The District does not concur with the audit finding or the $858,725 of questioned costs. This finding is the same as reported in the 21/22 audit. The District still contends that the costs were allowable. The issues regarding internal controls and reporting were not brought to the District’s attenti...
The District does not concur with the audit finding or the $858,725 of questioned costs. This finding is the same as reported in the 21/22 audit. The District still contends that the costs were allowable. The issues regarding internal controls and reporting were not brought to the District’s attention until 10 months into the 22/23 audit period, leaving no time for discussion or changes in interpretation and process.
The audit’s condition states that our internal controls were ineffective for ensuring we requested reimbursement only for students and staff with a documented unmet need and that our internal controls were ineffective for demonstrating per location and per user limitations. Based on guidance from the Federal Communications Commission (excerpted below), the District contends we have spent all funds for allowable costs, that those costs were reasonable and necessary, and for students and staff with unmet needs.
Districts were able to determine whether students and staff had unmet needs. For our district this meant addressing instances where students may have shared a home device with other siblings; student or staff devices were too old or slow to function properly when running
multiple required applications; and / or student owned devices did not have the appropriate
security in place to protect students during remote learning (especially from unauthorized websites). Home drives, where all educational digital resources were stored, couldn’t be accessed unless using a district issued device. Additionally, the district’s technical support could not access personally owned devices to provide for thousands of trouble tickets and support issues students faced during remote learning.
Based on these factors, unmet need was defined broadly, but within allowed parameters and inventory records were kept, albeit, not perfectly.
Devices for remote learning could also be used at school. During the pandemic in Washington State we experienced times when classrooms, schools and or districts were closed by the health department and state regulations because of outbreaks. Districts had to be prepared to support remote learning each day with constantly changing guidance on who was allowed to be in person.
Seattle Public Schools followed guidance from the Federal Communications Commission outlined in a document titled: . “Emergency Connectivity Fund Common Misconceptions”, “Misconception #2: If schools have returned to in-class instruction for the upcoming school year, they are not eligible to participate.
Answer: This is false. Equipment and services provided to students or school staff who would otherwise lack sufficient access to connected devices, and/or broadband internet access connection while off campus is eligible for Emergency Connectivity Fund Support.”
Additionally, from the Federal Communications Commission Order FCC-CIRC21-93-043021, question 77: “We think schools are in the best position to determine whether their students and staff have devices and broadband services sufficient to meet their remote learning needs, and we recognize that they are making such decisions in the midst of a pandemic. We, therefore, will not impose any specific metrics or process requirements on those determinations.” And from question 51: “…we are sensitive to the need to provide some flexibility during this uncertain time. If those connected devices were purchased for the purpose of providing students…with devices for off-campus use consistent with the rules we adopt today, we will not prohibit such on-campus use.”
Finally, SAO did not apply any reasonable measure to reduce questioned costs but did state they know that at least some of the equipment addressed unmet needs, while still choosing to question all costs. That is clearly out of alignment with the FCC guidance.
There are no corrective actions to take at this time as the funding source has been exhausted and the timeline has passed.