oversight

The St. Stephens Indian School Educational Association, Inc., Needs To Improve Financial Accountability for Federal Funds

Published by the Department of the Interior, Office of Inspector General on 2021-03-30.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                                                                     AUDIT




                           OF
               INSPECTOR GENERAL
               U.S. DEPARTMENT OF THE INTERIOR




   The St. Stephens Indian School
   Educational Association, Inc.,
   Needs To Improve Financial
   Accountability for Federal Funds




     This is a revised version of the report prepared for public release.




Report No.: 2019-FIN-058
                -   -                                            March 2021
             OFFICE OF
             INSPECTOR GENERAL
             U.S. DEPARTMENT OF THE INTERIOR



Memorandum

To:           Darryl LaCounte
              Director, Bureau of Indian Affairs

              Tony L. Dearman
              Director, Bureau of Indian Education

From:         Chris Stubbs
              Director, Office of Financial and Contract Audits

Subject:      Final Audit Report – The St. Stephens Indian School Educational Association,
              Inc., Needs To Improve Financial Accountability for Federal Funds
              Report No. 2019-FIN-058

        This report presents the results of our audit of Agreement Nos. A17AV00656,
A16AV00812, and A15AV00702 between the Bureau of Indian Education (BIE) and
St. Stephens Indian School Educational Association, Inc., which provided St. Stephens a total of
$12.5 million to operate elementary (K – 8) and high (9 – 12) school facilities owned by the
Bureau of Indian Affairs (BIA) between July 2015 and June 2018.

        We conducted this audit to determine whether agreement expenses were allowable and
St. Stephens complied with applicable laws and regulations, BIE and BIA guidelines, and
agreement terms and conditions. We reviewed transactions charged to the agreements totaling
$5.8 million. Attachment 1 provides the audit scope and methodology.

        We found multiple instances in which St. Stephens did not use agreement funds for
allowable activities and did not comply with applicable Federal regulations and agreement
provisions, which led us to identify $442,632 in funds that could be put to better use and
question $35,432 of St. Stephens’ claimed costs. In addition, we determined that the BIE did not
consistently oversee St. Stephens agreements in accordance with applicable regulations and BIA
policy.

        We make 11 recommendations to help the BIE and the BIA resolve questioned costs
and provide better oversight to St. Stephens. Based on the response to our draft report, we
consider Recommendations 1 – 4 to be unresolved and Recommendations 5 – 11 to be resolved
but not implemented. We will refer the recommendations to the Office of Policy, Management
and Budget for resolution and implementation tracking. In our recommendations summary at the
end of the report, we note our concern regarding the timing proposed for implementation of the
recommendations, as the earliest target date is December 31, 2021.




                     Office of Audits, Inspections, and Evaluations | Washington, DC
Background
       The BIA Rocky Mountain Region requested an audit of St. Stephens because of its
concerns that minor improvement and repair funds could not be accounted for and allegations
made by a prior employee that funds provided to St. Stephens had been misused.

       St. Stephens was formed on April 21, 1975, to take over operation of school facilities
owned by the BIA and located on the Wind River Indian Reservation in St. Stephens, WY. The
schools had been previously operated by the St. Stephens Indian Mission, Inc.

Results of Audit
       We found multiple instances in which St. Stephens did not use agreement funds for
allowable activities and did not comply with applicable Federal regulations and agreement
provisions. Specifically, we found that St. Stephens:

       •   Did not account for BIA funds for minor improvement and repair projects

       •   Claimed employer-provided housing program costs without approval

       •   Charged costs without sufficient supporting documentation for travel by St. Stephens
           staff and board members

       •   Misused BIE funds to pay for repairs to a St. Stephens board member’s vehicle and
           for dependents to travel with employees

        In addition, we found that the BIE did not consistently oversee the agreements with
St. Stephens in accordance with applicable regulations and BIA policy.

       We identified $442,632 in funds that could be put to better use and questioned $35,432 as
claimed costs that were ineligible and insufficiently supported. See Attachment 2 for a summary
of monetary impact of these questioned costs.

St. Stephens Did Not Properly Account for BIA Funds for Minor Improvement
and Repair Projects—Funds To Be Put To Better Use of $442,632

        We found that St. Stephens did not properly account for BIA funds for minor
improvement and repair projects, and we accordingly question $442,632 as funds that could be
put to better use. Specifically, St. Stephens (1) used BIE operations and maintenance funds to
complete projects that should have been paid for using BIA minor improvement and repair funds
and (2) did not maintain sufficient documentation to trace which projects the funds were spent
on. In addition, St. Stephens staff have not updated or tracked projects in the BIA’s asset
management system, called Maximo, since 2015, because St. Stephens did not have staff who
were trained to update the system.




                                                                                                2
        St. Stephens’ agreement with the BIE defines which funds to use for particular projects
and requires control and monitoring over all obligations and expenditures. BIA minor
improvement and repair funds may be used only to correct urgent deficiencies that cost less than
$250,000 at education, public safety, and justice facilities. The BIA Division of Facilities
Management and Construction uses Maximo to help administer this program, which includes
projects costing between $2,500 and $250,000. During our review, Maximo listed 16 open St.
Stephens projects with a total value of $382,534. St. Stephens told us that all but one of the
projects had been completed but that they had not updated the projects in the system since 2015.

      We found the following instances in which St. Stephens did not track or sufficiently
document its use of BIA minor improvement and repair funds:

   •   In the St. Stephens’ 2017 and 2018 single audits, we identified $442,632 in minor
       improvement and repair funds that St. Stephens held for certain projects and carried over
       from year to year. St. Stephens officials told us that St. Stephens saved the carrying
       balance by completing the projects with BIE operations and maintenance funds instead of
       BIA minor improvement and repair funds. We question the entire $442,632 because
       St. Stephens should have used BIA minor improvement and repair funds for these
       projects.

   •   We found that St. Stephens did not always obtain adequate supporting documentation to
       trace the minor improvement and repair funds to a specific project and used at least
       $368,897 of minor improvement and repair funds to repair three homes that were leased
       from the                         and not owned by the BIA. Prior to our audit, St. Stephens
       transferred $400,000 from its investment accounts to the BIA minor improvement and
       repair fund to cover what it estimated was spent on the home repairs, which leaves
       $31,133 that St. Stephens returned to the BIA over the cost of the mission homes repairs.

       As a result, we question $442,632 as funds to be put to better use.

St. Stephens Claimed Employer-Provided Housing Program Costs Without
Approval—Questioned Costs of $4,767

        We found that in 2015 St. Stephens started using BIE funds to provide employer housing
to recruit and retain key positions—specifically, for the superintendent and for the principals of
the elementary and high schools—without the required approval. To be an allowable cost,
employer-provided housing must be approved in advance (per 2 C.F.R. § 200.445). In addition,
the U.S. Department of the Interior’s Housing Management Handbook requires a housing
requirements analysis to ascertain the need for housing, which in this case the BIE must review
and approve. St. Stephens officials told us they completed the needs assessment and submitted it
to the BIA in 2015, but neither St. Stephens nor the BIA or the BIE could provide us with a copy
of the completed assessment.




-     In April 2015, St. Stephens entered into a 10-year lease, rent free, from the
                                                                                   -
          for three residences and a four-stall garage on the St. Stephens Indian Mission. In
exchange, St. Stephens agreed to repair and maintain the homes and outbuildings at its own cost.



                                                                                                 3
St. Stephens estimated it spent $400,000 of BIA funds to repair the three mission homes, which
St. Stephens repaid to the BIA (as described in the previous finding). In addition, from July 2016
through June 2018, St. Stephens spent $4,767 of BIE funds for utilities and maintenance on the
three mission homes, without approval from BIA and BIE staff. Therefore, we question the
$4,767 spent on utilities and maintenance for the mission homes as ineligible costs.

        Throughout 2019, St. Stephens officials contacted the BIA and the BIE for guidance
on their employer-provided housing program. BIE officials provided a housing policy for
St. Stephens to follow but were unable to provide the requested example of a needs assessment.
BIA facilities officials referred us to the Housing Management Handbook for guidance on
employer-provided housing. The handbook guidance, however, applies only to Government-
owned properties; it does not apply to the mission homes because the custody of the housing
units was transferred to St. Stephens (a non-Federal entity) pursuant to the lease signed in 2015.

        Employer-provided housing is a common practice in education. Typically, housing is on
school property and employees are charged rent. Because of the unique structure of the lease and
the location of the mission homes, St. Stephens needs guidance from the BIE and the BIA on
how to implement an employer-provided housing policy that complies with Federal regulations.

St. Stephens Charged Travel Costs Without Sufficient Supporting
Documentation—Questioned Costs of $26,835

        We reviewed a total of $55,445 in travel costs spent between July 2016 and June 2018
to determine whether sufficient documentation was provided. We found St. Stephens did not
consistently support travel costs with sufficient documentation such as completed travel
authorizations that included a justification for the travel and signed approval from a supervisor or
actual receipts. For example, we identified five transactions totaling $16,311 for hotel stays for
which the supporting documentation was hotel confirmations, not the actual receipts. We found
an additional 16 transactions totaling $10,524 that also did not have actual receipts to support the
costs. Without receipts to support the actual costs, we are unable to verify that these were
allowable travel costs. As a result, we identified $26,835 in insufficiently supported travel costs.

         According to 2 C.F.R. § 200.444, travel costs are an allowable expense for transportation,
lodging, and related items incurred by employees who are in travel status on official business of
the non-Federal entity. In addition, 2 C.F.R. § 200.474(a) requires that the employee also comply
with the non-Federal entity’s written travel reimbursement policies. St. Stephens travel guidance
states, “Personnel and school officials who are required to travel as part of their authorized duties
will complete a travel request signed by their supervisor and superintendent. Out-of-state travel
requires approval of the Board of Trustees. Incomplete travel requests will not be submitted for
approval.” In addition, the St. Stephens guidance requires travelers to attach all receipts to their
travel request and submit to the business office within 3 days after returning from a trip. Receipts
should be provided for travel, lodging, food, and any taxi or car rental fees, and similar
expenditures. According to the guidance, receipts are necessary for any reimbursement.




                                                                                                     4
St. Stephens Misused Funds for Repair of a Board Member’s Vehicle and for
Dependent Travel—Questioned Costs of $3,830

        In April 2017, St. Stephens authorized payment of $3,880 to repair a board member’s
personal vehicle. The board member had made two payments of $25 over the last 2 years to
cover the cost of the repairs; if this approach were to continue, it will take approximately
153 years for the board member to finish paying back St. Stephens. According to 2 C.F.R.
§ 200.445(a), costs of goods or services for personal use of the non-Federal entity’s employees
are unallowable. Therefore, we question $3,830.

        In addition, St. Stephens spent $8,397 to send five employees and six dependents to
Hawaii for the employees to attend a workplace wellness conference. 1 The travel authorizations
for the five employees were not completed to justify the need for these employees to attend a
conference in Hawaii; however, the school board did approve the trip. According to 2 C.F.R.
§ 200.474(c)(2), travel costs for dependents are unallowable, except for travel lasting 6 months
or more with prior approval of the Federal awarding agency.

        Out of the $8,397, the cost to fly the employees’ dependents to Hawaii was $4,204.
While St. Stephens recovered $4,334 through payroll reductions (which was $130 more than the
cost of the trip for the dependents), this payback went into a payroll account and not the original
fund used to pay for the travel. By not ensuring the funds were transferred back to the original
account, St. Stephens was left short on funds intended to improve student achievements and
provide for professional development of teachers.

The BIE Did Not Provide Adequate Oversight

       The BIE did not consistently oversee the agreements with St. Stephens in accordance
with applicable regulations and BIA policy. Specifically, the BIE did not perform a timely or
thorough review of financial status reports and was unaware St. Stephens implemented and
charged costs related to employer-provided housing until the matter was raised during our audit
fieldwork.

        We identified significant amounts overreported and underreported on the Federal
financial status reports submitted by St. Stephens when compared to amounts in its accounting
records. The BIE has no process or procedures to review the financial status reports. We note
that, had BIE staff, at a minimum, checked whether the amounts reported by St. Stephens
matched the amounts received, they would have noticed St. Stephens was reporting more funds
than were provided. Figure 1 provides a summary of the discrepancies in amounts reported and
actually received, by agreement.




1   The conference itself was 3 days; the additional 5 days approved by the school board were travel days.


                                                                                                             5
   Figure 1: Amounts Reported vs. Amounts in St. Stephens’ Accounting Records

                                 St. Stephens            Accounting             Difference
 Agreement                       Reported ($)            Records ($)      Over/(Under) ($)

 A17AV00656
    Total funds drawn                4,652,002              4,187,273                 464,729
    Total expenditures               3,353,894              4,995,045             (1,641,151)
 A16AV00812
    Total funds drawn                3,761,793              3,759,793                   2,000
    Total expenditures               4,556,646              5,300,757               (744,111)
 A15AV00702
    Total funds drawn                4,765,861              4,156,184                 609,677
    Total expenditures               4,486,086              3,953,542                 532,544


Conclusion and Recommendations
       Our review of claimed costs revealed multiple instances in which St. Stephens did not use
agreement funds for allowable activities and did not comply with applicable Federal regulations
and agreement provisions, resulting in $442,632 in funds that could be put to better use and
$35,432 in questioned costs. In addition, the BIE did not consistently oversee the St. Stephens
agreements in accordance with applicable regulations and BIE and BIA policies.

       We make 11 recommendations to help the BIA and the BIE provide oversight and help
ensure St. Stephens accounts for the funds it receives from the Federal Government.

       We recommend that the BIA Division of Facilities Management and Construction:

       1. Require St. Stephens staff to complete training in the Maximo system

       2. Ensure all funded and required minor improvement and repair projects have been
          completed and identify how much of the carried over $442,632 in restricted minor
          improvement and repair funds can and should be used to reconcile costs improperly
          paid from the BIE operations and maintenance fund

       3. Resolve the $31,133 in overpayment of minor improvement and repair costs from
          St. Stephens to cover the repairs made to the mission homes

       4. Coordinate with the BIE to provide guidance to St. Stephens on how to implement a
          compliant employer-provided housing policy




                                                                                              6
       We recommend that the BIE:

       5. Resolve the $4,767 in questioned costs claimed by St. Stephens for utilities and
          maintenance for the mission homes

       6. Coordinate with the BIA Division of Facilities Management and Construction to
          provide guidance to St. Stephens on how to implement a compliant employer-
          provided housing policy

       7. Ensure that St. Stephens maintains complete supporting documentation for claimed
          costs

       8. Resolve the $26,835 in questioned costs claimed by St. Stephens relating to
          insufficient supporting documentation for travel costs

       9. Resolve the $3,830 in questioned costs claimed by St. Stephens relating to the
          repairing of a board member’s personal vehicle

       10. Resolve the $130 overpayment of travel costs from the employees and ensure that the
           repaid $4,204 is moved from the payroll account to the travel account

       11. Develop and implement a process and procedures for reviewing financial status
           reports

        We issued a draft version of this report to the BIA and the BIE for review and response. The
BIA did not provide a response. In its response, the BIE concurred with Recommendations 1 – 3, 5,
and 7 – 11. The BIE partially concurred with Recommendations 4 and 6; the BIE does not
disagree with the recommendations but has asked the Solicitor’s Office to review whether
employer-provided housing for non-BIA owned properties is a permissible expenditure, and it
stated that it will use the Solicitor’s Office response to inform its implementation of the
recommendations.

        In addition, the BIE provided target dates and offices responsible for implementation of
the recommendations, but the stated timeframe to implement is more than 2 years from the date
of the response for four recommendations (Recommendations 4, 6, 8, and 11) and more than
1 year from the date of the response for the remaining seven. The BIE has provided no
explanation as to why it could not address these matters more promptly. To the extent possible,
the BIE should provide guidance to St. Stephens more promptly and revise the target completion
dates in coordination with the Office of Policy, Management and Budget.

        Because we did not receive a response from the BIA, we consider Recommendations 1 – 4 to
be unresolved. Based on the BIE response, we consider Recommendations 5 – 11 to be resolved
but not implemented. See Attachment 3 for the full text of the BIE response and Attachment 4
for the status of recommendations.

        We will refer all 11 recommendations to the Office of Policy, Management and Budget
for resolution and implementation tracking. In addition, we will notify Congress about our


                                                                                                       7
findings and we will report semiannually, as required by law, on actions you have taken to
implement the recommendations and on recommendations that have not been implemented.
We will also post a public version of this report on our website.

       If you have any questions about this report, please contact me at 202-208-5745.


Attachments (4)




                                                                                             8
Attachment 1: Scope and Methodology
Scope

        Our audit scope included $12.5 million in costs claimed by the St. Stephens Indian
School Educational Association, Inc., under three separate agreements—Nos. A17AV00656,
A16AV00812, and A15AV00702—with the Bureau of Indian Education (BIE) between July 1,
2015, and June 30, 2018. We reviewed 320 transactions charged to the agreements totaling
$5.8 million. As part of our audit, we reviewed St. Stephens’ compliance with agreement terms
and conditions, applicable Federal regulations, and Bureau of Indian Affairs (BIA) and BIE
policies and procedures.

Methodology

        We conducted this audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain sufficient,
appropriate evidence to provide a reasonable basis for our findings and conclusions based on our
audit objectives. We believe that the evidence obtained provides a reasonable basis for our
findings and conclusions based on our audit objectives.

        We assessed whether internal control was significant to the audit objective. We
determined that the St. Stephen’s control activities and the following principles were significant
to the audit objectives:

        •   Management should design control activities to achieve objectives and respond to
            risks

        •   Management should implement control activities through policies

        To accomplish our objectives, we:

        •   Reviewed the Code of Federal Regulations pertaining to claimed costs (2 C.F.R.
            § 200)

        •   Reviewed the terms and conditions for Agreement Nos. A17AV00656,
            A16AV00812, and A15AV00702 and St. Stephens’ policies and procedures

        •   Reviewed St. Stephens’ single audit reports for fiscal years 2016, 2017, and 2018

        •   Gathered background information on St. Stephens’ work and mission

        •   Interviewed officials, including BIA, BIE, and St. Stephens management and staff

        •   Reviewed evidence that supports selected expenditures charged to the agreements




                                                                                                     9
            We used and relied on computer-processed data from St. Stephens’ accounting systems.
    To assess the reliability of computer-processed data, we obtained copies of St. Stephens’ general
    ledger from its accounting system and compared the dates and figures in the ledger to source
    documents. We also reviewed the source documents against information in the general ledger to
    determine whether facts, dates, and figures contained errors or were incomplete. We also
    interviewed responsible parties at St. Stephens, the BIA, and the BIE to determine whether the
    information reviewed to answer our audit objective and report on our audit findings was reliable.

            To test payroll costs and nonpayroll direct costs, we selected a judgmental sample of
    320 transactions totaling $5.8 million that St. Stephens claimed under the three agreements. The
    figure below shows a breakout of each agreement and what we reviewed. These expenditures
    represented 28.6 percent of all costs charged to the three agreements as of August 15, 2019. For
    Agreement No. A15AV00702, we selected all transactions relating to the minor improvement
    and repair fund, and for Agreement Nos. A16AV00812 and A17AV00656 we randomly selected
    a sample of transactions from the highest percentage of expense categories. We then reviewed
    source documents supporting the transactions, including timesheets, vendor invoices and
    receipts, travel vouchers, and charge card statements. Because we selected audit samples for
    testing on a judgmental rather than statistical basis, we did not project the results of our test to
    the total population of recorded transactions.

                  Number and Value of Transactions for Each Agreement and
                 Number and Value of Sample Selected From Each Agreement

                         Universe                        Sample                       OIG Reviewed
Agreement                                                                             % of
No.              Transactions     Value ($)     Transactions     Value ($)     Transactions     % of Value

A15AV00702              17,140    7.4 million              30    0.7 million              0.2               9.4
A16AV00812              19,430    7.5 million             139    3.7 million              0.7              49.3
A17AV00656              20,955    5.2 million             151    1.4 million              0.7              26.9

Totals                 57,525         $20.1              320          $5.8                0.6              28.9
                                     million                        million




                                                                                                      10
Attachment 2: Monetary Impact

                                  Questioned Costs ($)
                                                              Funds To Be Put
Description                     Ineligible   Unsupported     To Better Use ($)

Restricted minor improvement
                                        –                –            442,632
and repair funds
Maintenance and utilities for
                                    4,767                –                  –
mission homes
Travel                                  –         26,835                    –
Repair of a board member’s
                                    3,830                –                  –
personal vehicle

Totals                            $8,597        $26,835             $442,632




                                                                            11
Attachment 3: Response to Draft Report
The Bureau of Indian Education’s response to our draft report follows on page 13.




                                                                                    12
                      United States Department of the Interior
                              BUREAU OF INDIAN EDUCATION
                                   Washington, D .C. 20240



                                      November 16, 2020

Memorandum

To:            Chris Stubbs
               Director, Office of Financial and Contract Audits
               Office of Inspector General

From:          Tony L. Dearman    _//4. ~
               Director, Bureau oflnl an~ ducation

Subject:       Draft Evaluation Report - The St. Stephens Indian School Educational
               Association Inc., Needs to Improve Financial Accountability for Federal Funds
               Report No. 2019-FIN-058

The Bureau of Indian Education (BIE) appreciates the opportunity to comment on the Office of
Inspector General's (OIG) evaluation of issues related to BIE's oversight of St. Stephens Indian
School. Addressing the draft report recommendations will improve oversight and ensure that
students at St. Stephens receive a high-quality education. Below is a summary of actions already
taken as well as plans to implement the OIG recommendations.

Recommendation 1
Require St. Stephens staff to complete training in the Maximo system.

Response: Concur.

BIE and the BIA Division of Facilities Management and Construction (DFMC) will ensure that
all relevant St. Stephens staff complete required Maximo system training.

Responsible Official: Director, BIE and Indian Affairs Deputy Assistant Secretary -
Management (DAS-M).
Target Date: December 31, 2021.

Recommendation 2
Ensure all funded and required minor improvement and repair projects have been completed and
identify how much of the carried over $442,632 in restricted minor improvement and repair
funds can and should be used to reconcile costs improperly paid from the BIE operations and
maintenance fund.

Response: Concur.

BIE and DFMC leadership will review all required minor improvement and repair projects for
comp]etion and identify which projects should be used to reconcile costs improperly paid from
the BIE operations and maintenance fund.

Responsible Official: Director, BIE and DAS-M.
Target Date: December 31, 2021.                                                              13
 Recommendation 3
 Resolve the $31,133 in overpayment of minor improvement and repair costs from St. Stephens to
 cover the repairs made to the mission homes.

Response: Concur.

BIE and DAS-M will ensure that the $31,133 overpayment costs are resolved.

Responsible Official: Director, BIE and DAS-M.
Target Date: December 31, 2021.

Recommendation 4
Coordinate with the BIE to provide guidance to St. Stephens on how to implement a compliant
employer-provided housing policy.

Response: Partially concur.

Upon receipt of the Draft Report the BIB and DAS-M requested the Solicitor's Office review of
recommendations 4 and 6 and consider whether employer-provided housing for non-BIA owned
properties was a permissible expenditure. The Solicitor's Office advised BIB and DAS-M that the
Elementary and Secondary Education Act of 1965 (ESEA), as amended by the Every Student
Succeeds Act (ESSA) Title II, Part A funds could be used for non-BIA owned employer-provided
housing if such an expenditure is part of a strategy to recruit and retain teachers and principals.
Accordingly, BIE and DAS-M will work to provide guidance to St. Stephens, which is limited in
scope to Title II, Part A ESSA funds .

Responsible Official: Director, BIE and DAS-M.
Target Date: September 1, 2022.

Recommendation 5
Resolve the $4,767 in questioned costs claimed by St. Stephens for utilities and maintenance for
the mission homes.

Response: Concur.

BIE will resolve the $4,767 in utilities and maintenance related questioned costs.

Responsible Official: Director, BIE.
Target Date: December 31, 2021.

Recommendation 6
Coordinate with BIA Division of Facilities Management and Construction to provide guidance to
St. Stephens on how to implement a compliant employer-provided housing policy.

Response: Partially concur.

Upon receipt of the Draft Report the BIB and DAS-M requested the Solicitor's Office ofreview
recommendations 4 and 6 and consider whether employer-provided housing for non -BIA owned
properties was a permissible expenditure. The Solicitor's Office advised BIB and DAS-M that the
Elementary and Secondary Education Act of 1965 (ESEA), as amended by the Every Student
Succeeds Act (ESSA) Title II, Part A funds could be used for non-BIA owned employer-provided
housing if such an expenditure is part of a strategy to recruit and retain teachers and principals.
Accordingly, BIE and DAS-M will work to provide guidance to St. Stephens, which is limited in
scope to Title II, Part A ESSA funds .                                                              14
Responsible Official: Director, BIE and Director, BIA.
Target Date: September 1, 2022

Recommendation 7
Ensure that St. Stephens maintains complete supporting documentation for claimed costs.

Response: Concur.

BIE will review current processes and procedures for completing supporting documentation for
expenditures. Following this review the BIE will provide St. Stephens with guidance regarding
the completion and maintenance of claimed cost supporting documentation.

Responsible Official: Director, BIE.
Target Date: December 31, 2021 .

Recommendation 8
Resolve the $26,835 in questioned costs claimed by St. Stephens relating to insufficient
supporting documentation for travel costs.

Response: Concur.

The BIE will resolve the $26,835 in questioned travel costs. BIE is additionally provide guidance
and training to St. Stephens regarding appropriate travel cost documentation.

Responsible Official: Director, BIE.
Target Date: September I, 2022.

Recommendation 9
Resolve the $3,830 in questioned costs claimed by St. Stephens relating to the repairing of a
board member's personal vehicle.

Response: Concur.

The BIE will resolve the $3,830 in questioned costs regarding a board member's personal
vehicle repairs.

Responsible Official: Director, BIE.
Target Date: December 31, 2021.

Recommendation 10
Resolve the $130 overpayment of travel costs from the employees and ensure that the repaid
$4,204 is moved from the payroll account to the travel account.

Response: Concur.

The BIE will resolve the$ 130 travel cost overpayment and ensure that the $4,204 is correctly
moved from the payroll account to the travel account.

Responsible Official: Director, BIE.
Target Date: December 31, 2021.

Recommendation 11
Develop and implement a process and procedures for reviewing financial status reports.          15
Response: Concur.

TI1e BIE will develop and implement a process and procedures for reviewing financial status
reports.

Responsible Official: Director, BIB.
Target Date: September 1, 2022




                                                                                              16
Attachment 4: Status of Recommendations
        The Bureau of Indian Affairs (BIA) did not respond to our draft report. In its response, the
Bureau of Indian Education (BIE) concurred with nine recommendations and partially concurred
with two. The BIE response included target dates and offices responsible for each recommendation
(see Attachment 3). Because we received no response from the BIA, we consider Recommendations
1 – 4 to be unresolved. Based on the BIE response, we consider Recommendations 5 – 11 to be
resolved but not implemented. We will refer all 11 recommendations to the Office of Policy,
Management and Budget for resolution and to track their implementation.

        We understand that some of these recommendations may require significant coordination
between multiple offices, but the BIE’s stated timeframe to implement these recommendations
remains a concern. Four recommendations will not be addressed for more than 2 years from
the date of the response, and the remaining seven will not be addressed for more than 1 year
from the date of the response. As noted in the report, we have suggested updating the target
implementation dates; in the interim, the BIE should consider additional temporary or partial
solutions.

 Recommendation                Status                   Action Required

                                                        We will refer these recommendations
 1–4                           Unresolved               to the Office of Policy, Management
                                                        and Budget for resolution.
                                                        We will refer these recommendations
                               Resolved but not         to the Office of Policy, Management
 5 – 11
                               implemented              and Budget for implementation
                                                        tracking.




                                                                                                  17
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                 and operations. You can report
                allegations to us in several ways.


By Internet:       www.doioig.gov

By Phone:          24-Hour Toll Free:                800-424-5081
                   Washington Metro Area:            202-208-5300

By Fax:            703-487-5402

By Mail:           U.S. Department of the Interior
                   Office of Inspector General
                   Mail Stop 4428 MIB
                   1849 C Street, NW.
                   Washington, DC 20240