Audit 343413

Program: ACTIVITIES ALLOWED OR UNALLOWED Criteria: The U.S. Department of Education provided additional guidance to grantees on ESSER funded activities that continue beyond the obligation and liquidation periods. A grantee or subgrantee must obligate ESSER funds within the period of availability and must liquidate those obligations within 120 days of the end of the period of availability (2 CFR section 200.344 (b)) (or within the approved period for a liquidation extension). The guidance states that under limited circumstances where a grantee or subgrantee timely obligates the ESSER funds, it may be allowable for ESSER funded activities to continue for a reasonable time beyond the obligation and liquidation period. Because ESSER is a State-administered program, the SEA or Governor determine whether activities extending past the liquidation period are allowable under the circumstances. The guidance also states that under no circumstances may services extend beyond the date on which funds revert to the U.S. Department of Treasury, which occurs four years after the obligation deadline. Condition: During our test of compliance with activities allowed and unallowed, we noted that the School District entered into multi-year contracts for software licenses and consumable supplies during the period of availability and paid for the entirety of the softwares licenses and consumable supplies within the liquidation period. The contracts were included in the ARP ESSER grant budget approved by the RI Department of Education. The multi-year contracts are for 6 years and extend beyond the liquidation period of September 30, 2024. The contracts extend to June 30, 2029, which is beyond the date on which funds revert to the U.S. Department of Treasury. Cause: The School District was unaware that the services could not extend past fours years of the liquidation date of September 30, 2024, which is September 30, 2028. Effect: The School District entered into contracts using ARP funds, a portion of which are considered an unallowed activity due to the fact that the services provided extend beyond the period allowed. Questioned Costs: $29,348 Recommendation: We recommend that in addition to receiving approval by the RI Department of Education of grant funded projects that the School District staff responsible for approving the grant projects review federal laws and regulations and guidance specific to the grant programs. Views of Responsible Officials: In our commitment to due diligence and adherence to compliance requirements for the expenditure of funds from a federal grant, the School District contacted the responsible representatives at the Rhode Island Department of Education (RIDE) to seek guidance on establishing a multi-year contract for curriculum materials. The budget description submitted to RIDE for approval indicated that the School District adopted the Bridge program in March 2024. It detailed that the associated expenses would be incurred under a six-year contract covering licenses and consumables, classified as High-Quality Curriculum Materials. This expense received both programmatic and budgetary approval from the Rhode Island Department of Education. Moving forward, the School District will request all supporting documentation to ensure compliance to the laws and regulations governing any federal or state grant.

Program: ACTIVITIES ALLOWED OR UNALLOWED Criteria: The U.S. Department of Education provided additional guidance to grantees on ESSER funded activities that continue beyond the obligation and liquidation periods. A grantee or subgrantee must obligate ESSER funds within the period of availability and must liquidate those obligations within 120 days of the end of the period of availability (2 CFR section 200.344 (b)) (or within the approved period for a liquidation extension). The guidance states that under limited circumstances where a grantee or subgrantee timely obligates the ESSER funds, it may be allowable for ESSER funded activities to continue for a reasonable time beyond the obligation and liquidation period. Because ESSER is a State-administered program, the SEA or Governor determine whether activities extending past the liquidation period are allowable under the circumstances. The guidance also states that under no circumstances may services extend beyond the date on which funds revert to the U.S. Department of Treasury, which occurs four years after the obligation deadline. Condition: During our test of compliance with activities allowed and unallowed, we noted that the School District entered into multi-year contracts for software licenses and consumable supplies during the period of availability and paid for the entirety of the softwares licenses and consumable supplies within the liquidation period. The contracts were included in the ARP ESSER grant budget approved by the RI Department of Education. The multi-year contracts are for 6 years and extend beyond the liquidation period of September 30, 2024. The contracts extend to June 30, 2029, which is beyond the date on which funds revert to the U.S. Department of Treasury. Cause: The School District was unaware that the services could not extend past fours years of the liquidation date of September 30, 2024, which is September 30, 2028. Effect: The School District entered into contracts using ARP funds, a portion of which are considered an unallowed activity due to the fact that the services provided extend beyond the period allowed. Questioned Costs: $29,348 Recommendation: We recommend that in addition to receiving approval by the RI Department of Education of grant funded projects that the School District staff responsible for approving the grant projects review federal laws and regulations and guidance specific to the grant programs. Views of Responsible Officials: In our commitment to due diligence and adherence to compliance requirements for the expenditure of funds from a federal grant, the School District contacted the responsible representatives at the Rhode Island Department of Education (RIDE) to seek guidance on establishing a multi-year contract for curriculum materials. The budget description submitted to RIDE for approval indicated that the School District adopted the Bridge program in March 2024. It detailed that the associated expenses would be incurred under a six-year contract covering licenses and consumables, classified as High-Quality Curriculum Materials. This expense received both programmatic and budgetary approval from the Rhode Island Department of Education. Moving forward, the School District will request all supporting documentation to ensure compliance to the laws and regulations governing any federal or state grant.