Gila Crossing Community SchoolTribal Government

Finding Number: 2025‐001 Repeat Finding: Yes, 2024‐001, 2023‐001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency(ies): U.S. Department of Interior Federal Award Number: A24AV00760 Pass‐Through Agency: Bureau of Indian Education 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 925 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 conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFS part 63). Condition The School did not complete character reinvestigations timely for all employees. In addition, the School did not properly document completed character reinvestigations for all employees. Cause School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely and properly documented. 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, we noted the following: - For four of 25 character investigations reviewed, the five year reinvestigation was not completed within five years. Of the four character investigations, two were a repeat finding from the prior year audit. - For three of 25 character investigations reviewed, the School did not maintain evidence that the suitability determination was conducted. Although a character investigation was performed by the FBI and favorable results were communicated to the School, the Certification of Investigation and Adjudication form were not completed and signed by an appropriate adjudicating official until being informed by auditors. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should ensure 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.

Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00813 N/A Administrative Cost Grants for Indian Schools 15.046 A23AV00813 N/A Special Education Cluster (IDEA) 84.027 A24AV00760 N/A Federal Agency(ies): U.S. Department of Interior Pass‐Through Agency(ies): Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement and Suspension and Debarment Criteria Non‐federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320. Condition The School’s internal controls over procurement of goods and services were not adequate. Cause The School has procures in place to perform procurement, suspension, and debarment in accordance with federal regulations and guidelines, however, they were not followed. Effect The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. Context - The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to two vendors with the Special Education Cluster (IDEA) and one vendor with the Administrative Cost Grants for Indian Schools. - For three non‐cooperative‐purchase vendors paid in excess of the small purchase threshold ($10,000), the School did not prepare and maintain documentation for at least 3 written quotes from qualified sources. The deficiency applied to two vendors with the Administrative Cost Grant, and one vendor with the Special Education Cluster (IDEA). -For all eight vendors procured via sole source reviewed, the School did not prepare and maintain documentation in accordance with School policy that there was only one sole source and that the determination was reasonable. Additionally, the School did not present the procurement to the Board for approval as a sole source for all eight vendors. The deficiency applied to five vendors procured through funding from the Administrative Cost Grant for Indian Schools, two vendors procured through funding from the Indian School Equalization Program, and one vendor which was procured through various sources of federal funding. -For the first of three vendors reviewed with whom the School had purchases exceeding $50,000 during the fiscal year, the School did not perform a sealed procurement. For the second of three vendors reviewed with whom the School had purchases exceeding $50,000 during the fiscal year, the School did not retain evidence that a sealed procurement was performed. Finally, for the third of three vendors reviewed with whom the School had purchases exceeding $50,000, the School did not maintain evidence that bids were solicited from an adequate known suppliers, were opened at the prescribed time and place, and that the award was made to the lowest responsive/responsible bidder. All three deficiencies applied to the Special Education Cluster (IDEA). The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2025‐003 Repeat Finding: Yes, 2024‐003, 2023‐003 Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency(ies): U.S. Department of Interior Federal Award Number: A23AV00813 Pass‐Through Agency(ies): Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment and Real Property Management Criteria Local governments and Indian tribes shall follow 2 CFR 200 for equipment acquired under federal awards received directly from a federal awarding agency. Institutions of higher education, hospitals, and other non‐profit organizations shall follow the provisions of Uniform Guidance. The Uniform Guidance requires that equipment be used in the program for which it was acquired or, when appropriate, other federal programs. Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequatelymaintained. Condition The School lacked adequate internal controls over its accounting of capital assets and inventory processes. Cause The School has not been able to devote proper resources and training to ensure capital assets are accurate and up to date. Effect The School’s internal controls over capital assets were not adequate to ensure that a misstatement would be prevented and/or detected. The School was not in compliance with requirements set by the federal government. Context During our review of the School’s capital asset schedules we noted the following: - The capital asset listing does not include identification numbers for individual assets. - Capital asset policies appear outdated and need to be updated; this includes adding policies related to finance purchases and lease recognition thresholds. - Physical inventory procedures are not documented, and it is unable to be determined if inventories are done periodically for all items on the School’s capital asset listing. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should design and implement effective internal control procedures to ensure the capital assets schedules are prepared in accordance with GAAP and School policy. The School’s personnel should obtain additional training as needed. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2025‐004 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A24AV00760 N/A Special Education Cluster (IDEA) 84.027 A24AV00760 N/A Administrative Costs Grant for Indian School 15.046 A24AV00760 N/A Federal Agency(ies): U.S. Department of Interior Pass‐Through Agency(ies): Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Indian tribes and tribal organizations may, without the approval of the Bureau of Indian Affairs (BIA), expend funds provided under a self‐determination contract for purposes identified in 25 USC 450j‐l(k), to the extent that the expenditure of the funds is supportive of a contracted program (25 USC 450j‐l(k)). These guidelines require internal controls over expenditures of federal monies, including the use of requisitions or purchase orders, to ensure expenditures comply with federal regulations and guidelines (25 CFR 39; 25 CFR 900). Uniform Guidance requires that non‐federal entities receiving federal awards establish and maintain internal controls designed to reasonably ensure compliance with laws, regulations, and program compliance requirements. Control activities should include proper authorization of expenditures and reviews of operating performance. Further, School management is responsible for establishing and maintaining internal controls over payroll that are adequate to ensure that all payroll disbursements are properly processed and recorded in accordance with Internal Revenue Service (IRS) regulations. Condition The School did not always follow its disbursement, payroll, and financial reporting process. Additionally, employees were not paid in accordance with contracts and time cards. Cause The School lacked adequate internal controls over disbursements, journal entries, and payroll. Controls in place did not always operate effectively and were not followed. Effect The School was not in compliance with federal regulations and guidelines. The School’s internal controls over disbursements, payroll, and journal entries were not adequate to ensure that all financial activities were properly processed, recorded and supported. Context - For one of 16 journal entries reviewed, the School did not maintain documentation to support the transaction for adjusting a cost initially charged to the Administrative Costs Grant to the Indian School Equalization Program. - For one of 45 disbursements reviewed, the purchase order was created after the invoice was received. - For one of 45 disbursements reviewed, the School could not provide supporting documentation including the purchase order, receiving report, and canceled check. - For three of 45 disbursements reviewed, there was no evidence of client clerical checks or cancellation of supporting documentation, and no evidence documenting receipt of services. - For two of 40 employee payroll records reviewed, the employee pay could not be recalculated. - For one of 10 credit card transactions reviewed, supporting documentation for the receipt was not maintained by the School. - The School miscoded $481,980 in expenditures of the Indian School Equalization Program to the Special Education Cluster (IDEA). The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should develop and implement stronger internal controls over its accounting records, specifically those of disbursements and payroll to ensure that all financial activities are properly processed and recorded. The School should maintain documentation to support all disbursements and ensure disbursements are allowable. The School should follow its established procedures for processing payroll and not circumvent the process by suppressing payroll. Additionally, the School must take care to ensure employee pay is properly calculated and that journal entries are properly supported. The School’s personnel should obtain additional training as needed. Additionally, the School should take more care to ensure they are in compliance with federal regulations and guidelines, as put forth in 25 CFR 39; 25 CFR 900 and in 25 USC 450j‐l(k). Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-001 Repeat Finding: Yes (2023-001, 2021-001) Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A23AV00813 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: CRITERIA According to the Indian Child Protection and Family Violence Prevention Act 925 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 conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFS part 63). Condition The School did not complete character reinvestigations timely for all employees. Cause School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. 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, we noted, for seven of 37 character investigations reviewed, the five year reinvestigation was not completed timely. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should ensure 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: 2024-002 Repeat Finding: Yes, 2023-002, 2022-002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization 15.042 A23AV00813 N/A Administrative Cost Grants for Indian Schools 15.046 A23AV00813 N/A Federal Agency(ies): U.S. Department of Interior Pass-Through Agency(ies): Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement and Suspension and Debarment Criteria Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320. Condition Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. Cause The School’s internal controls over procurement of goods and services were not adequate. Effect The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. Context The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to two vendors with the Indian School Equalization Program and four vendors with the Administrative Cost Grants for Indian Schools. Additionally, for three non-cooperative-purchase vendors paid in excess of the small purchase threshold ($10,000), the School did not prepare and maintain documentation for at least 3 written quotes from qualified sources, one instance from the Indian School Equalization Program and two instances from the Administrative Cost Grants for Indian Schools. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024-003 Repeat Finding: Yes, 2023-003 Program Name/Assistance Listing Title: COVID-19 Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Interior Federal Award Number: A23AV00813 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment and Real Property Management Criteria Local governments and Indian tribes shall follow 2 CFR 200 for equipment acquired under federal awards received directly from a federal awarding agency. Institutions of higher education, hospitals, and other non-profit organizations shall follow the provisions of Uniform Guidance. The Uniform Guidance requires that equipment be used in the program for which it was acquired or, when appropriate, other federal programs. Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Condition Documentation was not available to review equipment purchases or inventory listings and procedures. Additionally, the School lacked adequate internal controls over its accounting of capital assets and inventory processes. Cause The School has not been able to devote proper resources and training to ensure capital assets are accurate and up to date. Effect The School’s internal controls over capital assets were not adequate to ensure that a misstatement would be prevented and/or detected. The School was not in compliance with requirements set by the federal government. Context During our review of the School’s capital asset schedules we noted the following: • The capital asset listing does not include identification numbers for individual assets. • Capital asset policies appear outdated and need to be updated; this includes adding policies related to finance purchases and lease recognition thresholds. • Physical inventory procedures are not documented, and it is unable to be determined in inventories are done periodically. • The current year capital asset listing was not reconciled to the previous year’s listing. • All assets obtained during the year over $5,000 were not capitalized. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should design and implement effective internal control procedures to ensure the capital assets schedules are prepared in accordance with GAAP and School policy. The School’s personnel should obtain additional training as needed. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001, 2021‐001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S Department of Interior Federal Award Number: A22AV00793 Pass‐Through Agency: Bureau of Indian Education 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 925 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 conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B – Minimum Standards of Character and Suitability for Employment (25 CFS part 63). Condition The School did not complete character reinvestigations timely for all employees. Cause School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. 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, we noted the following:  For 10 of 30 character investigations reviewed, the five year reinvestigation was not completed timely. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should ensure 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. Page

Finding Number: 2023‐002 Repeat Finding: Yes, 2022‐002 Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A Federal Agency: U.S. Department of Interior Pass‐Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement and Suspension and Debarment Criteria Non‐federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR §200.320. Condition Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. Cause The School’s internal controls over procurement of goods and services were not adequate. Effect The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. Context The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to 3 vendors with the Indian School Equalization Program and 5 vendors with the Administrative Cost Grants for Indian Schools. Additionally, for four vendors paid in excess of the small purchase threshold ($10,000), the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐003 Repeat Finding: No Program Name/Assistance Listing Title: COVID‐19 Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Number: A22AV00793 Pass‐Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Equipment and Real Property Management Criteria Local governments and Indian tribes shall follow 2 CFR 200 for equipment acquired under federal awards received directly from a federal awarding agency. Institutions of higher education, hospitals, and other non‐profit organizations shall follow the provisions of Uniform Guidance. The Uniform Guidance requires that equipment be used in the program for which it was acquired or, when appropriate, other federal programs. Equipment records shall be maintained, a physical inventory of equipment shall be taken at least once every two years and reconciled to the equipment records, an appropriate control system shall be used to safeguard equipment, and equipment shall be adequately maintained. Condition Documentation was not available to review equipment purchases or inventory listings and procedures. Cause The School has not been able to devote proper resources and training to ensure capital assets are accurate and up to date. Effect The School’s internal controls over capital assets were not adequate to ensure that a misstatement would be prevented and/or detected. The School was not in compliance with requirements set by the federal government. Context During our review of the School’s capital asset schedules we noted the following:  The capital asset listing does not include identification numbers for individual assets.  Capital asset policies appear outdated and need to be updated; this includes adding policies related to finance purchases and lease recognition thresholds.  Physical inventory procedures are not documented and it is unable to be determined in inventories are done periodically. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should design and implement effective internal control procedures to ensure the capital assets schedules are prepared in accordance with GAAP and School policy. The School’s personnel should obtain additional training as needed. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐004 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A22AV00793 N/A Administrative Cost Grants for Indian Schools 15.046 A22AV00793 N/A COVID‐19 Education Stabilization Fund 84.425 A22AV00793 N/A Federal Agencies: U.S. Department of the Interior, U.S. Department of Education Pass‐Through Agency: Bureau of Indian Affairs Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Reporting Criteria The School is required to file the Federal Financial Report, SF‐425 to report program outlays and program income as prescribed by the Federal Awarding Agency. Condition Financial reporting obligations were not met during the year. Cause Adequate review systems were not in place for management to monitor compliance with these requirements and ensure accurate amounts were reported. Effect The School was not always in compliance with federal regulations and guidelines. Context The School reported incorrect expenditures for one of four quarterly reports reviewed. The School included both federal and non‐federal expenditures in the reporting. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The School should implement review procedures to ensure the information reported on the Federal Financial Report, SF‐425, is accurate and appropriate. Views of Responsible Officials See Corrective Action Plan.

FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: Yes, 2021-001, 2020-001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education 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 925 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 conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFS part 63). CONDITION The School did not complete character reinvestigations timely for all employees. CAUSE School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. 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, we noted the following: ? For eight of 27 character investigations reviewed, the initial investigation was completed timely; however, an adjudicating official did not certify the results. ? For two of 27 character investigations reviewed, the five year reinvestigation was not completed timely. RECOMMENDATION The School should ensure character investigations are performed in a timely manner and reviewed by an adjudicating official 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.

FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-002 Repeat Finding: No Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR ?180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR ?200.320. CONDITION Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. CAUSE The School?s internal controls over procurement of goods and services were not adequate. EFFECT The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement. CONTEXT The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to three vendors. Additionally, for three of four vendors paid between $25,000 to $100,000, the School deemed the procurement sole source; however, the School did not prepare and maintain documentation for the sole source. RECOMMENDATION The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-003 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A19AV00849 n/a Administrative Cost Grants for Indian Schools 15.046 A19AV00849 n/a Twenty-First Century Community Learning Centers 84.287 A19AV00849 n/a Federal Agencies: U.S. Department of Interior, U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Allowable Costs/Cost Principles CRITERIA According to Uniform Guidance 2 CFR 200.430, payroll distribution records must support the distribution of salary or wages among specific activities or cost objectives if an employee works on more than one award or activity. Employees who work on multiple activities or cost objectives must submit monthly activity reports, documenting time worked in each Federal program. CONDITION Time and effort records were not maintained for employees whose time was charges to multiple cost objectives. CAUSE The School?s policies over time and effort reporting were not always followed. EFFECT The School was not in compliance with the time and effort provision of Uniform Guidance 2 CFR 200.430. CONTEXT For two of two employees reviewed that were compensated from funding sources with different multiple cost objectives, time and effort documentation was not maintained to support costs charged to the Federal programs. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should review and implement policies related to time and effort reporting to ensure compliance. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2021-001 Repeat Finding: Yes, 2020-001 Program Name/Assistance Listing Title: Indian School Equalization Program Assistance Listing Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education 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 925 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 conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required standards of character no less stringent than those prescribed under subpart B ? Minimum Standards of Character and Suitability for Employment (25 CFS part 63). CONDITION The School did not complete character reinvestigations timely for all employees. CAUSE School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. 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, we noted for one of 22 character investigations reviewed, the five year reinvestigation was not completed timely. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should ensure 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 Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education 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 conduct with, or control over, Indian children. The individual should be reinvestigated every five years. In addition, individuals in those positions must meet the required 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 complete character reinvestigations timely for all employees. CAUSE School policies were not always followed and controls were not in place to ensure character reinvestigations were performed timely. 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, we noted for two of 39 character investigations reviewed, the five year reinvestigation was not completed timely. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should ensure 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: 2020-002 Repeat Finding: Yes, 2019-001 Program Name/CFDA Title: Indian School Equalization Program CFDA Number: 15.042 Federal Agency: U.S. Department of Interior Federal Award Number: A19AV00849 Pass-Through Agency: Bureau of Indian Education Questioned Costs: $3,785 Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Allowable Cost/Cost Principles CRITERIA School management is responsible for establishing and maintaining internal controls over payroll that are adequate to ensure that all payroll disbursements are properly processed and recorded in accordance with the Fair Labor Standards Act (FLSA) and Internal Revenue Service (IRS) regulations. Further, Indian tribes and tribal organizations may, without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (25 USC 46). CONDITION The School lacked adequate internal controls over its accounting for payroll transactions to ensure that all financial activities were properly processed and recorded. CAUSE Tracking and processing of contracts or personnel action request forms for employees were inadequate. EFFECT The School was not always incompliance with Federal Guidelines, School Policies or Fair Labor Standards Act guidelines. CONTEXT During our review of various payroll transactions at the School we noted for one of 40 employees reviewed, the School did not maintain an updated contract. The contract on file stated the employee was to be paid based on a fixed contract amount, when in actuality the employee was being paid hourly. As a result, the employee was paid $3,785 more than their contracted amount. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should maintain documentation to support all payroll disbursements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

Finding Number: 2019-001 Repeat Findings: Yes ? 2017-002, 2016-002 and 2015-002 Program Names/CFDA Titles: CFDA Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A18AV00768 $15,269 Title I Grants to Local Educational Agencies 84.010 A18AV00768 N/A Federal Agencies: U.S. Department of Interior, U.S. Department of Education Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Allowable Cost/Cost Principles CRITERIA School management is responsible for establishing and maintaining internal controls over payroll that are adequate to ensure that all payroll disbursements are properly processed and recorded in accordance with the Fair Labor Standards Act (FLSA) and Internal Revenue Service (IRS) regulations. Further, Indian tribes and tribal organizations may, without the approval of the BIA expend funds provided under a self-determination contract for purposes identified in 25 USC 46, to the extent that the expenditure of the funds is supportive of a contracted program (25 USC 46). CONDITION The School lacked adequate internal controls over its accounting for payroll transactions to ensure that all financial activities were properly processed and recorded. CAUSE Tracking and processing of contracts or personnel action request forms for employees were inadequate. EFFECT The School was not always in compliance with Federal Guidelines, School Policies or Fair Labor Standards Act guidelines.CONTEXT The following were noted during our review of various payroll transactions at the School: ? For one of 40 employees reviewed, the employee was underpaid $1,029 for fiscal year 2019. ? For one of 40 employees reviewed, the School did not maintain an updated contract showing the employee was hourly. ? For three of 40 employees reviewed, the number of contract days identified in the employee's contracts did not agree to the actual contract days worked; however, it was determined that the employees were paid appropriately for the year. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The School should develop and implement stringer internal controls over it accounting for payroll to ensure that financial activities are properly processed and recorded. The School should maintain documentation to support all payroll disbursements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

Finding Number: 2019-002 Repeat Findings: Yes ? 2018-002, 2017-003, 2016-003, 2015-003 Program Names/CFDA Titles: CFDA Numbers: Federal Award Numbers: Questioned Costs: Indian School Equalization Program 15.042 A18AV00768 N/A Administrative Cost Grants for Indian Schools 15.046 A18AV00768 N/A Federal Agency: U.S. Department of Interior Pass-Through Agency: Bureau of Indian Education Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Procurement and Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a non-procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. Additionally, the School should adhere to procurement methods outlined in 2 CFR 200.320. CONDITION Verification of suspension and debarment was not performed for all vendors with whom the School spent at least $25,000 using federal grant monies. Additionally, the School did not follow documented policies and procedures for the procurement of goods and services. Lastly, the School did not follow federal guidelines for purchases exceeding the small purchases threshold. CAUSE The School?s internal controls over procurement of goods and services were not adequate. EFFECT The School was not in compliance with federal regulations and guidelines related to suspension and debarment or procurement.CONTEXT The School did not maintain documentation that a review to determine that vendors with whom the School spent greater than $25,000 were not suspended and debarred. The deficiency applied to nine vendors. Additionally, for one vendor paid over $100,000 (with Indian School Equalization Program monies), the School did not follow federal guidelines and also did not maintain documentation that any competitive procurement was performed. Moreover, for four of seven vendors paid between $25,000 to $100,000, the School did not follow policies over procurement which require the School to obtain competitive quotes and bids. RECOMMENDATION The School should review documented policies and implement them in school procedures to ensure compliance with federal procurement requirements. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

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