EIN: 560819154
UEI: CETCPF7VE9W6
Audited by: Baker Tilly US, LLP
Oversight agency: 15 [Department of the Interior]
Data as of August 28, 2026
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 (131 days from today).
What is a management decision? →While documentation exists that a background investigation was completed, no documentation was maintained that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation. Questioned Costs: None noted. Context: No documentation was available that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation for 4 of the 40 employees selected for testing. The sample was not considered statistically valid. Effect: When comparison of background investigations and suitability determinations are not performed, employees may be hired who do not meet laws and regulations to work in a school environment or employees may be hired who are not suitable to perform the positions they were hired for. Cause: Documentation that the background investigations were compared to the employment application and that a suitability determination was conducted by an appropriate adjudicating official was not maintained. Recommendation: It is recommended that the Club updates its Employment Suitability Investigations policy to accurately reflect the process for performing background investigations and employment suitability. Within that policy, the Club should ensure that a process is put in place to ensure documentation of the background investigations and employment suitability assessment is maintained in employee files. Management’s Response: The Club and Cherokee Central Schools (CCS) agree with this finding and CCS notes that its Employment Suitability Investigations policy was updated and formally adopted on July 22, 2019. The audit included a sample of employee files from prior years, before the policy was implemented and before consistent personnel changes were made. Since the policy's adoption, appropriate procedures have been put in place to ensure background investigations and employment suitability assessments are conducted and properly documented. CCS will continue to monitor compliance with the policy and ensure that documentation is consistently maintained in employee personnel files moving forward. Current updates to be enacted immediately include documentation that the Superintendent has reviewed the files.
Show full finding ▾Hide full finding ▴Finding 2025-004: Significant Deficiency – Special Tests and Provisions Program: Indian School Equalization Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Identification Number: N/A Federal Award Year: June 30, 2025 Repeat of Prior Year Finding 2024-005 Criteria: 25 CFR section 63.17 requires that Indian Tribes and tribal organizations perform adjudication to determine suitability for employment and efficiency of service. The adjudication process protects the interests of the employer and the rights of applicants and employees. Adjudication requires uniform evaluation to ensure fair and consistent judgment. Condition: While documentation exists that a background investigation was completed, no documentation was maintained that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation. Questioned Costs: None noted. Context: No documentation was available that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation for 4 of the 40 employees selected for testing. The sample was not considered statistically valid. Effect: When comparison of background investigations and suitability determinations are not performed, employees may be hired who do not meet laws and regulations to work in a school environment or employees may be hired who are not suitable to perform the positions they were hired for. Cause: Documentation that the background investigations were compared to the employment application and that a suitability determination was conducted by an appropriate adjudicating official was not maintained. Recommendation: It is recommended that the Club updates its Employment Suitability Investigations policy to accurately reflect the process for performing background investigations and employment suitability. Within that policy, the Club should ensure that a process is put in place to ensure documentation of the background investigations and employment suitability assessment is maintained in employee files. Management’s Response: The Club and Cherokee Central Schools (CCS) agree with this finding and CCS notes that its Employment Suitability Investigations policy was updated and formally adopted on July 22, 2019. The audit included a sample of employee files from prior years, before the policy was implemented and before consistent personnel changes were made. Since the policy's adoption, appropriate procedures have been put in place to ensure background investigations and employment suitability assessments are conducted and properly documented. CCS will continue to monitor compliance with the policy and ensure that documentation is consistently maintained in employee personnel files moving forward. Current updates to be enacted immediately include documentation that the Superintendent has reviewed the files.
Finding 2025-004: Significant Deficiency - Special Tests and Provisions Repeat of Prior Year Finding 2024-005 Condition: While documentation exists that a background investigation was completed, no documentation was maintained that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation. Corrective Action: The Club and Cherokee Central Schools (CCS) agree with this finding and CCS notes that its Employment Suitability Investigations policy was updated and formally adopted on July 22, 2019. The audit included a sample of employee files from prior years, before the policy was implemented and before consistent personnel changes were made. Since the policy's adoption, appropriate procedures have been put in place to ensure background investigations and employment suitability assessments are conducted and properly documented. CCS will continue to monitor compliance with the policy and ensure that documentation is consistently maintained in employee personnel files moving forward. Current updates to be enacted immediately include documentation that the Superintendent has reviewed the files. Person Responsible For Corrective Action: Heather Driver, Interim CCS HR Director Anticipated Completion Date: June 30, 2026
2024-005
The Club drew down federal funds in advance of actual cash needs. For two cash draws tested for each program, the federal funds were not disbursed to vendors within 5 business days of the funds being drawn down. Questioned Costs: None noted. Context: Two federal draws occurred during the fiscal year for each program. The sample is not considered statistically valid. Effect: Federal funds were drawn in advance of immediate cash needs, resulting in excess federal cash on hand and noncompliance with cash management regulations. This increases the risk that federal funds could be used inefficiently, interest liabilities could be incurred on excess cash balances and federal funding may not be managed in accordance with grant requirements. Cause: The full grant funding was drawn down in advance of related expenditures due to funding uncertainty under the guidance of the Environmental Protection Agency (EPA). Later in the fiscal year, the unspent portion of the funds were returned to the EPA when the funding certainty returned. In addition, one draw down was deposited into a different Club bank account than the account was expected so the Club was not aware that it had received the funding. Recommendation: It is recommended that the Club strengthen controls over federal cash draws to ensure draws are based on actual and immediate cash needs. Management should maintain supporting documentation showing how each draw amount was calculated and should draw down funds as close as administratively feasible to the disbursement of those funds. Management’s Response: The Club is working with the EBCI Grant’s office to increase communication and coordinate the drawdowns so funds are received and processed for payment within the given grant timelines.
Show full finding ▾Hide full finding ▴Finding 2025-005: Significant Deficiency – Cash Management Program: Clean School Bus Program; Climate Pollution Reduction Grants Assistance Listing Number: 66.045; 66.046 Federal Agency: U.S. Environmental Protection Agency Federal Award Identification Number: 03D07424; 03D30125 Federal Award Year: June 30, 2025 Criteria: The Uniform Guidance requires that recipients and subrecipients minimize the time elapsing between the transfer of federal funds and the disbursement of those funds. Advance payments must be limited to the minimum amounts needed and timed as close as administratively feasible to actual, immediate cash requirements for program costs. Recipients must also maintain written procedures to minimize the time between drawdown and disbursement. Condition: The Club drew down federal funds in advance of actual cash needs. For two cash draws tested for each program, the federal funds were not disbursed to vendors within 5 business days of the funds being drawn down. Questioned Costs: None noted. Context: Two federal draws occurred during the fiscal year for each program. The sample is not considered statistically valid. Effect: Federal funds were drawn in advance of immediate cash needs, resulting in excess federal cash on hand and noncompliance with cash management regulations. This increases the risk that federal funds could be used inefficiently, interest liabilities could be incurred on excess cash balances and federal funding may not be managed in accordance with grant requirements. Cause: The full grant funding was drawn down in advance of related expenditures due to funding uncertainty under the guidance of the Environmental Protection Agency (EPA). Later in the fiscal year, the unspent portion of the funds were returned to the EPA when the funding certainty returned. In addition, one draw down was deposited into a different Club bank account than the account was expected so the Club was not aware that it had received the funding. Recommendation: It is recommended that the Club strengthen controls over federal cash draws to ensure draws are based on actual and immediate cash needs. Management should maintain supporting documentation showing how each draw amount was calculated and should draw down funds as close as administratively feasible to the disbursement of those funds. Management’s Response: The Club is working with the EBCI Grant’s office to increase communication and coordinate the drawdowns so funds are received and processed for payment within the given grant timelines.
Finding 2025-005: Significant Deficiency - Cash Management Condition: The Club drew down federal funds in advance of actual cash needs. For two cash draws tested for each program, the federal funds were not disbursed to vendors within 5 business days of the funds being drawn down. Corrective Action: The Club is working with the EBCI Grant's office to increase communication and coordinate the drawdowns so funds are received and processed for payment within the given grant timelines. Person Responsible For Corrective Action: Rhonica Via, Finance Director Anticipated Completion Date: June 30, 2026
Documentation that supported the evidence of quotes/bids, cost or price analysis, vendor selection rationale, required approvals and verification that the vendors selected were not suspended or debarred was not able to be located. Questioned Costs: None noted. Context: For Assistance Listing Number 66.045, the project funded by this grant program consisted of payments to a single vendor. For Assistance Listing Number 66.046, the project funded by this grant program consisted of payments to two vendors. The sample is not considered statistically valid. Effect: The Club is not able to document its compliance with procurement and suspension and debarment requirements. Cause: During the grant writing process, the Eastern Band of Cherokee Indians Natural Resources office reached out to potential vendors to obtain quotes for the projects, but the documentation of the procurement process was not able to be located. Recommendation: It is recommended that the Club maintain documentation throughout the procurement process and store that documentation in a place where it can be easily located and accessed. Management’s Response: The Club will coordinate with the EBCI Grant office to ensure all future grants follow the Club and Tribal procurement processes.
Show full finding ▾Hide full finding ▴Finding 2025-006: Significant Deficiency – Procurement Program: Clean School Bus Program; Climate Pollution Reduction Grants Assistance Listing Number: 66.045; 66.046 Federal Agency: U.S. Environmental Protection Agency Federal Award Identification Number: 03D07424; 03D30125 Federal Award Year: June 30, 2025 Criteria: The Uniform Guidance requires that the documentation be maintained for the history of procurement, including the rationale for the method of procurement, selection of contract type, basis for contractor selection and the basis for the contract price. Condition: Documentation that supported the evidence of quotes/bids, cost or price analysis, vendor selection rationale, required approvals and verification that the vendors selected were not suspended or debarred was not able to be located. Questioned Costs: None noted. Context: For Assistance Listing Number 66.045, the project funded by this grant program consisted of payments to a single vendor. For Assistance Listing Number 66.046, the project funded by this grant program consisted of payments to two vendors. The sample is not considered statistically valid. Effect: The Club is not able to document its compliance with procurement and suspension and debarment requirements. Cause: During the grant writing process, the Eastern Band of Cherokee Indians Natural Resources office reached out to potential vendors to obtain quotes for the projects, but the documentation of the procurement process was not able to be located. Recommendation: It is recommended that the Club maintain documentation throughout the procurement process and store that documentation in a place where it can be easily located and accessed. Management’s Response: The Club will coordinate with the EBCI Grant office to ensure all future grants follow the Club and Tribal procurement processes.
Finding 2025-006: Significant Deficiency - Procurement Condition: Documentation that supported the evidence of quotes/bids, cost or price analysis, vendor selection rationale, required approvals and verification that the vendors selected were not suspended or debarred was not able to be located. Corrective Action: The Club will coordinate with the EBCI Grant office to ensure all future grants follow the Club and Tribal procurement processes. Person Responsible For Corrective Action: Rhonica Via, Finance Director Anticipated Completion Date: June 30, 2026
The Club notified the contractor of the wage rate requirements but did not obtain or review certified payroll records for each week in which work was performed under the contract. Questioned Costs: None noted. Context: Two contracts under the grant were subject to wage rate requirements. The sample is not considered statistically valid. Effect: The Club did not perform adequate monitoring of contractors to ensure compliance with applicable wage rate requirements, which increases the risk of noncompliance with grant requirements. Cause: Club personnel were advised by the Environmental Protection Agency (EPA) that certified payroll records would only need to be made available if the grant was under EPA audit, so certified payroll records were not obtained and reviewed each week in which work was performed under the contract. Recommendation: It is recommended that the Club implement policies and procedures to ensure that weekly certified payrolls are obtained from contractors subject to wage rate requirements and those payroll records are reviewed for compliance with the applicable wage rate requirements. Management’s Response: The Club Finance Director will work with the current contractor and set up a schedule for payroll review based on their payroll schedule.
Show full finding ▾Hide full finding ▴Finding 2025-007: Significant Deficiency – Special Tests and Provisions Program: Climate Pollution Reduction Grants Assistance Listing Number: 66.046 Federal Agency: U.S. Environmental Protection Agency Federal Award Identification Number: 03D30125 Federal Award Year: June 30, 2025 Criteria: The Uniform Guidance requires that entities obtain certified payroll records for each week in which work was performed under a contract funded by an award that contains Wage Rate Requirements and review those records for compliance with the applicable wage rate requirements. Condition: The Club notified the contractor of the wage rate requirements but did not obtain or review certified payroll records for each week in which work was performed under the contract. Questioned Costs: None noted. Context: Two contracts under the grant were subject to wage rate requirements. The sample is not considered statistically valid. Effect: The Club did not perform adequate monitoring of contractors to ensure compliance with applicable wage rate requirements, which increases the risk of noncompliance with grant requirements. Cause: Club personnel were advised by the Environmental Protection Agency (EPA) that certified payroll records would only need to be made available if the grant was under EPA audit, so certified payroll records were not obtained and reviewed each week in which work was performed under the contract. Recommendation: It is recommended that the Club implement policies and procedures to ensure that weekly certified payrolls are obtained from contractors subject to wage rate requirements and those payroll records are reviewed for compliance with the applicable wage rate requirements. Management’s Response: The Club Finance Director will work with the current contractor and set up a schedule for payroll review based on their payroll schedule.
Finding 2025-007: Significant Deficiency - Special Tests and Provisions Condition: The Club notified the contractor of the wage rate requirements but did not obtain or review certified payroll records for each week in which work was performed under the contract. Corrective Action: The Club Finance Director will work with the current contractor and set up a schedule for payroll review based on their payroll schdule. Person Responsible For Corrective Action: Rhonica Via, Finance Director Anticipated Completion Date: July 31, 2026
FAC accepted this audit on January 15, 2026 — management decision was due July 15, 2026.
The annual SF-425 was not reviewed by someone other than the preparer of the report. Questioned Costs: None noted. Context: There were three annual SF-425 reports required for the current year, each of which did not have review of the calculation of the amounts in the reports. The sample was not a statistically valid sample. Effect: The report may contain inaccurate information. Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are properly reviewed by someone other than the preparer. Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained. Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Show full finding ▾Hide full finding ▴Finding 2024-004: Significant Deficiency - Reporting Program: Indian School Equalization; Indian Education Facilities, Operations and Maintenance Assistance Listing Number: 15.042; 15.047 Federal Agency: U.S. Department of the Interior Federal Award Identification Number: N/A Federal Award Year: June 30, 2024 Repeat of Prior Year Finding 2023-004 Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors. Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Questioned Costs: None noted. Context: There were three annual SF-425 reports required for the current year, each of which did not have review of the calculation of the amounts in the reports. The sample was not a statistically valid sample. Effect: The report may contain inaccurate information. Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are properly reviewed by someone other than the preparer. Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained. Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2024-004: Significant Deficiency - Reporting Repeat of Prior Year Finding 2023-004 Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Corrective Action: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date. Person Responsible For Corrective Action: Rhonica Via, Finance Director Anticipated Completion Date: June 30, 2025
2023-004
While documentation exists that a background investigation was completed, no documentation was maintained that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation. Questioned Costs: None noted. Context: No documentation was available that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation for 6 of the 40 employees selected for testing. The sample was not considered statistically valid. Effect: When comparison of background investigations and suitability determinations are not performed, employees may be hired who do not meet laws and regulations to work in a school environment or employees may be hired who are not suitable to perform the positions they were hired for. Cause: Documentation that the background investigations were compared to the employment application and that a suitability determination was conducted by an appropriate adjudicating official was not maintained. Recommendation: It is recommended that the Club updates its Employment Suitability Investigations policy to accurately reflect the process for performing background investigations and employment suitability. Within that policy, the Club should ensure that a process is put in place to ensure documentation of the background investigations and employment suitability assessment is maintained in employee files. Management’s Response: The Club and Cherokee Central Schools (CCS) agree with this finding and CCS notes that its Employment Suitability Investigations policy was updated and formally adopted on July 22, 2019. The audit included a sample of employee files from prior years, before the policy was implemented and before consistent personnel changes were made. Since the policy's adoption, appropriate procedures have been put in place to ensure background investigations and employment suitability assessments are conducted and properly documented. CCS will continue to monitor compliance with the policy and ensure that documentation is consistently maintained in employee personnel files moving forward. Current updates to be enacted immediately include documentation that the Superintendent has reviewed the files.
Show full finding ▾Hide full finding ▴Finding 2024-005: Significant Deficiency – Special Tests and Provisions Program: Indian School Equalization Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Identification Number: N/A Federal Award Year: June 30, 2024 Repeat of Prior Year Finding 2023-008 Criteria: 25 CFR section 63.17 requires that Indian Tribes and tribal organizations perform adjudication to determine suitability for employment and efficiency of service. The adjudication process protects the interests of the employer and the rights of applicants and employees. Adjudication requires uniform evaluation to ensure fair and consistent judgment. Condition: While documentation exists that a background investigation was completed, no documentation was maintained that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation. Questioned Costs: None noted. Context: No documentation was available that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation for 6 of the 40 employees selected for testing. The sample was not considered statistically valid. Effect: When comparison of background investigations and suitability determinations are not performed, employees may be hired who do not meet laws and regulations to work in a school environment or employees may be hired who are not suitable to perform the positions they were hired for. Cause: Documentation that the background investigations were compared to the employment application and that a suitability determination was conducted by an appropriate adjudicating official was not maintained. Recommendation: It is recommended that the Club updates its Employment Suitability Investigations policy to accurately reflect the process for performing background investigations and employment suitability. Within that policy, the Club should ensure that a process is put in place to ensure documentation of the background investigations and employment suitability assessment is maintained in employee files. Management’s Response: The Club and Cherokee Central Schools (CCS) agree with this finding and CCS notes that its Employment Suitability Investigations policy was updated and formally adopted on July 22, 2019. The audit included a sample of employee files from prior years, before the policy was implemented and before consistent personnel changes were made. Since the policy's adoption, appropriate procedures have been put in place to ensure background investigations and employment suitability assessments are conducted and properly documented. CCS will continue to monitor compliance with the policy and ensure that documentation is consistently maintained in employee personnel files moving forward. Current updates to be enacted immediately include documentation that the Superintendent has reviewed the files.
Finding 2024-005: Significant Deficiency - Special Tests and Provisions Repeat of Prior Year Finding 2023-008 Condition: While documentation exists that a background investigation was completed, no documentation was maintained that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation. Corrective Action: The Club and Cherokee Central Schools (CCS) agree with this finding and CCS notes that its Employment Suitability Investigations policy was updated and formally adopted on July 22, 2019. The audit included a sample of employee files from prior years, before the policy was implemented and before consistent personnel changes were made. Since the policy's adoption, appropriate procedures have been put in place to ensure background investigations and employment suitability assessments are conducted and properly documented. CCS will continue to monitor compliance with the policy and ensure that documentation is consistently maintained in employee personnel files moving forward. Current updates to be enacted immediately include documentation that the Superintendent has reviewed the files. Person Responsible For Corrective Action: Heather Driver, Interim CCS HR Director Anticipated Completion Date: June 30, 2025
2023-008
FAC accepted this audit on August 5, 2025 — management decision was due February 5, 2026.
The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023. Questioned Costs: None noted. Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample. Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report. Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely. Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained. Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Show full finding ▾Hide full finding ▴Finding 2023-004: Significant Deficiency - Reporting Program: Indian School Equalization; Indian Schools Student Transportation; Administrative Cost Grants for Indian Schools; Title I Grants to Local Educational Agencies; COVID-19 – Education Stabilization Fund Assistance Listing Number: 15.042; 15.044; 15.046; 84.010; 84.425 Federal Agency: U.S. Department of the Interior; U.S. Department of Education Federal Award Identification Number: N/A Federal Award Year: June 30, 2019; June 30, 2023 Repeat of Prior Year Finding 2022-003 Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors. Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023. Questioned Costs: None noted. Context: There was one annual SF-425 report required for the current year, which contained inaccurate data and was not submitted in a timely manner. The sample was not a statistically valid sample. Effect: Users of the annual report were not provided the report in a timely manner and may contain inaccurate information from the report. Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are accurate and submitted timely. Recommendation: We recommend that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained. Management’s Response: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date.
Finding 2023-004: Significant Deficiency - Reporting Repeat of Prior Year Finding 2022-003 Condition: The annual SF-425 was not reviewed by someone other than the preparer of the report. Certain amounts included on the annual SF-425, Federal Financial Report, for the year ended June 30, 2023, were not accurate. In addition, the SF-425 report was not submitted to the grantor agency by the due date of September 28, 2023. Corrective Action: The Club agrees with this finding as the annual SF-425 report was not submitted by the appropriate deadline. The Club will also establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the SF-425 before submitting to ensure accurate and timely reporting. The Club will comply with Uniform Guidance requirements of SF-425 by submitting an annual report to the grantors by its due date. Person Responsible For Corrective Action: Rhonica Via, Finance Director Anticipated Completion Date: June 30, 2025
2022-003
The Club was unable to locate the initial program application documentation for one individual selected for testing. Questioned Costs: None noted. Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid. Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program. Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process. Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation. Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Show full finding ▾Hide full finding ▴Program: CCDF Cluster Assistance Listing Number: 93.575; 93.596 Federal Agency: U.S. Department of Health and Human Services Federal Award Identification Number: N/A Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023 Criteria: CCDF regulations at 45 CFR §98.90 require that Lead Agencies retain documentation showing they have expended funds in compliance with CCDF law for at least three years from the day the Lead Agency submits the financial reports required by the Secretary or until complete resolution of any litigation or similar legal action involving records and make documents available to the federal government upon request. Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing. Questioned Costs: None noted. Context: The initial program application documentation was not able to be located for one of the six individuals selected for testing. The sample was not considered statistically valid. Effect: The Club is not able to provide documentation that the individual was eligible to receive a child care subsidy under the Child Care and Development Fund (CCDF) program. Cause: The Club moved its files to a different location during a renovation and the individual's file was misplaced during the process. Recommendation: It is recommended that the Club has a designated location to securely store all CCDF program documentation. In addition, it is recommended that the Club review documentation for other individuals to ensure no other documents were misplaced during the renovation. Management’s Response: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility.
Finding 2023-005: Significant Deficiency - Eligibility Condition: The Club was unable to locate the initial program application documentation for one individual selected for testing. Corrective Action: The Club agrees with this finding and will establish a process for storing all past and present student and staff files in a secure location to maintain all necessary applications and other documents related to enrollment and eligibility. Person Responsible For Corrective Action: Leslie McEntire, Childcare Manager Anticipated Completion Date: June 30, 2025
Documentation of the review and approval of certain expenditures was unable to be located. Questioned Costs: None noted. Context: The documentation of the review and approval of expenditures was not able to be located for two of the six expenditures selected for testing. There were a total of 23 expenditures charged to the program during fiscal year 2023. The sample was not considered statistically valid. Effect: When expenditures are not properly reviewed and approved, unallowable costs could be charged to federal programs. Cause: The Club has not implemented an effective system of internal controls over maintaining documentation of the review and approval of program expenditures. Recommendation: It is recommended that the Club ensures that internal controls are adequately maintained to ensure that the review and approval of program expenditures occurs and that the documentation of that review and approval is appropriately maintained. Management’s Response: The Club agrees with this finding and has established procedures to ensure that all required signatures are obtained before posting intercompany expenses for transportation. The Assistant Finance Director receives the monthly invoices from the Bus Department and forwards them to the Cherokee Central Schools Finance Director for approval before completing the monthly posting.
Show full finding ▾Hide full finding ▴Finding 2023-006: Significant Deficiency – Allowable Costs/Cost Principles Program: Indian Schools Student Transportation Assistance Listing Number: 15.044 Federal Agency: U.S. Department of the Interior Federal Award Identification Number: N/A Federal Award Year: June 30, 2023 Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that a review and approval of all expenditures occurs and that appropriate documentation of that review and approval is maintained. Condition: Documentation of the review and approval of certain expenditures was unable to be located. Questioned Costs: None noted. Context: The documentation of the review and approval of expenditures was not able to be located for two of the six expenditures selected for testing. There were a total of 23 expenditures charged to the program during fiscal year 2023. The sample was not considered statistically valid. Effect: When expenditures are not properly reviewed and approved, unallowable costs could be charged to federal programs. Cause: The Club has not implemented an effective system of internal controls over maintaining documentation of the review and approval of program expenditures. Recommendation: It is recommended that the Club ensures that internal controls are adequately maintained to ensure that the review and approval of program expenditures occurs and that the documentation of that review and approval is appropriately maintained. Management’s Response: The Club agrees with this finding and has established procedures to ensure that all required signatures are obtained before posting intercompany expenses for transportation. The Assistant Finance Director receives the monthly invoices from the Bus Department and forwards them to the Cherokee Central Schools Finance Director for approval before completing the monthly posting.
Finding 2023-006: Significant Deficiency - Allowable Costs/Cost Principles Condition: Documentation of the review and approval of certain expenditures was unable to be located. Corrective Action: The Club agrees with this finding and has established procedures to ensure that all required signatures are obtained before posting intercompany expenses for transportation. The Assistant Finance Director receives the monthly invoices from the Bus Department and forwards them to the Cherokee Central Schools Finance Director for approval before completing the monthly posting. Person Responsible For Corrective Action: Barry McMillan, Assistant Finance Director Anticipated Completion Date: June 30, 2024
Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports. Questioned Costs: None noted. Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample. Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information. Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports. Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained. Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Show full finding ▾Hide full finding ▴Finding 2023-007: Significant Deficiency – Reporting Program: CCDF Cluster Assistance Listing Number: 93.575; 93.596 Federal Agency: U.S. Department of Health and Human Services Federal Award Identification Number: N/A Federal Award Year: June 30, 2021; June 30, 2022; June 30, 2023 Criteria: The Uniform Guidance requires that an entity establish a system of properly-functioning internal controls and that all reporting be submitted accurately and within the time frames prescribed by the grantors. Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports. Questioned Costs: None noted. Context: There was no documented review or approval for both of the annual ACF-696T reports selected for testing. There were four annual ACF-696T reports required for the current year. The sample was not a statistically valid sample. Effect: Without an effective review and approval process, the annual ACF-696T reports may contain inaccurate information. Cause: The Club has not implemented an effective system of internal controls over reporting to ensure that the reports are reviewed and approved by someone within the Club, other than the original preparer of the reports. Recommendation: It is recommended that the Club implement proper review of the reporting process. Someone other than the preparer of the report should provide adequate review prior to finalizing and submitting the report. This review should include verification that amounts included on the report agree to the underlying general ledger detail as of the report date and verification that the report is submitted by the due date. These procedures should be documented and retained. Management’s Response: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting.
Finding 2023-007: Significant Deficiency - Reporting Condition: Annual ACF-696T reports were not reviewed by someone other than the preparer of the reports. Corrective Action: The Club agrees with this finding and will establish a review process in their policy and procedures to ensure that someone other than the person preparing the report reviews the annual ACF-696T reports before submitting them to ensure accurate reporting. Person Responsible For Corrective Action: Rhonica Via, Finance Director Anticipated Completion Date: June 30, 2025
While documentation exists that a background investigation was completed, no documentation was maintained that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation. Questioned Costs: None noted. Context: No documentation was available that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation for 4 of the 40 employees selected for testing. The sample was not considered statistically valid. Effect: When comparison of background investigations and suitability determinations are not performed, employees may be hired who do not meet laws and regulations to work in a school environment or employees may be hired who are not suitable to perform the positions they were hired for. Cause: Documentation that the background investigations were compared to the employment application and that a suitability determination was conducted by an appropriate adjudicating official was not maintained. Recommendation: It is recommended that the Club updates its Employment Suitability Investigations policy to accurately reflect the process for performing background investigations and employment suitability. Within that policy, the Club should ensure that a process is put in place to ensure documentation of the background investigations and employment suitability assessment is maintained in employee files. Management’s Response: The Club and Cherokee Central Schools (CCS) agree with this finding and CCS notes that its Employment Suitability Investigations policy was updated and formally adopted on July 22, 2019. The audit included a sample of employee files from prior years, before the policy was implemented and before consistent personnel changes were made. Since the policy's adoption, appropriate procedures have been put in place to ensure background investigations and employment suitability assessments are conducted and properly documented. CCS will continue to monitor compliance with the policy and ensure that documentation is consistently maintained in employee personnel files moving forward. Current updates to be enacted immediately include documentation that the Superintendent has reviewed the files.
Show full finding ▾Hide full finding ▴Finding 2023-008: Significant Deficiency – Special Tests and Provisions Program: Indian School Equalization Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Identification Number: N/A Federal Award Year: June 30, 2023 Criteria: 25 CFR section 63.17 requires that Indian Tribes and tribal organizations perform adjudication to determine suitability for employment and efficiency of service. The adjudication process protects the interests of the employer and the rights of applicants and employees. Adjudication requires uniform evaluation to ensure fair and consistent judgment. Condition: While documentation exists that a background investigation was completed, no documentation was maintained that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation. Questioned Costs: None noted. Context: No documentation was available that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation for 4 of the 40 employees selected for testing. The sample was not considered statistically valid. Effect: When comparison of background investigations and suitability determinations are not performed, employees may be hired who do not meet laws and regulations to work in a school environment or employees may be hired who are not suitable to perform the positions they were hired for. Cause: Documentation that the background investigations were compared to the employment application and that a suitability determination was conducted by an appropriate adjudicating official was not maintained. Recommendation: It is recommended that the Club updates its Employment Suitability Investigations policy to accurately reflect the process for performing background investigations and employment suitability. Within that policy, the Club should ensure that a process is put in place to ensure documentation of the background investigations and employment suitability assessment is maintained in employee files. Management’s Response: The Club and Cherokee Central Schools (CCS) agree with this finding and CCS notes that its Employment Suitability Investigations policy was updated and formally adopted on July 22, 2019. The audit included a sample of employee files from prior years, before the policy was implemented and before consistent personnel changes were made. Since the policy's adoption, appropriate procedures have been put in place to ensure background investigations and employment suitability assessments are conducted and properly documented. CCS will continue to monitor compliance with the policy and ensure that documentation is consistently maintained in employee personnel files moving forward. Current updates to be enacted immediately include documentation that the Superintendent has reviewed the files.
Finding 2023-008: Significant Deficiency - Special Tests and Provisions Condition: While documentation exists that a background investigation was completed, no documentation was maintained that the results of the background investigation were compared to the employment application or that a suitability determination was conducted by an appropriate adjudicating official who herself/himself was the subject of a favorable background investigation. Corrective Action: The Club and Cherokee Central Schools (CCS) agree with this finding and CCS notes that its Employment Suitability Investigations policy was updated and formally adopted on July 22, 2019. The audit included a sample of employee files from prior years, before the policy was implemented and before consistent personnel changes were made. Since the policy's adoption, appropriate procedures have been put in place to ensure background investigations and employment suitability assessments are conducted and properly documented. CCS will continue to monitor compliance with the policy and ensure that documentation is consistently maintained in employee personnel files moving forward. Current updates to be enacted immediately include documentation that the Superintendent has reviewed the files. Person Responsible For Corrective Action: Heather Driver, Interim CCS HR Director Anticipated Completion Date: June 30, 2024
FAC accepted this audit on December 10, 2023 — management decision was due June 10, 2024.
2020-005
FAC accepted this audit on May 9, 2022 — management decision was due November 9, 2022.
FAC accepted this audit on March 31, 2019 — management decision was due October 1, 2019.
GSA_MIGRATION
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GSA_MIGRATION
2017-002
FAC accepted this audit on November 20, 2018 — management decision was due May 20, 2019.
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