EIN: 450383691
UEI: CM3NZMDUSML7
Audited by: BRADY MARTZ
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 31, 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 October 1, 2026 (33 days from today).
What is a management decision? →Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Allowable Costs/Cost Principles Criteria Under 2 CFR Part 200, Subpart E, costs must not only be allowable but also necessary and reasonable for the performance of the federal award. ESSER funds are intended to address learning loss, support safe school operations, and respond to pandemic-related impacts; however, expenditures must still adhere to federal cost principles regarding reasonableness and prudent stewardship. Condition During our review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund, we identified certain costs that were aligned with allowable programmatic activities but appeared excessive in nature. While the expenditures supported educational or COVID-19 recovery objectives, the cost of certain items exceeded what would be considered reasonable for the intended benefit. The District incurred the following expenditures to the program with the following items noted: Check 239348 Dated 8/6/2024 for $49,700 The expenditure amount for The Hunt day camp did not appear to be reasonable for the performance of the federal award. We believe the costs appear excessive for The Hunt day camp. Check 239417 Dated 8/21/2024 for $49,100 The expenditure amount for the Energy Sovereignty day camp did not appear to be reasonable for the performance of the federal award. We believe the costs appear excessive for the Energy Sovereignty day camp. Check 239161 Dated 7/16/2024 for $47,300 The expenditure amount for the STEM project did not appear to be reasonable for the performance of the federal award. We believe the costs appear excessive for the STEM day camp. Check 239873 Dated 9/19/2024 for $49,900 The expenditure amount for the Native American Literacy day camp did not appear to be reasonable for the performance of the federal award. We believe the costs appear excessive for the Native American Literacy day camp. Context In a total population exceeding 250 expenditures, forty (40) transactions were tested. Four (4) of these transactions were found with exceptions. The remaining untested population included 22 additional transactions that appear to be similar in nature. These additional transactions totaled $1,033,190.91. This appears to be a systemic issue affecting the District. Cause The condition appears to result from limited internal guidance defining what constitutes “reasonable” levels of spending for ESSER-funded activities. In some cases, urgency to deploy funds may have reduced the rigor of cost review processes. Effect Although the expenditures may have a valid programmatic purpose, the excessive nature of the costs increases the risk of being identified as waste or abuse. This may result in questioned costs, potential repayment obligations, and increased scrutiny from oversight bodies. Questioned Costs $196,000 Repeat Finding This is a repeat finding of 2024-003. Recommendation We recommend that management: • Implement enhanced cost analysis procedures, including price comparisons or cost reasonableness reviews prior to purchase • Require documentation supporting why higher-cost options are necessary • Strengthen supervisory review and approval processes for significant expenditures • Provide targeted training on federal cost principles, with emphasis on reasonableness and stewardship of ESSER funds Management’s Response See corrective action plan.
Show full finding ▾Hide full finding ▴Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Allowable Costs/Cost Principles Criteria Under 2 CFR Part 200, Subpart E, costs must not only be allowable but also necessary and reasonable for the performance of the federal award. ESSER funds are intended to address learning loss, support safe school operations, and respond to pandemic-related impacts; however, expenditures must still adhere to federal cost principles regarding reasonableness and prudent stewardship. Condition During our review of expenditures charged to the Elementary and Secondary School Emergency Relief Fund, we identified certain costs that were aligned with allowable programmatic activities but appeared excessive in nature. While the expenditures supported educational or COVID-19 recovery objectives, the cost of certain items exceeded what would be considered reasonable for the intended benefit. The District incurred the following expenditures to the program with the following items noted: Check 239348 Dated 8/6/2024 for $49,700 The expenditure amount for The Hunt day camp did not appear to be reasonable for the performance of the federal award. We believe the costs appear excessive for The Hunt day camp. Check 239417 Dated 8/21/2024 for $49,100 The expenditure amount for the Energy Sovereignty day camp did not appear to be reasonable for the performance of the federal award. We believe the costs appear excessive for the Energy Sovereignty day camp. Check 239161 Dated 7/16/2024 for $47,300 The expenditure amount for the STEM project did not appear to be reasonable for the performance of the federal award. We believe the costs appear excessive for the STEM day camp. Check 239873 Dated 9/19/2024 for $49,900 The expenditure amount for the Native American Literacy day camp did not appear to be reasonable for the performance of the federal award. We believe the costs appear excessive for the Native American Literacy day camp. Context In a total population exceeding 250 expenditures, forty (40) transactions were tested. Four (4) of these transactions were found with exceptions. The remaining untested population included 22 additional transactions that appear to be similar in nature. These additional transactions totaled $1,033,190.91. This appears to be a systemic issue affecting the District. Cause The condition appears to result from limited internal guidance defining what constitutes “reasonable” levels of spending for ESSER-funded activities. In some cases, urgency to deploy funds may have reduced the rigor of cost review processes. Effect Although the expenditures may have a valid programmatic purpose, the excessive nature of the costs increases the risk of being identified as waste or abuse. This may result in questioned costs, potential repayment obligations, and increased scrutiny from oversight bodies. Questioned Costs $196,000 Repeat Finding This is a repeat finding of 2024-003. Recommendation We recommend that management: • Implement enhanced cost analysis procedures, including price comparisons or cost reasonableness reviews prior to purchase • Require documentation supporting why higher-cost options are necessary • Strengthen supervisory review and approval processes for significant expenditures • Provide targeted training on federal cost principles, with emphasis on reasonableness and stewardship of ESSER funds Management’s Response See corrective action plan.
Contact Person: Duane Poitra, Business Manager Corrective Action Plan: We will resolve these issues and ensure full compliance by training purchasing agents and business office staff to properly document federally funded purchase order expenditures, maintain supporting invoices, and verify that vendor quotes reflect competitive market rates. Purchasing agents and approving administrators will also ensure staff travel requests are electronically filed; all related documentation for all related expenses will be collected. Additional training will be provided to relevant staff on federal expenditure guidelines to prevent future issues. These corrective actions will mitigate the risk of non-compliance and ensure that expenditures are reasonable and necessary for the federal award. Anticipated Completion Date: Fiscal Year 2025-2026
2024-003
Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria 2 CFR sections 200.313(c) and (e) includes a requirement for the non-federal entity to not encumber the equipment without prior approval of the federal awarding agency. 2 CFR section 200.311 includes a requirement for the non-federal entity, with prior approval by the ED or passthrough entity, may also use ESF funds to purchase real property, perform construction or minor remodeling, and for improvements to land, buildings, or equipment. Condition The District did not obtain prior approval for equipment acquisition or construction projects. This condition was noted for the following expenditures: Check 241010 Dated 12/27/2024 for $104,931.00 Check 240640 Dated 11/14/2024 for $147,398.90 Check 239597 Dated 8/30/2024 for $121,240.00 Context Per discussion with the District staff and review of program expenditures, there were 22 capital asset acquisitions during the year, we tested three of them for prior state approval. All three of these purchases were made without prior state approval. Cause The District did not properly submit for prior approval for equipment acquisition or construction until after the expenditure had been incurred and in some instances there were no submissions for prior approval. Effect The District may have purchased capital items that were not allowed by the State. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2024-004. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.
Show full finding ▾Hide full finding ▴Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria 2 CFR sections 200.313(c) and (e) includes a requirement for the non-federal entity to not encumber the equipment without prior approval of the federal awarding agency. 2 CFR section 200.311 includes a requirement for the non-federal entity, with prior approval by the ED or passthrough entity, may also use ESF funds to purchase real property, perform construction or minor remodeling, and for improvements to land, buildings, or equipment. Condition The District did not obtain prior approval for equipment acquisition or construction projects. This condition was noted for the following expenditures: Check 241010 Dated 12/27/2024 for $104,931.00 Check 240640 Dated 11/14/2024 for $147,398.90 Check 239597 Dated 8/30/2024 for $121,240.00 Context Per discussion with the District staff and review of program expenditures, there were 22 capital asset acquisitions during the year, we tested three of them for prior state approval. All three of these purchases were made without prior state approval. Cause The District did not properly submit for prior approval for equipment acquisition or construction until after the expenditure had been incurred and in some instances there were no submissions for prior approval. Effect The District may have purchased capital items that were not allowed by the State. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2024-004. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.
Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The purchasing agent acquired verification that American Rescue Plan – Elementary and Secondary School Emergency Relief (ESSER III) may be used for IDEA B allowable special education purchases. Moving forward, prior approval will be acquired by District purchasing agents on the ND DPI Capital Expenditure Prior Approval For Use of Federal Funding form before capital purchase is made using federal funding. Anticipated Completion Date: Fiscal Year 2025-2026
2024-004
Assistance Listing Number 84.181 Special Education Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Procurement 2 CFR Part 200.317 through 200.327 Criteria Procurement Standards require for the District to maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in 2 CFR Part 200.317 through 200.327. Condition The District performed a procurement activity that did not follow District policies as well as standards found in 2 CFR Part 200.317 through 200.327. The District failed to obtain quotes or bids for a purchase exceeding $10,000. This condition was noted for the following expenditure: Check 240313 Dated 10/17/2024 for $10,219.00 Context Per discussion with the District staff and review of program expenditures, there were 2 expenditures incurred in which quotes or bids should have been obtained. Both transactions were tested and it was noted that 1 transaction did not have the necessary quotes or bids. Cause District’s internal controls in place failed to ensure all procurement policies are followed. Effect District is not in compliance with their internal procurement policies and procurement standards. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2024-006 Recommendation Recommend the District to review internal controls to ensure all internal policies and compliance requirements are both being monitored and the District is remaining in compliance. Management’s Response See corrective action plan.
Show full finding ▾Hide full finding ▴Assistance Listing Number 84.181 Special Education Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Procurement 2 CFR Part 200.317 through 200.327 Criteria Procurement Standards require for the District to maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in 2 CFR Part 200.317 through 200.327. Condition The District performed a procurement activity that did not follow District policies as well as standards found in 2 CFR Part 200.317 through 200.327. The District failed to obtain quotes or bids for a purchase exceeding $10,000. This condition was noted for the following expenditure: Check 240313 Dated 10/17/2024 for $10,219.00 Context Per discussion with the District staff and review of program expenditures, there were 2 expenditures incurred in which quotes or bids should have been obtained. Both transactions were tested and it was noted that 1 transaction did not have the necessary quotes or bids. Cause District’s internal controls in place failed to ensure all procurement policies are followed. Effect District is not in compliance with their internal procurement policies and procurement standards. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2024-006 Recommendation Recommend the District to review internal controls to ensure all internal policies and compliance requirements are both being monitored and the District is remaining in compliance. Management’s Response See corrective action plan.
Contact Person: Duane Poitra, Business Manager Corrective Action Plan: To ensure compliance with applicable federal purchasing regulations, purchasing agents will be trained by business office staff on the micro-purchase threshold requirements in 2 CFR Part 200. Internal controls will be established for purchases over $10,000, competitive bidding, such as sealed bids, quotes, or competitive proposals, will be acquired by purchasing agents as required by the Uniform Guidance (2 CFR Part 200). The designated purchasing agent will follow these rules, and all federal funding purchases exceeding $10,000 will require approval from the Superintendent and Business Manager to ensure compliance. Anticipated Completion Date: Fiscal Year 2025-2026
2024-006
FAC accepted this audit on March 30, 2025 — management decision was due September 30, 2025.
Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria Costs charged to the program should be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Condition The District incurred the following expenditures to the program with the following items noted: Check 236621 Dated 12/20/2023 for $49,600 The expenditure amount for Health Eating and Living workshop that did not appear to be reasonable for the performance of the federal award. No documentation was available to account for the supplies and other costs included in the check amount. Check 236241 Dated 11/22/2023 for $49,394 The expenditure amount for a Video Editing class that did not appear to be reasonable for the performance of the federal award. In addition, the amounts paid to the vendor for computer purchases exceeded market value. Check 238235 Dated 5/6/2024 for $676 The expenditure was for staff travel. In accordance with District policies, a Staff Travel Request Form is required. This form was not maintained. Context In a total population exceeding 250 expenditures, forty (40) transactions were tested. Three (3) of these transactions were found with exceptions. Cause The District did not properly obtain all invoice documentation and proper review to ensure expenditures were necessary and reasonable for the performance of the federal award. Effect The District may have incurred costs deemed excessive for the grant. Questioned Costs $99,670 Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements. Management’s Response See corrective action plan.
Show full finding ▾Hide full finding ▴Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria Costs charged to the program should be necessary and reasonable for the performance of the federal award and be allocable thereto under the principles in 2 CFR Part 200, Subpart E. Condition The District incurred the following expenditures to the program with the following items noted: Check 236621 Dated 12/20/2023 for $49,600 The expenditure amount for Health Eating and Living workshop that did not appear to be reasonable for the performance of the federal award. No documentation was available to account for the supplies and other costs included in the check amount. Check 236241 Dated 11/22/2023 for $49,394 The expenditure amount for a Video Editing class that did not appear to be reasonable for the performance of the federal award. In addition, the amounts paid to the vendor for computer purchases exceeded market value. Check 238235 Dated 5/6/2024 for $676 The expenditure was for staff travel. In accordance with District policies, a Staff Travel Request Form is required. This form was not maintained. Context In a total population exceeding 250 expenditures, forty (40) transactions were tested. Three (3) of these transactions were found with exceptions. Cause The District did not properly obtain all invoice documentation and proper review to ensure expenditures were necessary and reasonable for the performance of the federal award. Effect The District may have incurred costs deemed excessive for the grant. Questioned Costs $99,670 Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements. Management’s Response See corrective action plan.
2024-003 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: We will resolve these issues and ensure full compliance by training purchasing agents and business office staff to properly document federally funded purchase order expenditures, maintain supporting invoices, and verify that vendor quotes reflect competitive market rates. Purchasing agents and approving administrators will also ensure staff travel requests are electronically filed; all related documentation for all related expenses will be collected. Additional training will be provided to relevant staff on federal expenditure guidelines to prevent future issues. These corrective actions will mitigate the risk of non-compliance and ensure that expenditures are reasonable and necessary for the federal award. Anticipated Completion Date: Fiscal Year 2024-2025
Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria 2 CFR sections 200.313(c) and (e) includes a requirement for the non-federal entity to not encumber the equipment without prior approval of the federal awarding agency. 2 CFR section 200.311 includes a requirement for the non-federal entity, with prior approval by the ED or passthrough entity, may also use ESF funds to purchase real property, perform construction or minor remodeling, and for improvements to land, buildings, or equipment. Condition The District did not obtain prior approval for equipment acquisition or construction projects. Context Per discussion with the District staff and review of program expenditures, there were 19 capital asset acquisitions during the year, we tested all of them for prior state approval. One purchase was approved by the state after the purchase was made. Seven purchases were made without prior state approval. Cause The District did not properly submit for prior approval for equipment acquisition or construction until after the expenditure had been incurred and in some instances there were no submissions for prior approval. Effect The District may have purchased capital items that were not allowed by the State. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2023-004. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.
Show full finding ▾Hide full finding ▴Assistance Listing Number 84.425 Education Stabilization Fund Department of Education Passed Through North Dakota Department of Public Instruction Passed Through Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria 2 CFR sections 200.313(c) and (e) includes a requirement for the non-federal entity to not encumber the equipment without prior approval of the federal awarding agency. 2 CFR section 200.311 includes a requirement for the non-federal entity, with prior approval by the ED or passthrough entity, may also use ESF funds to purchase real property, perform construction or minor remodeling, and for improvements to land, buildings, or equipment. Condition The District did not obtain prior approval for equipment acquisition or construction projects. Context Per discussion with the District staff and review of program expenditures, there were 19 capital asset acquisitions during the year, we tested all of them for prior state approval. One purchase was approved by the state after the purchase was made. Seven purchases were made without prior state approval. Cause The District did not properly submit for prior approval for equipment acquisition or construction until after the expenditure had been incurred and in some instances there were no submissions for prior approval. Effect The District may have purchased capital items that were not allowed by the State. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2023-004. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.
2024-004 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The purchasing agent acquired verification that American Rescue Plan – Elementary and Secondary School Emergency Relief (ESSER III) may be used for IDEA B allowable special education purchases. Moving forward, prior approval will be acquired by District purchasing agents on the ND DPI Capital Expenditure Prior Approval For Use of Federal Funding form before capital purchase is made using federal funding. Anticipated Completion Date: Fiscal Year 2024-2025
2023-004
Assistance Listing Number 84.181 Special Education – Grants for Infants and Families Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Maintenance of Effort Criteria The total amount of state and local funds budgeted for expenditure in the current fiscal year for early intervention services for children eligible under Part C and their families must be at least equal to the total amount of state and local funds actually expended for early intervention services for these children and their families in the most recent preceding fiscal year for which the information is available. Condition District does not currently monitor this compliance requirement. Context Not Applicable Cause District does not currently have appropriately designed internal controls in place to ensure all compliance requirements are being monitored Effect Lack of internal controls to monitor the compliance requirements could cause the District to fall out of compliance. Questioned Costs Not Applicable Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review internal controls to ensure all compliance requirements are both being monitored and District is remaining in compliance. Management’s Response See corrective action plan.
Show full finding ▾Hide full finding ▴Assistance Listing Number 84.181 Special Education – Grants for Infants and Families Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Maintenance of Effort Criteria The total amount of state and local funds budgeted for expenditure in the current fiscal year for early intervention services for children eligible under Part C and their families must be at least equal to the total amount of state and local funds actually expended for early intervention services for these children and their families in the most recent preceding fiscal year for which the information is available. Condition District does not currently monitor this compliance requirement. Context Not Applicable Cause District does not currently have appropriately designed internal controls in place to ensure all compliance requirements are being monitored Effect Lack of internal controls to monitor the compliance requirements could cause the District to fall out of compliance. Questioned Costs Not Applicable Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review internal controls to ensure all compliance requirements are both being monitored and District is remaining in compliance. Management’s Response See corrective action plan.
2024-005 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The Business Manager and the Special Education Director will collaborate to develop the budget at the beginning of each fiscal year, using the previous year’s expenditures as a baseline. At the conclusion of each quarter, they will meet to review the status of the Special Education Budget, ensuring that the current spending aligns with or exceeds the previous year's expenditures. Anticipated Completion Date: Fiscal Year 2024-2025
Assistance Listing Number 84.181 Special Education Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Procurement 2 CFR Part 200.317 through 200.327 Criteria Procurement Standards require for the District to maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in 2 CFR Part 200.317 through 200.327. Condition The District performed a procurement activity that did not follow District policies as well as standards found in 2 CFR Part 200.317 through 200.327. The District failed to obtain quotes or bids for a purchase exceeding $10,000. Context Per discussion with the District staff and review of program expenditures, there were 4 expenditures incurred in which quotes or bids should have been obtained. All four transactions were tested and it was noted that 1 transaction did not have the necessary quotes or bids. Cause District’s internal controls in place failed to ensure all procurement policies are followed. Effect District is not in compliance with their internal procurement policies and procurement standards. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review internal controls to ensure all internal policies and compliance requirements are both being monitored and the District is remaining in compliance. Management’s Response See corrective action plan.
Show full finding ▾Hide full finding ▴Assistance Listing Number 84.181 Special Education Department of Education Passed Through Turtle Mountain Band of Chippewa Indians Procurement 2 CFR Part 200.317 through 200.327 Criteria Procurement Standards require for the District to maintain and use documented procedures for procurement transactions under a Federal award or subaward, including for acquisition of property or services. These documented procurement procedures must be consistent with State, local, and tribal laws and regulations and the standards identified in 2 CFR Part 200.317 through 200.327. Condition The District performed a procurement activity that did not follow District policies as well as standards found in 2 CFR Part 200.317 through 200.327. The District failed to obtain quotes or bids for a purchase exceeding $10,000. Context Per discussion with the District staff and review of program expenditures, there were 4 expenditures incurred in which quotes or bids should have been obtained. All four transactions were tested and it was noted that 1 transaction did not have the necessary quotes or bids. Cause District’s internal controls in place failed to ensure all procurement policies are followed. Effect District is not in compliance with their internal procurement policies and procurement standards. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation Recommend the District to review internal controls to ensure all internal policies and compliance requirements are both being monitored and the District is remaining in compliance. Management’s Response See corrective action plan.
2024-006 Contact Person: Duane Poitra, Business Manager Corrective Action Plan: To ensure compliance with applicable federal purchasing regulations, purchasing agents will be trained by business office staff on the micro-purchase threshold requirements in 2 CFR Part 200. Internal controls will be established for purchases over $10,000, competitive bidding, such as sealed bids, quotes, or competitive proposals, will be acquired by purchasing agents as required by the Uniform Guidance (2 CFR Part 200). The designated purchasing agent will follow these rules, and all federal funding purchases exceeding $10,000 will require approval from the Superintendent and Business Manager to ensure compliance. Anticipated Completion Date: Fiscal Year 2024-2025
FAC accepted this audit on April 2, 2024 — management decision was due October 2, 2024.
Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Special Tests and Provisions 2 CFR Part 200, Appendix II Criteria For construction contracts and subcontracts greater than $2,000 funded with federal dollars, the District should verify prevailing wage rate clauses were included in the contract or subcontract and for each week in which work was performed under the contract or subcontract the District should monitor certified payroll registers to ensure contractors and subcontractors were paying employees the prevailing wage rates. Condition The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Context The District had one construction project carried over from the prior year in which wage rate clauses were not provided, in addition the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing rates. Cause The District was unaware of the compliance requirements regarding the construction projects. Effect The District is not in compliance with Wage Rate Requirements, a part of the Special Tests and Provisions. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2022-003. Recommendation We recommend the District to review the wage rate compliance requirements as part of the special tests and provisions of this program in the compliance supplement and to create and implement a process of submitting prevailing wage rates to contractors as well as obtaining the certified payroll registers to determine if contractors are in compliance. Management’s Response See corrective action plan
Show full finding ▾Hide full finding ▴Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Special Tests and Provisions 2 CFR Part 200, Appendix II Criteria For construction contracts and subcontracts greater than $2,000 funded with federal dollars, the District should verify prevailing wage rate clauses were included in the contract or subcontract and for each week in which work was performed under the contract or subcontract the District should monitor certified payroll registers to ensure contractors and subcontractors were paying employees the prevailing wage rates. Condition The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Context The District had one construction project carried over from the prior year in which wage rate clauses were not provided, in addition the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing rates. Cause The District was unaware of the compliance requirements regarding the construction projects. Effect The District is not in compliance with Wage Rate Requirements, a part of the Special Tests and Provisions. Questioned Costs Undeterminable. Repeat Finding See prior year finding 2022-003. Recommendation We recommend the District to review the wage rate compliance requirements as part of the special tests and provisions of this program in the compliance supplement and to create and implement a process of submitting prevailing wage rates to contractors as well as obtaining the certified payroll registers to determine if contractors are in compliance. Management’s Response See corrective action plan
2023-003 MATERIAL WEAKNESS – SPECIAL TESTS AND PROVISIONS Condition: The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The contractor indicated that he would not be using payroll in this particular contract, but rather work would be performed by independent contractors. It was not understood by the District that the contractor would be required to provide weekly certified payroll reports indicating that no payroll occurred during the weekly payroll reporting period. Contractors awarded future construction project contracts applicable to payroll reporting will be required to provide weekly certified payroll reports to the Belcourt School District. Anticipated Completion Date: Fiscal Year 2023-2024
2022-003
Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria Governors, SEAs, and subrecipients must receive prior approval for capital expenditures for equipment acquisition or improvements to land, buildings, or equipment. For capital equipment or improvements to land, buildings, or equipment that were purchased with grant funds, the Governor or SEA, as the pass-through entity, must provide prior approval to subrecipients. Condition The District did not obtain prior approval for equipment acquisition. In addition, the approval received was for less than the expenditures incurred. Context The District purchased one capital asset during the year in which prior approval was needed to be obtained. Cause The District did not properly submit for prior approval for equipment acquisition until after the purchase had been made. The request for equipment acquisition was also submitted for less than the acquisition amount. Effect Noncompliance with Equipment/Real Property Management requirements. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.
Show full finding ▾Hide full finding ▴Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Equipment/Real Property Management Criteria Governors, SEAs, and subrecipients must receive prior approval for capital expenditures for equipment acquisition or improvements to land, buildings, or equipment. For capital equipment or improvements to land, buildings, or equipment that were purchased with grant funds, the Governor or SEA, as the pass-through entity, must provide prior approval to subrecipients. Condition The District did not obtain prior approval for equipment acquisition. In addition, the approval received was for less than the expenditures incurred. Context The District purchased one capital asset during the year in which prior approval was needed to be obtained. Cause The District did not properly submit for prior approval for equipment acquisition until after the purchase had been made. The request for equipment acquisition was also submitted for less than the acquisition amount. Effect Noncompliance with Equipment/Real Property Management requirements. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation We recommend the District to review all compliance requirements of federal programs to ensure they have procedures to ensure compliance with those requirements and for the requests for acquisition to be made timely and for the appropriate expenditure amount. Management’s Response See corrective action plan.
2023-004 MATERIAL WEAKNESS – Equipment/Real Property Management Condition: The District did not obtain prior approval for equipment acquisition. In addition, the approval received was for less than the expenditures incurred. Contact Person: Duane Poitra, Business Manager Corrective Action Plan: The purchasing agent acquired verification that American Rescue Plan – Elementary and Secondary School Emergency Relief (ESSER III) may be used for IDEA B allowable special education purchases. Moving forward, prior approval will be acquired by District purchasing agents on the ND DPI Capital Expenditure Prior Approval For Use of Federal Funding form before capital purchase is made using federal funding. Anticipated Completion Date: April 1, 2024
Assistance Listing Number 84.027; 84.173 Special Education Cluster (IDEA) Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Maintenance of Effort 34 CFR Part 300.203 Criteria IDEA Part B funds received by a local education agency (LEA) cannot be used to reduce the level of expenditures for the education of children with disabilities made by the LEA from local funds, or a combination of state and local funds, below the level of those expenditures for the proceeding year. Condition District expenditures made with state and local funds fell below the level of those expenditures for the preceding year. Cause The District used funding received from the ESSER program to reduce the expenditures paid for with state and local funding. Effect Noncompliance with Maintenance of Effort requirements. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation We recommend the District to monitor expenditures made with state and local funding to ensure the level of expenditures per student with disabilities remains consistent, or increases, over the prior year. Management’s Response See corrective action plan.
Show full finding ▾Hide full finding ▴Assistance Listing Number 84.027; 84.173 Special Education Cluster (IDEA) Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Maintenance of Effort 34 CFR Part 300.203 Criteria IDEA Part B funds received by a local education agency (LEA) cannot be used to reduce the level of expenditures for the education of children with disabilities made by the LEA from local funds, or a combination of state and local funds, below the level of those expenditures for the proceeding year. Condition District expenditures made with state and local funds fell below the level of those expenditures for the preceding year. Cause The District used funding received from the ESSER program to reduce the expenditures paid for with state and local funding. Effect Noncompliance with Maintenance of Effort requirements. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation We recommend the District to monitor expenditures made with state and local funding to ensure the level of expenditures per student with disabilities remains consistent, or increases, over the prior year. Management’s Response See corrective action plan.
2023-005 MATERIAL WEAKNESS – Idea Part B Funds Condition: District expenditures made with state and local funds fell below the level of those expenditures for the preceding year. Contact Person: Duane Poitra, Business Manager Corrective Action Plan: District will monitor state and local funding towards special education expenditures to ensure annual compliance with the audit standard of Maintenance of Effort requirements pertaining to Special Education. Anticipated Completion Date: April 1, 2024
FAC accepted this audit on March 7, 2023 — management decision was due September 7, 2023.
2022-003 Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Special Tests and Provisions 2 CFR Part 200.326 Criteria For construction contracts and subcontracts greater than $2,000 funded with federal dollars, the District should verify prevailing wage rate clauses were included in the contract or subcontract and for each week in which work was performed under the contract or subcontract the District should monitor certified payroll registers to ensure contractors and subcontractors were paying employees the prevailing wage rates. Condition The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Cause The District was unaware of the compliance requirements regarding the construction projects. Effect The District is not in compliance with Wage Rate Requirements, a part of the Special Tests and Provisions. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation We recommend the District to review the wage rate compliance requirements as part of the special tests and provisions of this program in the compliance supplement and to create and implement a process of submitting prevailing wage rates to contractors as well as obtaining the certified payroll registers to determine if contractors are in compliance. Management?s Response The District will plan to get payroll registers monthly from contractors moving forward.
Show full finding ▾Hide full finding ▴2022-003 Assistance Listing Number 84.425 Education Stabilization Fund Department of Education North Dakota Department of Public Instruction Turtle Mountain Band of Chippewa Indians Special Tests and Provisions 2 CFR Part 200.326 Criteria For construction contracts and subcontracts greater than $2,000 funded with federal dollars, the District should verify prevailing wage rate clauses were included in the contract or subcontract and for each week in which work was performed under the contract or subcontract the District should monitor certified payroll registers to ensure contractors and subcontractors were paying employees the prevailing wage rates. Condition The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Cause The District was unaware of the compliance requirements regarding the construction projects. Effect The District is not in compliance with Wage Rate Requirements, a part of the Special Tests and Provisions. Questioned Costs Undeterminable. Repeat Finding This is not a repeat finding. Recommendation We recommend the District to review the wage rate compliance requirements as part of the special tests and provisions of this program in the compliance supplement and to create and implement a process of submitting prevailing wage rates to contractors as well as obtaining the certified payroll registers to determine if contractors are in compliance. Management?s Response The District will plan to get payroll registers monthly from contractors moving forward.
2022-003 MATERIAL WEAKNESS ? SPECIAL TESTS AND PROVISIONS Condition: The District did not provide the wage rate clauses to contractors. In addition, the District did not obtain from contractors the certified payroll registers, nor did they perform testing to ensure contractors were paying the prevailing wage rates. Corrective Action Plan: The contractor indicated that he would not be using payroll in this particular contract, but rather work would be performed by independent contractors. It was not understood by the District that the contractor would be required to provide weekly certified payroll reports indicating that no payroll occurred during the weekly payroll reporting period. Contractors awarded future construction project contracts applicable to payroll reporting will be required to provide weekly certified payroll reports to the Belcourt School District. Duane Poitra, Business Manager is responsible for this corrective action plan. Anticipated Completion Date: Fiscal Year 2022-23
FAC accepted this audit on March 27, 2022 — management decision was due September 27, 2022.
FAC accepted this audit on March 22, 2021 — management decision was due September 22, 2021.
FAC accepted this audit on May 13, 2020 — management decision was due November 13, 2020.
2019-014 MATERIAL WEAKNESS ? LACK OF FORMAL APPROVAL OF PLEDGE OF SECURITIES Condition Belcourt Public School District does not have internal controls in place to ensure the Indian School Equalization Program Grant funds are adequately pledged with a financial institution. Effect Belcourt Public School District, at times, may not be in compliance with Uniform Guidance. Cause Belcourt Public School District has not implemented internal controls to ensure grant funds are adequately pledged at a financial institution. Criteria Uniform Guidance requires internal controls to be in place surrounding the special test compliance requirement. Questioned Costs None. Prior Recommendation No. Recommendation We recommend Belcourt Public School District implement a formal internal control process to ensure Indian School Equalization Program Grant funds are adequately pledged with a financial institution. Belcourt Public School District?s Response and Corrective Actions See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-014 MATERIAL WEAKNESS ? LACK OF FORMAL APPROVAL OF PLEDGE OF SECURITIES Condition Belcourt Public School District does not have internal controls in place to ensure the Indian School Equalization Program Grant funds are adequately pledged with a financial institution. Effect Belcourt Public School District, at times, may not be in compliance with Uniform Guidance. Cause Belcourt Public School District has not implemented internal controls to ensure grant funds are adequately pledged at a financial institution. Criteria Uniform Guidance requires internal controls to be in place surrounding the special test compliance requirement. Questioned Costs None. Prior Recommendation No. Recommendation We recommend Belcourt Public School District implement a formal internal control process to ensure Indian School Equalization Program Grant funds are adequately pledged with a financial institution. Belcourt Public School District?s Response and Corrective Actions See Corrective Action Plan.
2019-014 MATERIAL WEAKNESS ? LACK OF FORMAL APPROVAL OF PLEDGE OF SECURITIES Condition: Belcourt Public School District does not have internal controls in place to ensure the Indian School Equalization Program Grant funds are adequately pledged with a financial institution. Corrective Action Plan: The Belcourt Public School District management will address identifying number 2019-14 ?Lack of Formal Approval of Pledge of Securities? by establishing an internal control to monitor, on a quarterly basis, pledged securities at financial institution that previously did not have adequate pledged securities to ensure the securities pledged by this financial institution exceed 110% of FDIC Insurance held. The District internal control will also include reporting in writing to this financial institution of any anticipated major fluctuations in the bank balance that may require increased pledged securities. Should the financial institution determine it does not have the feasibility to maintain adequate collateral secured, the District will move funds from that financial institution to another that can provide adequate securities to pledge. Anticipated Completion Date: Fiscal Year 2019-20
2019-015 MATERIAL WEAKNESS ? PRESENTING STUDENT TESTING REPORTS TO TRIBE Condition Belcourt Public School District submits, but does not formally review, the Student Testing Annual Report with the Tribal Council or the Grant School Board. Effect Belcourt Public School District may not be in compliance with its own internal control policies surrounding the Indian School Equalization Program grant which could impact funding for the grant in future periods. Cause Belcourt School District's internal controls did not ensure the report was presented during the usual presentation period, which resulted in the lack of presentation of this report during Fiscal Year 2019. Criteria Belcourt Public School District's internal control over the Indian School Equalization Program grant agreement states "The student testing report is reviewed with the Tribe Council once a year." Questioned Costs None. Prior Recommendation No. Recommendation We recommend Belcourt Public School District review the Annual Student Testing Report with the Tribal Council and the Grant School Board. We further recommend Belcourt Public School District monitor its internal controls of ensuring the report is presented during each fiscal year. Belcourt Public School District?s Response and Corrective Actions See Corrective Action Plan.
Show full finding ▾Hide full finding ▴2019-015 MATERIAL WEAKNESS ? PRESENTING STUDENT TESTING REPORTS TO TRIBE Condition Belcourt Public School District submits, but does not formally review, the Student Testing Annual Report with the Tribal Council or the Grant School Board. Effect Belcourt Public School District may not be in compliance with its own internal control policies surrounding the Indian School Equalization Program grant which could impact funding for the grant in future periods. Cause Belcourt School District's internal controls did not ensure the report was presented during the usual presentation period, which resulted in the lack of presentation of this report during Fiscal Year 2019. Criteria Belcourt Public School District's internal control over the Indian School Equalization Program grant agreement states "The student testing report is reviewed with the Tribe Council once a year." Questioned Costs None. Prior Recommendation No. Recommendation We recommend Belcourt Public School District review the Annual Student Testing Report with the Tribal Council and the Grant School Board. We further recommend Belcourt Public School District monitor its internal controls of ensuring the report is presented during each fiscal year. Belcourt Public School District?s Response and Corrective Actions See Corrective Action Plan.
2019-015 MATERIAL WEAKNESS ? PRESENTING STUDENT TESTING REPORTS TO TRIBE Condition: Belcourt Public School District submits, but does not formally review, the Student Testing Annual Report with the Tribal Council or the Grant School Board. Corrective Action Plan: The Belcourt Public School District management will address identifying number 2019-15 ?Presenting Student Testing Reports to Tribe? by the Superintendent taking responsibility to schedule a meeting with the Turtle Mountain Band of Chippewa Tribal Chairman and Council/100-297 Grant School Board prior to October 1st to review the high school?s Annual Student Testing Report information. The Superintendent, after July 1, will communicate, in writing, directives to the High School Principal to begin compiling the Annual Student Testing Report and once meeting is scheduled, to attend meeting with Tribal Chairman and Council/100-297 Grant School Board to present final the Annual Student Testing Report for prior school year. Anticipated Completion Date: September 30, 2020
FAC accepted this audit on March 26, 2019 — management decision was due September 26, 2019.
FAC accepted this audit on March 19, 2018 — management decision was due September 19, 2018.
FAC accepted this audit on March 30, 2017 — management decision was due September 30, 2017.
GSA_MIGRATION
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GSA_MIGRATION
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