School?s Accounting Policies and Procedures Manual states, ?All financial reports to funding agencies will be submitted on a timely basis.? Section 24(D) of the School?s Accounting Policies and Procedures Manual states, ?The accountant will be responsible for preparing all financial reports accurately and on a timely basis. The accountant will also be responsible for the timely submission of the financial reports to the funding agencies.? Cause: Management of the School did not adhere to written policy. Effect: The School is not in compliance with the OMB Uniform Guidance. Recommendation: Implement adopted policies requiring the filing of SF-425?s within 90 calendar days of fiscal year end. Views of Responsible Officials and Planned Corrective Actions: See Corrective Action Plan.

Corrective Action Plan

2022-002 Missing Personnel Files (Material Weakness) New Finding This Year Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Action Taken: Due to the absence of the HR Generalist who was involved in a motorcycle accident in the midst of putting together all personnel files as recommended by the BIA records review, there were documents that were not filed immediately. We have created a checklist to ensure all files are complete and all documents filed in a timely manner. In 2020 when the building was undergoing renovation many of the personnel files were placed in storage and upon arrival of the new management team we had to recover and replace many missing documents. Thus creating a checklist to ensure each personnel file is complete.

About Other →
2022-003
Cost Allowability
MATERIAL WEAKNESS

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.

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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.

Corrective Action Plan

2022-003 Payroll (Material Weakness) New Finding This Year Recommendation: Management should restrict payroll module access to those with a logical need for such access. Action Taken: St. Francis Indian School has checks and balances in place when changes need to be made in the payroll module. The only employees who have access are those who need to input data and make changes such as Human Resources and of course Payroll.

About Allowable Costs / Cost Principles →
2022-004
Reporting

The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.

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2022-004 Late Single Audit Submission (Compliance) New Finding This Year Condition: The School did not submit the single audit reporting package to the Federal Audit Clearinghouse within nine months following their fiscal year-end as required (deadline of March 31, 2023). Criteria: Section 200.512(a)(1) Report Submission of the Office of Management and Budget?s Uniform Guidance outlines the following requirement: ?The audit must be completed and the data collection form [?] must be submitted within the earlier of 30 calendar days after receipt of the auditor?s report(s), or nine months after the end of the audit period.? Cause: The School was unable to provide necessary audit documentation (employment contracts) timely due to improper record retention. Effect: Non-compliance with the Office of Management and Budget?s Uniform Guidance. Potential reduction or delay in federal and state funding as well as the effects of being placed on high risk status by a federal and/or state agency. Recommendation: Management develop and implement policies regarding the retention of employment contracts. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan. New Finding This Year Condition: The School was unable to locate 4 of 24 personnel files selected for testing. However, essential personnel file documents were eventually located and furnished to auditors. Criteria: Part 3 Chapter 2 Section 2 of the School?s Personnel Policies states, ?The Superintendent/CEO or his or her designee shall maintain personnel records for all employees.? Section 200.334 Retention Requirements for Records of the Office of Management and Budget?s Uniform Guidance states, ?Financial records, supporting documents, statistical records, and all other non-Federal entity records pertinent to a Federal award must be retained for a period of three years from the date of submission of the final expenditure report or, for Federal awards that are renewed quarterly or annually, from the date of the submission of the quarterly or annual financial report, respectively, as reported to the Federal awarding agency or pass-through entity in the case of a subrecipient.? Cause: Management of the School did not adhere to written policy regarding the storage of personnel files (record retention). Effect: The School is not in adherence with written policy and in danger of not being in compliance with the Office of Management and Budget?s Uniform Guidance. Essential personnel file documents were located and furnished to auditors. Without these payroll costs charged to federal programs would have been questioned. Recommendation: Recommend adhering to adopted policies regarding the retention of personnel files. Views of Responsible Official and Planned Corrective Actions: See Corrective Action Plan.

Corrective Action Plan

2022-004 Late Single Audit Submission (Compliance) New Finding This Year Recommendation: Management develop and implement policies regarding the retention of employment contracts. Action Taken: Due to the HR Generalist?s accident, the contracts were not filed in a timely manner in the employees personnel file. We have developed a checklist to ensure all the requirements are met on what needs to be filed immediately with signed copies to payroll for data entry. We are recommending that the school start utilizing Personnel Actions for those employees that do not require contracts per regulations.

About Reporting →

FY 2021-06-30

FAC accepted this audit on September 29, 2022 — management decision was due March 29, 2023.

2021-001
Equipment & Real Property
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2020-001

About Equipment and Real Property Management →
2021-002
Reporting
MATERIAL WEAKNESS
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2021-003
Special Tests & Provisions
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FY 2020-06-30

FAC accepted this audit on November 21, 2021 — management decision was due May 21, 2022.

2020-001
Equipment & Real Property
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2019-002

About Equipment and Real Property Management →
2020-002
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT
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2020-003
Reporting
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FY 2019-06-30

FAC accepted this audit on May 18, 2020 — management decision was due November 18, 2020.

2019-001
Cost Allowability
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2018-001

About Allowable Costs / Cost Principles →
2019-002
Equipment & Real Property
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2018-003

About Equipment and Real Property Management →
2019-003
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT
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FY 2018-06-30

FAC accepted this audit on March 28, 2019 — management decision was due September 28, 2019.

2014-001
Other
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2014-001

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2014-003
Equipment & Real Property
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2014-003

About Equipment and Real Property Management →
2014-005
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT
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FY 2017-06-30

FAC accepted this audit on March 26, 2018 — management decision was due September 26, 2018.

2014-001
Other
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2014-001

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2014-003
Equipment & Real Property
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2014-003

About Equipment and Real Property Management →
2014-004
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2014-004

About Special Tests and Provisions →
2014-005
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT
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FY 2016-06-30

FAC accepted this audit on January 16, 2018 — management decision was due July 16, 2018.

2014-001
Other
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2014-001

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2014-003
Equipment & Real Property
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2014-003

About Equipment and Real Property Management →
2014-004
Special Tests & Provisions
MATERIAL WEAKNESSREPEAT
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Prior Finding References

2014-004

About Special Tests and Provisions →
2014-005
Procurement & Suspension/Debarment
MATERIAL WEAKNESSREPEAT
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2014-007
Reporting
REPEAT
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Prior Finding References

2014-007

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