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Department of the Interior Federal Financial Assistance Listing 15.042 Indian School Equalization Allowable Costs/Activities Allowed or Unallowed Significant Deficiency in Internal Control Over Compliance and Immaterial Instance of Noncompliance Criteria – A good system of internal control includes an adequate system for ensuring all expenditures are properly recorded and allowable under the related federal grant in accordance with 2 CFR 200.430(i). Condition – In our testing of allowable costs and activities we noted one instance totaling $3.27 where payroll benefits were not paid in accordance with the employment letter. Cause – Procedures are not in place to adequately identify unallowable costs or activities. Effect – A lack of internal controls over allowable costs and activities could result in the improper use of federal funds and non-compliance with the provisions of applicable grant requirements. Questioned Costs – None reported Context/Sampling – A nonstatistical sample of 60 transactions out of 882 total transactions were selected for testing, which accounted for $26,666 of $2,203,450 of federal program expenditures. Repeat Finding from Prior Years – Yes, 2024-008 Recommendation – The School should review internal control procedures to ensure federal expenditures are being properly reviewed for unallowable costs and activities. Views of Responsible Officials – The School respectfully disagrees with the classification of this matter as a significant deficiency.

Department of the Interior Federal Financial Assistance Listing 15.046 Administrative Cost Grants for Indian Schools Allowable Costs/Activities Allowed or Unallowed Material Weakness in Internal Control Over Compliance and Immaterial Instance of Noncompliance Criteria – A good system of internal control includes an adequate system for ensuring all expenditures are properly recorded and allowable under the related federal grant in accordance with 2 CFR 200.430(i). Condition – In our testing of allowable costs and activities we noted six instances where payroll expenditures were not paid in accordance with the employment letter. Cause – Procedures are not in place to adequately identify unallowable costs or activities. Effect – A lack of internal controls over allowable costs and activities could result in the improper use of federal funds and non-compliance with the provisions of applicable grant requirements. Questioned Costs – None reported Context/Sampling – A nonstatistical sample of 60 transactions out of 882 total transactions were selected for testing, which accounted for $138,702 of $781,712 of federal program expenditures. Repeat Finding from Prior Years – Yes, 2023-007 Recommendation – The School should review internal control procedures to ensure federal expenditures are being properly reviewed for unallowable costs and activities. Views of Responsible Officials – There is no disagreement with the audit finding.

Department of Interior Federal Financial Assistance Listing 15.042 Indian School Equalization Allowable Costs/Activities Allowed or Unallowed Material Weakness in Internal Control Over Compliance and Immaterial Instance of Noncompliance Criteria – A good system of internal control includes an adequate system for ensuring all expenditures are properly recorded and allowable under the related federal grant in accordance with 2 CFR 200.430(i). Condition – In our testing of allowable costs and activities we noted several instances where payroll expenditures were not paid in accordance with the employment letter. Cause – Procedures are not in place to adequately identify unallowable costs or activities. Effect – A lack of internal controls over allowable costs and activities could result in improper use of federal funds and non-compliance with the provisions of applicable grant requirements. Questioned Costs – None reported Context/Sampling – A nonstatistical sample of 60 transactions out of 10,014 total transactions were selected for testing, which accounted for $61,549 of $2,139,500 of federal program expenditures. Repeat Finding from Prior Years – Yes, 2023-008 Recommendation – The School should review internal control procedures to ensure federal expenditures are being properly reviewed for unallowable costs and activities. Views of Responsible Officials – There is no disagreement with the audit finding.

Department of the Interior Federal Financial Assistance Listing 15.046 Administrative Cost Grants for Indian Schools Allowable Costs/Activities Allowed or Unallowed Material Weakness in Internal Control Over Compliance and Immaterial Instance of Noncompliance Criteria – A good system of internal control includes an adequate system for ensuring all expenditures are properly recorded and allowable under the related federal grant in accordance with 2 CFR 200.430(i). Condition – In our testing of allowable costs and activities we noted four instances where payroll expenditures were not paid in accordance with the employment letter. Cause – Procedures are not in place to adequately identify unallowable costs or activities. Effect – A lack of internal controls over allowable costs and activities could result in the improper use of federal funds and non-compliance with the provisions of applicable grant requirements. Questioned Costs – None reported Context/Sampling – A nonstatistical sample of 60 transactions out of 821 total transactions were selected for testing, which accounted for $129,328 of $648,490 of federal program expenditures. Repeat Finding from Prior Years – Yes, 2022-007 Recommendation – The School should review internal control procedures to ensure federal expenditures are being properly reviewed for unallowable costs and activities. Views of Responsible Officials – There is no disagreement with the audit finding.

Department of Interior Federal Financial Assistance Listing 15.042 Indian School Equalization Allowable Costs/Activities Allowed or Unallowed Material Weakness in Internal Control Over Compliance and Immaterial Instance of Noncompliance Criteria – A good system of internal control includes an adequate system for ensuring all expenditures are properly recorded and allowable under the related federal grant in accordance with 2 CFR 200.430(i). Condition – In our testing of allowable costs and activities we noted five instances where payroll expenditures were not paid in accordance with the employment letter. Cause – Procedures are not in place to adequately identify unallowable costs or activities. Effect – A lack of internal controls over allowable costs and activities could result in improper use of federal funds and non-compliance with the provisions of applicable grant requirements. Questioned Costs – None reported Context/Sampling – A nonstatistical sample of 60 transactions out of 4,205 total transactions were selected for testing, which accounted for $98,689 of $1,818,900 of federal program expenditures. Repeat Finding from Prior Years – No. Recommendation – The School should review internal control procedures to ensure federal expenditures are being properly reviewed for unallowable costs and activities. Views of Responsible Officials – There is no disagreement with the audit finding

Material Weakness in Internal Control Over Compliance and Material Instance of Noncompliance2022-008 Department of EducationFederal Financial Assistance Listing/CFDA Number 84.425Education Stabilization FundSpecial Tests and ProvisionsCriteria ? Uniform Guidance and 2 CFR 656.40 through 656.41 set forth the standardsnonfederal entities other than states must follow when operating federal programs.Condition ? In our testing of Special Tests and Provisions, it was identified that the School didnot satisfy the requirements of 2 CFR 656.40 through 2 CFR 656.41. The School did not ensureproper inclusion of prevailing wage rate clauses were included in a construction contract andalso did not obtain proper support to ensure required certified payrolls were submitted.Cause ? Lack of oversight, awareness, or understanding of all of the specific requirements underUniform Guidance and applicable CFR sections, and controls were not adequately designed toensure compliance with all of these requirements.Effect ? Lack of compliance to federal requirements increases the overall risk of non-compliance.Questioned Costs ? None reportedContext/Sampling ? All contracts were selected for testing.Repeat Finding from Prior Years ? No.Recommendation ? We recommend that management establish controls to follow all applicablerequirements under Uniform Guidance and applicable CFR sections.View of responsible officials ? There is no disagreement with the finding.

Material Weakness in Internal Control Over Compliance and Immaterial Instance of Noncompliance2022-009 Department of EducationFederal Financial Assistance Listing/CFDA Number 84.425Education Stabilization FundAllowable Costs/Activities Allowed or UnallowedCriteria ? A good system of internal control includes an adequate system for ensuring allexpenditures are properly recorded and allowable under the related federal grant in accordancewith 2 CFR 200.430(i).Condition ? In our testing of allowable costs and activities we noted four instances ofexpenditures that were not COVID related and therefore not allowable under the terms of thegrant.Cause ? Procedures are not in place to adequately identify unallowable costs or activities.Effect ? A lack of internal controls over allowable costs and activities could result in improperuse of federal funds and non-compliance with the provisions of applicable grant requirements.Questioned Costs ? $27,110Context/Sampling ? A nonstatistical sample of 60 transactions out of 994 total transactions wereselected for testing, which accounted for $833,248 of $1,232,609 of federal programexpenditures.Repeat Finding from Prior Years ? No.Recommendation ? The School should review internal control procedures to ensure federalexpenditures are being properly reviewed for unallowable costs and activities.Views of Responsible Officials ? There is no disagreement with the audit finding.

Significant Deficiency in Internal Control over Compliance and Immaterial Instance of Noncompliance 2021-007 A/B. Allowable Costs and Cost Principles/Activities Allowed or Unallowed Federal program information: Federal Agency CFDA Number Program Title Award Year Department of Interior 15.042 Indian School Equalization Program 2021 Criteria ? A good system of internal control includes an adequate system for ensuring all expenditures are approved and supporting documentation is retained under the related federal grant. Condition ? In our testing of allowable costs and activities we identified two expenditures that lacked supporting vendor invoices. Cause ? Review and approval procedures are not in place to adequately identify that all expenditures include supporting documentation. Effect ? A lack of internal controls over allowable costs and activities could result in wrongful use of federal funds and non-compliance with the provisions of applicable grant requirements. Questioned Costs ? None reported. The total of known and projected questioned costs were less than the threshold that would require reporting. Context/Sampling ? A nonstatistical sample of 40 transactions out of 3,774 total transactions were selected for testing, which accounted for $58,885 of $1,671,530 of federal program expenditures. Repeat Finding from Prior Years ? No Recommendation ? The School should review internal control procedures to ensure federal expenditures are being properly reviewed for unallowable costs and activities. Views of Responsible Officials ? There is no disagreement with the audit finding.

Significant Deficiency in Internal Control over Compliance and Immaterial Instance of Noncompliance 2021-008 A/B. Allowable Costs and Cost Principles/Activities Allowed or Unallowed Federal program information Federal Agency CFDA Number Program Title Award Year Department of Interior 15.046 Grant Support Administration 2021 Criteria ? A good system of internal control includes an adequate system for ensuring all expenditures are allowable under the related federal grant. Condition ? In our testing of allowable costs and activities we noted one expenditure that was unallowable to the program related to an employee gift. Cause ? Procedures are not in place to adequately identify unallowable costs or activities. Effect ? A lack of internal controls over allowable costs and activities could result in wrongful use of federal funds and non-compliance with the provisions of applicable grant requirements. Questioned Costs ? None reported. The total of known and projected questioned costs were less than the threshold that would require reporting. Context/Sampling ? A nonstatistical sample of 60 transactions out of 847 total transactions were selected for testing, which accounted for $151,014 of $627,025 of federal program expenditures. Repeat Finding from Prior Years ? Yes Recommendation ?The School should review internal control procedures to ensure federal expenditures are being properly reviewed for unallowable costs and activities. Views of Responsible Officials ? There is no disagreement with the audit finding.

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