Administrative Review Summary Report
Date: 09-03-26
Name of Agency: Indian Nations Council, Boy Scouts of America
Reviewer: Matthew Smith Date of review: 07-10-26
Persons interviewed: Roger Findahl and Laura Lovell Date of Exit Conference: 09-02-26
This School Food Authority (SFA) operates the Special Milk Program.
The following areas were corrected prior to the On-Site Portion of this Administrative Review (AR):
· Counting and Claiming: The Counting and claiming errors were discovered during a review of June 2025’s reimbursement claim. The non-systemic errors resulted in a substantial overclaim of milks due to errors occurring when the daily counts were consolidated into the monthly count manually. Indian Nations Council, Boy Scouts of America (BSA) did not catch the error by checking the claim for correctness [as required by federal regulation 7 CFR Part 215.10 (d)]. Prior to the completion of this AR, Indian Nations Council, BSA took corrective action by using a spreadsheet to consolidate the daily milk counts into the monthly milk counts. The SA reviewer conducted a review of June 2026, and July of 2026 reimbursement claims and found no errors.
No further action is required for the above.
Procurement Review Summary Report
Date: 09-03-26
Name of Agency: Indian Nations Council, Boy Scouts of America
Reviewer: Matthew Smith Date of Review: 07-10-26
Persons interviewed: Roger Fndahl and Date of exit conference: 09-02-26
Laura Lovell
Programs Operated by the School Food Authority (SFA): This SFA operates the Special Milk Program.
The following areas were corrected during the Procurement Review (PR):
· The procurement plan provided at the beginning of this review had micro-purchase threshold of purchases of up to $50,000 without meeting the criteria required by federal regulation [contained in 2 CFR Part 200.320 (a) (1) (iv)]. Prior to the completion of this review Indian Nations Council, Boy Scouts of American (BSA) took corrective action by adopting an amendment to their procurement plan. The amendment reset their micro-purchase threshold to purchases up to $10,000.
No further action is required for the above.
Findings for the Procurement Review (PR)
Failure to Provide Requested Record: Indian Nations Council, Boy Scouts of America (INC) failed to provide a third invoice showing a milk purchase for their vendor Tankersley for school year 2025 – 2026 (07/01/25 – 06/30/26). Federal regulation [7 CFR Part 215.7 (d) (7)] and the permanent agreement that INC has with Oklahoma Human Services (OKDHS) requires records pertaining to the Special Milk Program (SMP) be made available to the State Agency (OKDHS) and to the USDA for audit and review. Request for an additional invoice showing a milk purchase was made on 08/07/26, 08/18/26, and 08/28/26. INC failed to provide an additional invoice from Tankersly for school year 2025 – 2026 showing a milk purchase.
To demonstrate compliance with providing requested records:
· Provide INC’s plan for corrective action to demonstrate understanding and compliance.
Procurement Record Retention: INC during the PR could not provide the third requested invoice for their vendor Tankersley for school year 2025 - 2026. Federal regulation [2 CFR Part 200.317 (i)] requires School Food Authorities (SFA) to maintain sufficient records to document the history of each procurement transaction. The State of Oklahoma requires these records to be retained for seven years after payment for the last reimbursement has been received for the school year.
To demonstrate compliance with record retention:
· Provide INC’s plan for corrective action to demonstrate understanding and compliance.
