CIBECUE COMMUNITY EDUCATION BOARD, INC. DBA DISHCHII'BIKOH COMM SCHOOL

Finding Number: 2024-002 Repeat Finding: Similar to prior year finding 2023-003 Program Name/Assistance Listing Title: Indian School Equalization, Special Education Cluster Assistance Listing Number: 15.042, 84.027 Federal Agency: U.S. Department of the Interior, U.S. Department of Education Federal Award Number: A23AV00811 Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Procurement, Suspension and Debarment

Criteria: Under 2 CFR §215.43 the School is required to implement certain procurement policies that adhere to the minimum federal requirements as outlined in 2 CFR §215.44. 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.

Condition: The School did not always follow procurement standards as put forth in 2 CFR §200.318 through §200.326.

Effect: Noncompliance with federal regulation that led to a qualified audit opinion over the listed federal programs as noted above.

Cause: Management oversight.

Context: For two of 25 vendors within the Simplified Acquisition Threshold tested, the School did not maintain documentation that appropriate procurement procedures were performed or provide documentation to support the School’s reasoning for a noncompetitive procurement.

Recommendation: The School should review its procurement procedures to ensure that proper procurement procedures are performed documentation is maintained to support the procurement.

Response: The School’s responses are presented in a separate document.

Contact person: Dolores Silva, Chief Financial Officer

Finding Number: 2024-003 Repeat Finding: Similar to prior year finding 2023-004 Program Name/Assistance Listing Title: Indian School Equalization Assistance Listing Number: 15.042 Federal Agency: U.S. Department of the Interior Federal Award Number: A23AV00811 Questioned Costs: None Type of Finding: Noncompliance, Material Weakness 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.

Effect: Noncompliance with federal regulation.

Cause: Management oversight.

Context: For three of 20 employees tested, the School did not maintain a current and full background check and character investigation on file.

Recommendation: The School should review its human resources procedures to ensure that current character investigations are maintained for all required employees.

Response: The School’s responses are presented in a separate document.

Contact person: Dolores Silva, Chief Financial Officer

Finding Number: 2024-004 Repeat Finding: Similar to prior year finding 2023-005 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A23AV00811, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting

Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... 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." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512."

Condition: The School did submit their audit for the fiscal year ending June 30, 2024 timely. The audit was submitted August XX, 2025, which was XXX days past the March 31, 2025 deadline.

Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee.

Cause: Management oversight.

Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe.

Response: The School’s responses are presented in a separate document.

Contact person: Dolores Silva, Chief Financial Officer

Finding Number: 2023-003 Repeat Finding: Similar to prior year finding 2022-003 Program Name/Assistance Listing Title: Indian School Equalization, Special Education Cluster Assistance Listing Number: 15.042, 84.027 Federal Agency: U.S. Department of the Interior, U.S. Department of Education Federal Award Number: A22AV00792 Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Procurement, Suspension and Debarment Criteria: Under 2 CFR §215.43 the School is required to implement certain procurement policies that adhere to the minimum federal requirements as outlined in 2 CFR §215.44. 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. Condition: The School did not always follow procurement standards as put forth in 2 CFR §200.318 through §200.326. Effect: Noncompliance with federal regulation that led to a qualified audit opinion over the listed federal programs as noted above. Cause: Management oversight. Context: For ten of 25 vendors within the Simplified Acquisition Threshold reviewed, the School did not maintain documentation that appropriate procurement procedures were performed. Recommendation: The School should review its procurement procedures to ensure that proper procurement procedures are performed documentation is maintained to support the procurement. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer

Finding Number: 2023-004 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: A22AV00792 Questioned Costs: None Type of Finding: Noncompliance, Material Weakness 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. Effect: Noncompliance with federal regulation. Cause: Management oversight. Context: For six of 20 employees tested, the School did not maintain a current and full background check and character investigation on file. Recommendation: The School should review its human resources procedures to ensure that current character investigations are maintained for all required employees. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer

Finding Number: 2023-005 Repeat Finding: Similar to prior year finding 2022-004 Program Name/Assistance Listing Title: Indian School Equalization Program, Administrative Cost Grants for Indian Schools, Indian Education Facilities, Operations, and Maintenance, Special Education Cluster, and Education Stabilization Fund - COVID-19 Assistance Listing Number: 15.042, 15.046, 15.047, 21.027, 84.010, 84.027, and 84.425D Federal Agency: U.S. Department of the Interior, U.S. Department of Treasury, U.S. Department of Education Federal Award Number: A22AV00792, Unknown (21.027) Questioned Costs: None Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria: 2 CFR § 200.512(a) provides, in part: "The audit must be completed and the data collection form ... 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." 2 CFR § 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in § 200.512." Condition: The School did submit their audit for the fiscal year ending June 30, 2023 timely. The audit was submitted August 16, 2024, which was 138 days past the March 31, 2024 deadline. Effect: Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the School from qualifying as a low-risk auditee. Cause: Management oversight. Recommendation: The School should implement procedures to ensure that all audit documentation is available for the audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe. Response: The School’s responses are presented in a separate document. Contact person: Dolores Silva, Chief Financial Officer