Audit 31772

Federal Program Affected Program Name: COVID-19: Elementary and Secondary School Emergency Relief II (ESSER II) Fund Assistance Listing Number: 84.425D Pass-Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria or Specific Requirements The Uniform Guidance 2 CFR ? 200.430(i)(1)(viii) states that budget estimates alone may not be used to allocate compensation charges to Federal awards. When using budget estimates for interim accounting purposes, entities must also establish internal controls to identify significant changes in corresponding work activities and review and adjust after-the-fact interim charges to reflect accurate, allowable, and properly allocated charges. Condition The District charged multi-funded employees based on budget estimates. There was not a system of monitoring and internal controls to identify significant changes in corresponding work activities nor to adjust budgeted charges to reflect the actual percentage of work performed for the grant. Cause The condition identified appears to be due to lack of sufficient internal controls to monitor and adjust after-the-fact employee budgeted time to actual time reflected on approved employee time certifications.

Federal Program Affected Program Name: COVID-19: Emergency Connectivity Fund (ECF) Program Assistance Listing Number: 32.009 Pass-Through Entity: N/A ? Direct Award Federal Agency: Federal Communications Commission Criteria or Specific Requirements In accordance with Federal Communications Commission (FCC) Report and Order 21-58 paragraphs 116-118, COVID-19 Emergency Connectivity Fund (ECF) Program participants are required to maintain asset and service inventories of the devices and services purchased with ECF Program support. Asset inventories are required to contain the following elements: (a) device type, (b) device make/model, (c) equipment serial number, (d) the name of the person to whom the device was provided, and (e) the dates the device was loaned out and returned to the school. In accordance with FCC Report and Order 21-58 paragraph 5, ECF Program support shall be used by schools to meet the otherwise unmet connectivity needs of students and school staff during the COVID-19 pandemic. In accordance with FCC Report and Order 21-58 paragraph 54, ECF Program support shall not be used to fund more than one connected device and more than one Wi-Fi hotspot per students or school staff member during the COVID-19 emergency period. Condition The District did not maintain adequate asset inventories for devices purchased using ECF support, as inventory records do not contain all of the aforementioned required elements. The District was not able to substantiate unmet need for all devices for which reimbursement was requested. Cause The condition identified appears to be due to lack of sufficient internal controls to ensure that program requirements are met.

Federal Program Affected Program Name: COVID-19: Emergency Connectivity Fund (ECF) Program Assistance Listing Number: 32.009 Pass-Through Entity: N/A ? Direct Award Federal Agency: Federal Communications Commission Criteria or Specific Requirements In accordance with 2 CFR ?200.214 of the Uniform Guidance, non-Federal entities must verify that vendors are nor suspended or debarred prior to entering into covered transactions. Condition The District did not maintain documentation to demonstrate that they verified whether a vendor was suspended or debarred prior to entering into a covered transaction. Cause The condition identified appears to be due to lack of sufficient internal controls to ensure that program requirements are met.

Federal Program Affected Program Name: COVID-19: Elementary and Secondary School Emergency Relief II (ESSER II) Fund Assistance Listing Number: 84.425D Pass-Through Entity: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria or Specific Requirements The Uniform Guidance 2 CFR ? 200.430(i)(1)(viii) states that budget estimates alone may not be used to allocate compensation charges to Federal awards. When using budget estimates for interim accounting purposes, entities must also establish internal controls to identify significant changes in corresponding work activities and review and adjust after-the-fact interim charges to reflect accurate, allowable, and properly allocated charges. Condition The District charged multi-funded employees based on budget estimates. There was not a system of monitoring and internal controls to identify significant changes in corresponding work activities nor to adjust budgeted charges to reflect the actual percentage of work performed for the grant. Cause The condition identified appears to be due to lack of sufficient internal controls to monitor and adjust after-the-fact employee budgeted time to actual time reflected on approved employee time certifications.

Federal Program Affected Program Name: COVID-19: Emergency Connectivity Fund (ECF) Program Assistance Listing Number: 32.009 Pass-Through Entity: N/A ? Direct Award Federal Agency: Federal Communications Commission Criteria or Specific Requirements In accordance with Federal Communications Commission (FCC) Report and Order 21-58 paragraphs 116-118, COVID-19 Emergency Connectivity Fund (ECF) Program participants are required to maintain asset and service inventories of the devices and services purchased with ECF Program support. Asset inventories are required to contain the following elements: (a) device type, (b) device make/model, (c) equipment serial number, (d) the name of the person to whom the device was provided, and (e) the dates the device was loaned out and returned to the school. In accordance with FCC Report and Order 21-58 paragraph 5, ECF Program support shall be used by schools to meet the otherwise unmet connectivity needs of students and school staff during the COVID-19 pandemic. In accordance with FCC Report and Order 21-58 paragraph 54, ECF Program support shall not be used to fund more than one connected device and more than one Wi-Fi hotspot per students or school staff member during the COVID-19 emergency period. Condition The District did not maintain adequate asset inventories for devices purchased using ECF support, as inventory records do not contain all of the aforementioned required elements. The District was not able to substantiate unmet need for all devices for which reimbursement was requested. Cause The condition identified appears to be due to lack of sufficient internal controls to ensure that program requirements are met.

Federal Program Affected Program Name: COVID-19: Emergency Connectivity Fund (ECF) Program Assistance Listing Number: 32.009 Pass-Through Entity: N/A ? Direct Award Federal Agency: Federal Communications Commission Criteria or Specific Requirements In accordance with 2 CFR ?200.214 of the Uniform Guidance, non-Federal entities must verify that vendors are nor suspended or debarred prior to entering into covered transactions. Condition The District did not maintain documentation to demonstrate that they verified whether a vendor was suspended or debarred prior to entering into a covered transaction. Cause The condition identified appears to be due to lack of sufficient internal controls to ensure that program requirements are met.