Wounded Knee District School

Criteria: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. Condition: Background checks were not available for two employees selected for testing. The background checks for two additional employees were not in compliance with the five-year requirement. Context: There were four exceptions noted in our sample of ten employees. Questioned Costs: None noted .Cause: Oversight of background checks was not being performed to ensure the School was complying with the requirements. Effect: The School is not in compliance with the Indian School Equalization Program or the Indian Child Protection and Family Violence Prevention Act. Identification of Prior Audit Finding: This finding is not a repeat of a prior year finding. Recommendation: We recommend the School implement an independent review of the background check files at least annually to ensure background check files are being properly completed, updated and maintained. Views of Responsible Officials: The views of management are included in the corrective action plan beginning on page 36.

Condition: The Indian Child Protection and Family Violence Prevention Act 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 in a position that involves regular contact with, or control over, Indian children. In addition, background investigations must be completed every five years and adjudicated by an adjudicating official with proper training and credentials. The adjudicator must have a current adjudicated background check on file. Recommendation: We recommend the School implement an independent review of the background check files at least annually to ensure background check files are being properly completed, updated and maintained. The adjudicator must themselves have a independent clean adjudication on file with the School. Response: The School Board will implement a plan to complete an independent annual review of all background check files to ensure background checks are being properly completed, updated and maintained. We will also assure the adjudicator has a completed current adjudication on file. ANTICIPATED COMPLETION DATE: June 30, 2024 PERSON(S) RESPONSIBLE: Monica Whirlwind Horse, Principal and the School Board

Criteria: Special education funds must be used for allowable costs and the special education purpose must be documented. The School?s purchasing policy requires the Principal and Business Manager approve purchase requests and requires payments have receipts for support. The School?s payroll procedures require a signed and completed timesheet documenting actual hours of employee service to document time in accordance with the Uniform Guidance. Funding for facilities improvement and repair should be properly tracked. Condition: During testing we noted the following exceptions: 1. One purchase coded to special education funds which was not supported by documentation of the special education purpose. 2. Two disbursements were not signed by the Principal. 3. Supporting receipts were not attached to one item selected for testing. 4. Two payroll checks were written without supporting timesheets. 5. Multiple facilities improvement and repair project expenditures were not properly tracked and documented. Context/Sampling: This is a systemic issue affecting all funds of the School. The samples used appear statistically valid. 1. A purchase of $1,375 for donor cards was coded to special education funds and the special education purpose was not documented. 2. Of 132 disbursements selected for testing, two did not have the Principal?s signature and one did not have the receipts attached. 3. Timesheets were not available for two of 102 timesheets for a total gross pay of $1,504. 4. At the beginning of the year, the School had restricted fund balances in facilities improvement and repair of $172,834 for 14 projects some dating back to FY 2012. In the current year, the Facility Manager and Business Manager identified many of the projects and were able to close $105,879 of the projects and move the expenditures to the correct funds. Questioned Costs: No reportable questioned costs noted. Cause: The missing grant purpose and authorizing signatures were not noted during the approval process. The time sheets were not signed and returned by the employee. There have been changes in personnel at the School as well as the BIE's tracking software which led to a lack of proper tracking of facilities improvement and repair projects. Effect: The School is not in compliance with internal policies and the Uniform Guidance. Identification of Prior Audit Finding: This finding is a repeat of Finding 2018-001 in the immediate prior audit. Recommendation: All purchases should be reviewed to ensure the proper authorization has been obtained, all supporting documentation is attached and the reason for program costs have documented. All purchase documentation should be maintained. Properly completed and approved timesheets should be maintained for all payroll paid. Facilities improvement and repair projects should be tracked to ensure proper reporting. Views of Responsible Officials: The views of management are included in the corrective action plan on page 34.

Corrective Action Planned/Taken: The School has identified personnel within the Business Office to examine all purchase and payroll documentation to ensure amounts paid are properly calculated, all approvals are obtained and all supporting documentation is attached, including documentation of purpose for federal grants. Anticipated Completion Date: This plan will be implemented immediately. Personel Responsible: The Business Manager will be responsible for this corrective action.

2018-001

GSA_MIGRATION

GSA_MIGRATION

2017-002

GSA_MIGRATION

GSA_MIGRATION