LEUPP SCHOOLS, INC.Tribal Government

Finding Number: 2022-001 Repeat Finding: Yes, 2021-002 Program Names/Assistance Listing Titles: Indian School Equalization; Indian Education Facilities, Operations, and Maintenance Assistance Listing Numbers: 15.042; 15.047 Federal Award Numbers: A19AV00865 Questioned Costs: N/A Federal Agency: U.S. Department of the Interior Pass-Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Reporting CRITERIA Per the grant agreement, the School is required to file SF-425 Quarterly Financial Statements (2 CFR Subpart D ?200.327). Furthermore, the reports should agree to the School?s supporting documentation for federal revenues. CONDITION The School did not meet its financial reporting obligations during the year. CAUSE The School did not have an adequate system in place to maintain compliance with these requirements EFFECT The School was not always in compliance with federal regulations and guidelines. Less than full compliance with these reporting requirements could potentially result in a reduction or discontinuation of program awards in the future. CONTEXT During our review of the School?s SF-425 reports, we noted the following: - The first quarter SF-425 report included $9,491 of non-federal revenues and $67 of nonfederal disbursements. - The second and third quarter SF-425 reports included $980 of non-federal revenues and $67 of non-federal disbursements. - The fourth quarter SF-425 report included $1,491 of non-federal revenues and $67 of non-federal disbursements. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should implement standard procedures to ensure submission of accurate reports. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

Finding Number: 2021-001 Repeat Finding: Yes, 2020-001 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Number: A19AV00865 Pass-Through Agency: Bureau of Indian Affairs Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as sub-recipients of states, must follow the procurement standards set out at 2 CFR ?200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements in the 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of verbal quotes for purchases of at least $3,000 but less than $20,000, written quotes for purchases of at least $20,000 but no more than $50,000, and formal bid procedures for purchases over $50,000. Additionally, the manual requires procurement records to be maintained for three years after the School or the School?s agents, subcontractors, or obligors make the final payment and all other pending matters are closed. Finally, the Uniform Guidance requires employees to verify that the vendor, supplier, contractor, subcontractor, provider or their respective principals (e.g., owners, top management, etc.) with expenditures in excess of $25,000 are not suspended, debarred, or otherwise excluded by the Federal Government. The School should consult the Federal Excluded Parties List System (EPLS) before awarding funds and print the documentation to maintain in the contract file. This requirement is specified in 2 CFR ?180.220. CONDITION The School did not always follow its Board adopted Policies and Procedures Manual or federal regulations for purchases below the Simplified Acquisition threshold of $150,000 in the administration of procurements. CAUSE Inadequate training and record keeping. EFFECT The School was not in compliance with the Board adopted Policies and Procedures Manual. Additionally, the School was not compliant with 2 CFR ?180.220 and, as a result, could have made purchases from a suspended or debarred party. However, it was determined that the vendor was not suspended or debarred. CONTEXT During our review of procurement, the following were noted: For one purchase in the School?s oral quote range, the School did not obtain or maintain quotes. For one vendor with expenditures over $25,000 reviewed, the School did not perform the suspension and debarment check. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should provide applicable training to ensure employees adhere to their Board adopted Policies and Procedures Manual and the Suspension and Debarment requirements under 2 CFR ?180.220. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

Finding Number: 2021-002 Repeat Finding: Yes, 2020-002 Program Names/Assistance Listing Titles: Indian School Equalization, Indian Education Facilities, Operations, and Maintenance Assistance Listing Numbers: 15.042, 15.047 Federal Award Numbers: A19AV00865, A19AV00865 Questioned Costs: N/A Federal Agency: U.S. Department of the Interior Pass-Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Reporting CRITERIA Per the grant agreement, the School is required to file SF-425 Quarterly Financial Statements (2 CFR Subpart D ?200.327). Furthermore, the reports should agree to the School?s supporting documentation for federal revenues. CONDITION The School did not meet its financial reporting obligations during the year. CAUSE The School did not have an adequate system in place to maintain compliance with these requirements. EFFECT The School was not always in compliance with federal regulations and guidelines. Less than full compliance with these reporting requirements could potentially result in a reduction or discontinuation of program awards in the future. CONTEXT During our review of the School?s SF-425 reports, we noted the following: -The second quarter SF-425 report included $1,431 of non-federal revenues. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should implement standard procedures to ensure submission of accurate reports. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

Finding Number: 2021-003 Repeat Finding: Yes, 2020-003 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Number: A19AV00865 Pass-Through Agency: Bureau of Indian Affairs Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to the Indian Child Protection and Family Violence Prevention Act (25 USC ?3201 et. sec.), the School must conduct a character investigation 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. The investigation should be reinvestigated every five years. The Act further states that the School may employ individuals in those positons only if the individuals meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63). CONDITION The School did not have timely character investigations performed for all employees. CAUSE School policies were not always followed or controls were not in place to ensure timely character investigations are performed. EFFECT The School was not in compliance with the Indian Child Protection and Family Violence Prevention Act. CONTEXT During our review of the School?s character investigations, the following were noted: -For two of 14 employee files reviewed, the character investigations were not performed timely. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should ensure adequate character investigations are performed in a timely manner to achieve full compliance with the School?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

Finding Number: 2020-001 Repeat Finding: No Program Name/CFDA Title: Indian School Equalization Program CFDA Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Number: A19AV00865 Pass-Through Agency: Bureau of Indian Affairs Questioned Costs: N/A Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Procurement, Suspension, and Debarment CRITERIA Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR ??200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. The Board adopted a Policies and Procedures Manual that requires the collection of verbal quotes for purchases of at least $3,000 but less than $20,000, written quotes for purchases of at least $20,000 but no more than $50,000, and formal bid procedures for purchases over $50,000. Additionally, the manual requires procurement records to be maintained for three years after the School or School?s agents, subcontractors or obligors make the final payment and all other pending matters are closed. Finally, the Uniform Guidance requires employees to verify that the vendor, supplier, contractor, subcontractor, provider or their respective principals (e.g., owners, top management, etc.) with expenditures in excess of $25,000 are not suspended, debarred or otherwise excluded by the Federal Government. The School should consult the Federal Excluded Parties List System (EPLS) before awarding funds and print the documentation to maintain in the contract file. This requirement is specified in 2 CFR ?180.220. CONDITION The School did not follow its Board adopted Policies and Procedures Manual or federal regulations for purchases below the Simplified Acquisition threshold of $150,000 in the administration of procurements. CAUSE Lack of knowledge, inadequate training, turnover of key positions, and inadequate record keeping. EFFECT The School was not in compliance with the Board adopted Policies and Procedures Manual. Additionally, the School was not compliant with 2 CFR ?180.220 and as a result could have entered into a contract with a suspended or debarred party. However, it was determined that the vendors were not suspended or debarred. CONTEXT During our review of procurement, the following were noted: For all three purchases in the School?s formal bid range, the School did not perform a sealed bid or proposal. For one purchase in the School?s written quote range, the School did not obtain or maintain quotes. For all four purchases in the School?s oral quote range, the School did not obtain or maintain quotes. For one purchase noted as a sole source, the School did not maintain documentation that there was only one source and that the determination was reasonable. For all three covered transactions reviewed, the School did not perform the suspension and debarment check. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should adhere to their Board adopted Policies and Procedures Manual and the Suspension and Debarment requirements under 2 CFR ?180.220. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

Finding Number: 2020-002 Repeat Finding: Yes, 2019-007 Program Names/CFDA Titles: Indian School Equalization Program; Indian Education Facilities, Operation, and Maintenance CFDA Numbers:15.042; 15.047 Federal Award Numbers: A19AV00865 Questioned Costs: N/A Federal Agency: U.S. Department of the Interior Pass-Through Agency: Bureau of Indian Affairs Type of Findings: Noncompliance, Significant Deficiency Compliance Requirements: Reporting CRITERIA The School is required to file the Federal Financial Report, SF-425. Quarterly and semi-annual reports are required to be submitted no later than 30 days after the end of each reporting period. Annual reports are required to be submitted no later than 90 days at the end of each reporting period. CONDITION The School did not meet its financial reporting obligations during the year. CAUSE The School did not have an adequate system in place to monitor compliance with these requirements. EFFECT The School was not always in compliance with federal regulations and guidelines. Less than full compliance with these reporting requirements could potentially result in a reduction or discontinuation of program awards in the future. CONTEXT During our review of the School?s SF-425 reports, we noted the following: The first quarter SF-425 report was not submitted timely. The fourth quarter SF-425 report included $6,829 of non-federal revenues. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should implement standard procedures for the creation and submission of accurate reports on a timely basis. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

Finding Number: 2020-003 Repeat Finding: Yes, 2019-005 Program Name/CFDA Title: Indian School Equalization Program CFDA Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Number: A19AV00865 Pass-Through Agency: Bureau of Indian Affairs Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to the Indian Child Protection and Family Violence Protection Act (25 USC ?3201 et. sec.), the School must conduct a character investigation 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. The investigation should be reinvestigated every five years. The Act further states that the School may employ individuals in those positions only if the individuals meet standards of character, no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFR part 63). CONDITION The School did not have current and timely character investigations for all employees. In addition, the School did not have adequate character investigations on file for all employees. CAUSE School policies were not always followed or controls were not in place to ensure timely character investigations are performed and all adequate documentation is maintained and turnover in key positions. EFFECT The School was not in compliance with the Indian Child Protection and Family Violence Protection Act. CONTEXT During our review of the School?s character investigations, the following were noted: For two of nine employee files reviewed, the employee file did not have a complete federal background check on file, therefore it could not be determined whether the character investigation was completed timely and was still valid. For two of nine employee files reviewed, the character investigations were not performed timely. For one of nine employee files reviewed, the employee file's background investigation had expired and a current investigation was not on file. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should ensure adequate character investigations are performed and documentation is maintained in a timely manner to achieve full compliance with the School?s policies and the Indian Child Protection and Family Violence Prevention Act. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

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