Finding 1057882 (2023-001)

FEDERAL COMMUNICATIONS COMMISSION EMERGENCY CONNECTIVITY FUND PROGRAM - AL NUMBER 32.009 AUDIT PERIOD - YEAR ENDED JUNE 30, 2023 2023-001.Activities Allowed or Unallowed / Special Tests and Provisions Criteria or specific requirement: Office of Management and Budget (OMB) 47 CFR § 54.1710 requires entities requesting funding to certify that they are only seeking support for eligible equipment provided to students and school staff who would otherwise lack connected devices sufficient to engage in remote learning. OMB 47 CFR § 54.1706 (b) states that eligible schools cannot request and receive support for the purchase of eligible equipment and services for use solely at the school; however, some on-campus use is permitted for eligible equipment that was purchased primarily to provide off-campus access. Condition: During testing, we identified 652 devices, totaling $227,400, were reimbursed by the Emergency Connectivity Fund. Adequate supporting documentation was not retained to support the actual unmet need for the devices, as required by the grant. Additionally, the devices were purchased primarily for on-campus use. Cause: District's unfamiliarity with the new federal program. The service provider submitted the request for reimbursement without consulting the District to determine the actual amount of equipment provided to students and school staff with unmet needs. Effect or potential effect: The District received funding in excess of the documented actual unmet need for their students and school staff resulting in questionable costs of $227,400. Questioned costs: The questioned costs for 652 devices totaled $227,400. Context: Adequate documentation of actual unmet need could not be provided for 652 devices totaling $227,400. The District purchased and was reimbursed for a total of 830 devices for $286,140. Identification as a repeat finding: No Recommendation: The District should contact the Federal Communications Commission for guidance regarding this matter and implement proper controls over program expenditures. Views of responsible officials: The district will contact the FCC and review the procedures used by the E-rate/Technology Coordinator to determine how this came about and develop further procedures to avoid this happening again.