KEAMS CANYON ELEMENTARY SCHOOL

According to generally accepted accounting principles (GAAP), School management is responsible for establishing and maintaining internal controls over financial reporting to include controls over the School's accounting records and general ledger transactions

School management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure that all financial activities are properly processed and reported.

Management is responsible for maintaining controls over capital assets in accordance with 2 CFR 200.313 including updating capital asset schedules for assets purchased with Federal award monies.

According to the Indian Child Protection and Family Violence Protection Act (25 USC 3201 etc. 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 Schools 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).

According to generally accepted accounting principles (GAAP), School management is responsible for establishing and maintaining internal controls over financial reporting to include controls over the School's accounting records and general ledger transactions

School management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure that all financial activities are properly processed and reported.

Management is responsible for maintaining controls over capital assets in accordance with 2 CFR 200.313 including updating capital asset schedules for assets purchased with Federal award monies.

According to the Indian Child Protection and Family Violence Protection Act (25 USC 3201 etc. 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 Schools 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).

According to generally accepted accounting principles (GAAP), School management is responsible for establishing and maintaining internal controls over financial reporting to include controls over the School's accounting records and general ledger transactions

School management is responsible for establishing and maintaining internal controls over disbursements that are adequate to ensure that all financial activities are properly processed and reported.

Management is responsible for maintaining controls over capital assets in accordance with 2 CFR 200.313 including updating capital asset schedules for assets purchased with Federal award monies.

According to the Indian Child Protection and Family Violence Protection Act (25 USC 3201 etc. 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 Schools 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).

Finding Number: 2021-001 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Number: A19AV00875 Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Procurement and Suspension and Debarment Criteria The Board adopted policies in accordance with 2 CFR ?180.220 that requires the collection of quotes for purchases of at least $10,000 but no more than $250,000, and formal bid procedures for purchases over $250,000. In addition, 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 Campus 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 or federal regulations regarding the collection of quotes, suspension and debarment checks, and conflict of interest files. Cause The School has not implemented controls to perform the collection of quotes, suspension and debarment checks for vendors, and maintaining conflict of interest files. Effect The School was not in compliance with the Board adopted policies. 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. Context Samples were not intended to be, and were not, statistically valid samples. The following items were noted during our review of procurement requirements: ? For eight of ten purchases within the quote range, determined that quotes were not obtained/retained. ? For all five purchases reviewed over $25,000, a suspension and debarment check was not performed. ? The School does not have conflict of interest policies in place for employees and Governing Board members, and no conflict of interest disclosures are filed. Recommendation The School should adhere to its Board adopted policies and implement procedures for performing suspension and debarment checks and using conflict of interest files. Views Of Responsible Officials See Corrective Action Plan.

Finding Number: 2021-002 Repeat Finding: Yes, 2020-102 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00875 N/A Administrative Cost Grants for Indian Schools 15.046 A19AV00875 N/A COVID-19 Education Stabilization Fund 84.425 A19AV00875 N/A Federal Agency: U.S. Department of Education; U.S. Department of Interior Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Reporting Criteria The School is required to report cumulative program outlays and program income on the Federal Financial Report, SF-425 (7 CFR ? 2500.046). Quarterly reports are required to be submitted no later than 30 days after the end of each reporting period. Single audit reporting packages must have a report date nine months after fiscal year-end. Due to COVID-19 this was extended by an additional six months (2 CFR Part 200 Subpart F). Condition Federal Financial Reports SF-425 were not always submitted timely. In addition, the audit was not completed by the extended deadline. Cause School policies were not always followed or controls were not in place to ensure complete and accurate information could be provided timely. In addition, the COVID-19 pandemic delayed the single audit reporting package. EFFECT The School was not in compliance with federal regulations and guidelines for SF-425 and single audit submissions. Context Quarterly SF-425 reports were not submitted within 30 days after the end of each reporting period. In addition, the single audit report was not completed within 15 months of year end. Samples were not intended to be, and were not, statistically valid samples. Recommendation The School should implement controls for filing the Federal Financial Reports, SF-425, and the single audit report in a timely manner. Views Of Responsible Officials See Corrective Action Plan.

Finding Number: 2021-003 Repeat Finding: Yes, 2020-103 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A19AV00875 N/A COVID-19 Education Stabilization Fund 84.425 A19AV00875 N/A Federal Agency: U.S. Department of Education; U.S. Department of Interior Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Equipment and Real Property Management Criteria Management is responsible for maintaining controls over capital assets in accordance with 2 CFR 200.313 including updating capital asset schedules for assets purchased with Federal award monies. Condition The School did not have adequate internal controls in place to prepare complete and accurate capital asset schedules. Cause The School lacks procedures to properly review expenditures for capital additions and for completing an inventory. Effect Capital assets purchased with Federal award monies are not properly tracked. Context Samples were not intended to be, and were not, statistically valid samples. The following items were noted during our review of equipment and real property management requirements: ? Expenditures for items purchased with federal award monies that should have been included as capital asset additions were not recorded on the School?s capital asset listing. ? The School did not perform a capital outlay reconciliation for the fiscal year. ? An inventory of capital assets has not been performed by the School in the last two years. Recommendation The School should allocate the necessary resources to implement controls and procedures to ensure capital asset listings are prepared accurately. The School should also provide staff with the training necessary to identify potential capital assets. Views Of Responsible Officials See Corrective Action Plan.

Findings And Questioned Costs Related To Federal Awards Finding Number: 2021-004 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Number: A19AV00875 Pass-Through Agency: Bureau of Indian Education 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 employee 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 timely character investigations performed 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. Effect The School was not in compliance with the Indian Child Protection and Family Violence Prevention Act. Context Samples were not intended to be, and were not, statistically valid samples. During our review of the School?s character investigations, we noted the following: ? For four of 41 background investigations reviewed, the background check on file was over five years old. ? For six of 41 background investigations reviewed, a background check was not retained. Recommendation The School should ensure adequate character investigations are performed in a timely manner and documentation is maintained 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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