Audit 293951

2 CFR § 3474.1 gives regulatory effect to the U.S. Department of Education for 2 CFR § 200.403 (a), which requires, except where otherwise authorized by statute, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Costs incurred under the Education Stabilization Fund (ESF) must be consistent with the purpose of the ESF which is to prevent, prepare for, and respond to COVID-19. For fiscal year 2022, one of the 64 tested expenditures paid out of the #84.425U – American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund totaling $239,173 was determined to not be allowable based on the ESF grant's guidelines and 2 CFR § 200.403 (a). This expenditures was: Pursuant to ORC §3302.10, districts are subject to an academic distress commission after receiving an overall grade of F or an overall rating of less than two stars on the Ohio School Report Cards for three consecutive years. Youngstown met these criteria in FY 2016. The District’s academic distress commission appointed a chief executive officer with complete operational, managerial, and instructional control of the district. Among other duties, this included contracting for services and modifying policies and procedures previously established. Under his authority, the CEO approved the unallowable expenditure noted above. The noncompliance has resulted in a questioned cost in the amount of $239,173. The District should implement additional procedures to help ensure expenditures charged to the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund are necessary and reasonable for the grant program in accordance with 2 CFR § 200.403 (a) and allowable under the grant guidelines. Failure to do so could result in reduced future federal funding or the requirement to repay the Ohio Department of Education.

2 CFR § 3474.1 gives regulatory effect to the U.S. Department of Education for 2 CFR § 200.403 (a), which requires, except where otherwise authorized by statute, costs must be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles. Costs incurred under the Education Stabilization Fund (ESF) must be consistent with the purpose of the ESF which is to prevent, prepare for, and respond to COVID-19. For fiscal year 2022, one of the 64 tested expenditures paid out of the #84.425U – American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund totaling $239,173 was determined to not be allowable based on the ESF grant's guidelines and 2 CFR § 200.403 (a). This expenditures was: Pursuant to ORC §3302.10, districts are subject to an academic distress commission after receiving an overall grade of F or an overall rating of less than two stars on the Ohio School Report Cards for three consecutive years. Youngstown met these criteria in FY 2016. The District’s academic distress commission appointed a chief executive officer with complete operational, managerial, and instructional control of the district. Among other duties, this included contracting for services and modifying policies and procedures previously established. Under his authority, the CEO approved the unallowable expenditure noted above. The noncompliance has resulted in a questioned cost in the amount of $239,173. The District should implement additional procedures to help ensure expenditures charged to the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Fund are necessary and reasonable for the grant program in accordance with 2 CFR § 200.403 (a) and allowable under the grant guidelines. Failure to do so could result in reduced future federal funding or the requirement to repay the Ohio Department of Education.