Nazlini Community School, Inc.Tribal Government

2022-004 Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Material Weakness in Internal Controls over Compliance) - Modified and Repeated (Prior Year Finding 2021-004) Criteria or Specific Requirement: To help ensure that expenditures charged to the programs are allowed:  By the grant agreements and to comply with 2 Code of Federal Regulations (CFR) §225, Appendix B, the School should maintain all supporting documentation, including reviewed and approved invoices.  All costs should support the objectives of the grant. Condition: During our testwork over expenditures we noted the following deficiencies:  Indian School Equalization Program (Basic Ops) and Indian School Equalization Program (Basic Dorms) (ALN 15.042) - For 3 of the 20 transactions tested, adequate supporting documents were not provided to substantiate the payments.  Administrative Cost Grant for Indian Schools (ALN 15.046) – For 10 of the 35 transactions tested, adequate supporting documents were not provided to substantiate the payments.  Coronavirus Response and Relief Supplemental Appropriations, Act 2021 (CRRSA Act) and American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP) (ALN 84.425) – For 8 of the 14 transactions tested, adequate supporting documents were not provided to substantiate the payments. Questioned Costs:  Indian School Equalization Program (Basic Ops) and Indian School Equalization Program (Basic Dorms) (ALN 15.042) - $761.  Administrative Cost Grant for Indian Schools (ALN 15.046) - $173,843.  Coronavirus Response and Relief Supplemental Appropriations, Act 2021 (CRRSA Act) and American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP) (ALN 84.425) - $280,136. Cause: The School did not follow its policies and procedures. Effect: There is an increased risk of payments being made for goods or services not received and of unallowable charges to the federal programs or with complying with federal program requirements for claiming administrative costs. Auditor's Recommendations: To help ensure that expenditures are allowable and to help maintain an effective internal control environment over expenditures, the School should require personnel to follow the existing policies and procedures for obtaining, reviewing and approving expenditure transactions. In addition, the School should ensure that all supporting documentation is properly maintained and that expenditures are based on actual costs. Management Response: Management agrees with the auditor's finding. Internal Controls did not exist during the audit period due to lack of staff in the business office and lack of understanding in the administration staff. The school has since hired a consulting firm to assist with following the existing policies and procedures. The school also has hired an experienced Principal to oversee the operations of the business office. Anticipated Completion Date: June 30, 2023. Responsible Party: Delores Noble, Principal. Amber Wauneka, Consultant with Homeland Business Services.

2022-005 Internal Controls and Compliance over Reporting (Significant Deficiency) Criteria or Specific Requirement: The School is responsible for establishing and maintaining internal controls over financial reporting, including general ledger controls and compliance requirements over federal funding that are adequate to ensure that a material misstatement would be prevented and/or detected. Additionally, the School is required to report cumulative program outlays and program income on the Federal Financial, 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. Annual reports are required to be submitted no later than 90 days at the end of each reporting period. In accordance with 2 CFR 200.512, the single audit must be completed, and the data collection form and reporting package must be submitted within the earlier of 30 calendar days after receipt of the auditor’s report(s), or nine months after the end of the audit period. Condition: The School did not have adequate controls in place over financial reporting including revenues and federal reporting compliance. Cause: There was turnover in School personnel and a lack of established internal controls and procedures over the reporting process to ensure timely and accurate reporting. Effect: The School was not in compliance with federal regulations and guidelines. Auditor's Recommendation: The School should ensure adequate reviews of revenue reporting are conducted to ensure amounts are recorded in the correct fiscal year. In addition, the School should maintain documentation to support the appropriate and timely submission of the Federal Financial Report, SF-425 and implement internal controls to ensure timely completion of the single audit. Management Response: Management agrees with the auditor's finding. Internal Controls did not exist during the audit period due to lack of staff in the business office and lack of understanding in the administration staff. The school has since hired a consulting firm to assist with following the existing policies and procedures. The school also has hired an experienced Principal to oversee the operations of the business office. Anticipated Completion Date: June 30, 2023. Responsible Party: Delores Noble, Principal. Amber Wauneka, Consultant with Homeland Business Services.

2022-06 Special Tests and Provisions Compliance Requirement (Significant Deficiency) Criteria or Specific Requirement: In accordance with the Indian Child Protection and Family Violence Protection Act, the School is required to conduct an investigation of the character of each individual who is employed or is being considered for employment by the School in a position that involves regular contact with, or control over, Indian children. 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: During our test work over special tests and provisions, we noted that employee background investigations were not conducted. Cause: Turnover in School personnel led to a lapse in the required performance and documentation of background investigations. Effect: The School is not in compliance with the special tests and provisions requirements. Auditor's Recommendations: We recommend that the School ensure that employees follow the policies and procedures that are in place along with the compliance requirements for the Indian School Equalization Program and ensure that the compliance requirement is being followed. Management Response: Management agrees with the auditor's finding. Internal Controls did not exist during the audit period due to lack of staff in the business office and lack of understanding in the administration staff. The school has since hired a consulting firm to assist with following the existing policies and procedures. The school also has hired an experienced Principal to oversee the operations of the business office. Anticipated Completion Date: June 30, 2023. Responsible Party: Delores Noble, Principal. Amber Wauneka, Consultant with Homeland Business Services.

2021-004 Activities Allowed or Unallowed and Allowable Costs/Cost Principles (Material Weakness in Internal Controls over Compliance) Federal program information Funding Agency Title ALN # Award Year and Number U.S. Department of Interior Administrative Cost Grant for Indian Schools 15.046 2020; A19AV00942 U.S. Department of Education Coronavirus Response and Relief Supplemental Appropriations, Act 2021 (CRRSA Act) American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP) 84.425 2021; A19AV00942 Criteria or Specific Requirement: To help ensure that expenditures charged to the programs are allowed: ? By the grant agreements and to comply with 2 Code of Federal Regulations (CFR) ?225, Appendix B, the School should maintain all supporting documentation, including reviewed and approved invoices. ? All costs should support the objectives of the grant. Condition: During our testwork over expenditures we noted the following deficiencies: ? Administrative Cost Grant for Indian Schools (ALN 15.046) ? For 13 of the 25 transactions tested, adequate supporting documents were not provided to substantiate the payments. ? Coronavirus Response and Relief Supplemental Appropriations, Act 2021 (CRRSA Act) and American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP) (ALN 84.425) ? For 17 of the 25 transactions tested, adequate supporting documents were not provided to substantiate the payments. Questioned Costs: ? Administrative Cost Grant for Indian Schools (ALN 15.046) - $35,239.60 ? Coronavirus Response and Relief Supplemental Appropriations, Act 2021 (CRRSA Act) and American Rescue Plan - Elementary and Secondary School Emergency Relief (ARP) (ALN 84.425) - $77,103.49 Cause: The School did not follow its policies and procedures. Effect: There is an increased risk of payments being made for goods or services not received and of unallowable charges to the federal programs or with complying with federal program requirements for claiming administrative costs. Auditor's Recommendations: To help ensure that expenditures are allowable and to help maintain an effective internal control environment over expenditures, the School should require personnel to follow the existing policies and procedures for obtaining, reviewing and approving expenditure transactions. In addition, the School should ensure that all supporting documentation is properly maintained and that expenditures are based on actual costs.