Finding 2022-042 Education Stabilization Fund, ALN 84.425 - During-the-Award Monitoring Procedures Management Views For part a., MDE partially agrees with the finding. MDE acknowledges that it did not complete any reviews of the FERs submitted during fiscal year 2022. However, the Uniform Guidanc...
Finding 2022-042 Education Stabilization Fund, ALN 84.425 - During-the-Award Monitoring Procedures Management Views For part a., MDE partially agrees with the finding. MDE acknowledges that it did not complete any reviews of the FERs submitted during fiscal year 2022. However, the Uniform Guidance does not specify a timeframe for the review of FERs for the Education Stabilization Funds (ESF) and the ESF program is inherently more flexible than other federal programs in this regard. Although GANs originally required ESF subrecipients to submit a FER by August 29, 2022, MDE communicated to ESF subrecipients after the initial GANs that the August 29, 2022 due date was subject to change due to the continuously changing rules and requirements around this funding, including extension possibilities such as late liquidation. ESF FERs were due either within 60 days of full draw of the funds or within 60 days of the end of the award period, which could have been during the State?s fiscal year 2022 or well after September 30, 2022. For this reason, under Uniform Guidance, MDE had the authority to delay the review of FERs until closer to the end date of the award. In the case of late liquidation, the U.S. Department of Education provided notification that extended the award period as far as 14 months beyond the original end date of the award. For part b., MDE partially agrees with the finding. MDE acknowledges that subrecipient desk reviews were not finalized; however, the majority of the subrecipient monitoring was complete. The Uniform Guidance does not specify a timeframe for ESF subrecipient monitoring to occur and no requirement or expectation was made that monitoring would be finalized by MDE management by September 30, 2022. While the MDE contractor was not tracking completion against the date of September 30, 2022, documentation was and is still available, upon request from the OAG, to demonstrate the substantial ongoing monitoring activities, such as desk reviews and review of amendments, as of the end of the State?s fiscal year 2022. The Compliance Team was in regular contact with MDE throughout the monitoring process. The Compliance Team provided regular updates leading up to September 30, 2022 and shared comprehensive preliminary results with the department soon after September 30, 2022. Planned Corrective Action For part a., MDE will evaluate the process for reviewing FERs to determine the appropriate timeframe for FER review of these ESF funds in light of federal liquidation extensions. MDE and subrecipients were notified of a one-time, Coronavirus Aid, Relief, and Economic Security Act reopening drawdown opportunity during the spring of 2023, which again reopened the possibility for subrecipients to submit FERs. MDE will begin interim reviews of a sample of submitted FERs by September 30, 2023. For part b., MDE?s contractor provided MDE with the final results of its school year 2021 monitoring that was finalized during the summer of 2022 on January 5, 2023. MDE and its contractor have since followed up with subrecipients to recommend necessary or reasonable corrective action in March 2023. School year 2022 monitoring is ongoing and anticipated to be completed by September 30, 2023. Anticipated Completion Date September 30, 2023 Responsible Individual(s) Spencer Simmons, MDE