2022-066 Oregon Department of Education Improve subrecipient monitoring procedures Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C, 84.425D, 84.425U & 84.425W Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C200048; 20...
2022-066 Oregon Department of Education Improve subrecipient monitoring procedures Federal Awarding Agency: U.S. Department of Education Assistance Listing Number and Name: 84.425C, 84.425D, 84.425U & 84.425W Education Stabilization Fund (COVID-19) Federal Award Numbers and Years: S425C200048; 2020 (COVID-19), S425D200049; 2020 (COVID-19), S425C210048; 2021 (COVID-19), S425D210049; 2021 (COVID-19), S425U210049; 2021 (COVID-19), S425W210038; 2021 (COVID-19) Compliance Requirement: Subrecipient Monitoring Type of Finding: Significant Deficiency; Noncompliance Prior Year Finding: N/A Questioned Costs: N/A Criteria: 2 CFR 200.332 Federal regulations require the department to evaluate each subrecipients risk of noncompliance with Federal statues, regulations, and the terms and conditions of the subaward for purposes of determining the appropriate monitoring to perform. In addition, the department should monitor the activities of the subrecipients receiving funds to ensure the subaward is used for authorized purposes, is in compliance with Federal statutes, regulations, and the terms and condition of the subaward; and the subaward performance goals are achieved. Depending on the department risk assessment, which was not performed, the department could perform various monitoring tools to ensure accountability and compliance. As of June 30, 2022, the department was still in the process of drafting and implementing a plan to monitor the funds. The department had not completed a risk assessment process of the local educational agencies (LEA) for these funds and stated it planned to begin some desk or on-site monitoring in Spring 2023. $522 million in funds have been passed through to subrecipients as of June 30, 2022. The department required LEA?s to submit applications to receive funds and sign agreements that outlined all federal requirements. In addition, the department also required the LEA?s to complete a reimbursement request form that contains general ledger detail but no additional support is provided. According to the department, it follows-up with a LEA if funds appear to be ineligible or other questions are raised. Finally, although LEAs programs may have had a single audit the department could not provide a list of which LEAs had audits and whether there were findings or not. In fiscal year 2021, the department was also working to finalize its risk assessment and monitoring plans. However, the department experienced staff turnover which delayed its plans. Insufficient subrecipient monitoring increases the risk of not timely identifying subrecipients that are not administering federal awards in compliance with federal requirements. We recommend department management complete its risk assessment, consider the results of LEAs single audits and perform desk or on-site monitoring as necessary. MANAGEMENT RESPONSE: We agree with this recommendation. ODE acknowledges that it did not implement pandemic funding related desk audit and site monitoring procedures in FY 21. FY 21 saw the COVID-19 Delta and Omicron variants continue to infect school staff and students so on-site visits were not feasible. The pandemic also forced districts to dedicate administrator time and attention to student health and safety and adjusting to the ever-changing health environment, guidance and requirements. In anticipation of such challenges during the pandemic, ODE set up the ESSER reimbursements to districts allows for much more detailed reporting when requesting reimbursement to allow ODE to track how districts were spending their funds. While not traditional monitoring, it was an effective, efficient, and creative way to ensure ODE spending oversight in unprecedented times. As discussed with Secretary of State auditors, ODE finalized and implemented a risk assessment tool in the spring of 2023 and has completed an initial set of ten monitoring desk reviews with districts. Anticipated Completion Date: June 30, 2024 Contact: Cynthia Stinson, Senior Manager of Federal Investments & Pandemic, Renewal Effort, OTLA