Audit 48515

Community Consolidated School District No. 21 05-016-0210-04 SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ending June 30, 2022 SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2022 - 003 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Emergency Connectivity Fund Program - 2022 4. Project No.: ECF2190013022 5. ASL No.: 32.009 6. Passed Through: Direct Funding 7. Federal Agency: Federal Communications Commission 8. Criteria or specific requirement (including statutory, regulatory, or other citation) "According to 47 CFR Section 54.1706(c), ""Emergency Connectivity Fund support for eligible equipment and services is limited to no more than one fixed broadband internet access connection per location, and one connected device and one Wi-Fi hotspot per student, school staff member, or library patron. In addition there is also an ""unmet need"" requirement. According to the ""2022 Compliance Supplement,"" dated April 2022 and released by the Executive Office of the President Office of Management and Budget, ""When schools file for requests for reimbursement, however, they should only request reimbursement for eligible equipment and services provided to students or school staff who would otherwise lack broadband services and/or devices sufficient to engage in remote learning.""" 9. Condition15 During our audit testing we noted that the District submitted a claim through SPI invoicing for 2,200 laptops ($858,814 in equipment) that exceeded the allowable amount of equipment to satisfy the District's unmet need (equipment available through existing leases). 10. Questioned Costs16 $858,814 in questioned costs identified. The invoiced amount through SPI invoicing for 2,200 computers that were received by the District and not substantiated to meet the District's unmet needs. 11. Context17 The finding is a systemic problem as District procured connectivity devices beyond their unmet needs. The District utlized Emergency Connectivity Funding for payment on several outstanding chromebook leases during the fiscal year and the number of devices within these lease agreements (5,800 chromebooks and 685 staff computers) were for a sufficient number of connectivity devices for the Districts needs. 12. Effect The District was not in compliance with unmet need requirements under the federal award. The District ordered a material amount of additional equipment to the grant in excess of what was already readily available to serve students. 13. Cause The District has not designed and implemented an internal control process to ensure that Emergency Connectivity Funding was utilized exclusively for unmet needs of the District. 14. Recommendation The District should have functional internal controls in place to ensure compliance with unmet need requirements of the federal award. The submissions of claims for reimbursement should be reviewed and approved by someone other than the preparer to ensure the claim does not exceed the unmet need criteria. 15. Management's response18 See corrective action plan 14 See footnote 11. 15 Include facts that support the deficiency identified on the audit finding (?200.516 (b)(3)). 16 Identify questioned costs as required by ?200.516 (a)(3 - 4). 17 See footnote 12. 18 To the extent practical, indicate when management does not agree with the finding, questioned cost, or both.

Community Consolidated School District No. 21 05-016-0210-04 SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ending June 30, 2022 SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2022 - 004 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Emergency Connectivity Fund Program - 2022 4. Project No.: ECF2190013022 5. ASL No.: 32.009 6. Passed Through: Direct Funding 7. Federal Agency: Federal Communications Commission 8. Criteria or specific requirement (including statutory, regulatory, or other citation) Emergency Connectivity Fund Program participants are required to maintain asset and service inventories of the devices and services purchased with ECF Program support. 9. Condition15 During our audit testing we noted that the District did not include all the equipment inventory required criteria in its inventory listing. The inventory listing did not include the full name of the person to whom the device was provided for all pieces of equipment purchased through the ECF grant. 10. Questioned Costs16 N/A 11. Context17 The IT department did not have an inventory listing for ECF equipment that included all required data elements per the compliance requirements. 12. Effect The District was not in compliance with Equipment/Real Property Managment requirements of the federal award. 13. Cause The District did not implement procedures and corresponding internal controls to ensure that inventory records for connectivity devices received under the award were maintained in accordance with the compliance requirements for the federal award program. 14. Recommendation The District should review the compliance supplement and include all required inventory tracking criteria in its inventory log for equipment obtained under the award. 15. Management's response18 See corrective action plan 14 See footnote 11. 15 Include facts that support the deficiency identified on the audit finding (?200.516 (b)(3)). 16 Identify questioned costs as required by ?200.516 (a)(3 - 4). 17 See footnote 12. 18 To the extent practical, indicate when management does not agree with the finding, questioned cost, or both.

Community Consolidated School District No. 21 05-016-0210-04 SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ending June 30, 2022 SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2022 - 003 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Emergency Connectivity Fund Program - 2022 4. Project No.: ECF2190013022 5. ASL No.: 32.009 6. Passed Through: Direct Funding 7. Federal Agency: Federal Communications Commission 8. Criteria or specific requirement (including statutory, regulatory, or other citation) "According to 47 CFR Section 54.1706(c), ""Emergency Connectivity Fund support for eligible equipment and services is limited to no more than one fixed broadband internet access connection per location, and one connected device and one Wi-Fi hotspot per student, school staff member, or library patron. In addition there is also an ""unmet need"" requirement. According to the ""2022 Compliance Supplement,"" dated April 2022 and released by the Executive Office of the President Office of Management and Budget, ""When schools file for requests for reimbursement, however, they should only request reimbursement for eligible equipment and services provided to students or school staff who would otherwise lack broadband services and/or devices sufficient to engage in remote learning.""" 9. Condition15 During our audit testing we noted that the District submitted a claim through SPI invoicing for 2,200 laptops ($858,814 in equipment) that exceeded the allowable amount of equipment to satisfy the District's unmet need (equipment available through existing leases). 10. Questioned Costs16 $858,814 in questioned costs identified. The invoiced amount through SPI invoicing for 2,200 computers that were received by the District and not substantiated to meet the District's unmet needs. 11. Context17 The finding is a systemic problem as District procured connectivity devices beyond their unmet needs. The District utlized Emergency Connectivity Funding for payment on several outstanding chromebook leases during the fiscal year and the number of devices within these lease agreements (5,800 chromebooks and 685 staff computers) were for a sufficient number of connectivity devices for the Districts needs. 12. Effect The District was not in compliance with unmet need requirements under the federal award. The District ordered a material amount of additional equipment to the grant in excess of what was already readily available to serve students. 13. Cause The District has not designed and implemented an internal control process to ensure that Emergency Connectivity Funding was utilized exclusively for unmet needs of the District. 14. Recommendation The District should have functional internal controls in place to ensure compliance with unmet need requirements of the federal award. The submissions of claims for reimbursement should be reviewed and approved by someone other than the preparer to ensure the claim does not exceed the unmet need criteria. 15. Management's response18 See corrective action plan 14 See footnote 11. 15 Include facts that support the deficiency identified on the audit finding (?200.516 (b)(3)). 16 Identify questioned costs as required by ?200.516 (a)(3 - 4). 17 See footnote 12. 18 To the extent practical, indicate when management does not agree with the finding, questioned cost, or both.

Community Consolidated School District No. 21 05-016-0210-04 SCHEDULE OF FINDINGS AND QUESTIONED COSTS Year Ending June 30, 2022 SECTION III - FEDERAL AWARD FINDINGS AND QUESTIONED COSTS 1. FINDING NUMBER:14 2022 - 004 2. THIS FINDING IS: X New Repeat from Prior year? Year originally reported? 3. Federal Program Name and Year: Emergency Connectivity Fund Program - 2022 4. Project No.: ECF2190013022 5. ASL No.: 32.009 6. Passed Through: Direct Funding 7. Federal Agency: Federal Communications Commission 8. Criteria or specific requirement (including statutory, regulatory, or other citation) Emergency Connectivity Fund Program participants are required to maintain asset and service inventories of the devices and services purchased with ECF Program support. 9. Condition15 During our audit testing we noted that the District did not include all the equipment inventory required criteria in its inventory listing. The inventory listing did not include the full name of the person to whom the device was provided for all pieces of equipment purchased through the ECF grant. 10. Questioned Costs16 N/A 11. Context17 The IT department did not have an inventory listing for ECF equipment that included all required data elements per the compliance requirements. 12. Effect The District was not in compliance with Equipment/Real Property Managment requirements of the federal award. 13. Cause The District did not implement procedures and corresponding internal controls to ensure that inventory records for connectivity devices received under the award were maintained in accordance with the compliance requirements for the federal award program. 14. Recommendation The District should review the compliance supplement and include all required inventory tracking criteria in its inventory log for equipment obtained under the award. 15. Management's response18 See corrective action plan 14 See footnote 11. 15 Include facts that support the deficiency identified on the audit finding (?200.516 (b)(3)). 16 Identify questioned costs as required by ?200.516 (a)(3 - 4). 17 See footnote 12. 18 To the extent practical, indicate when management does not agree with the finding, questioned cost, or both.