FAC Explorer

Finding 21412 (2022-003)

Significant Deficiency
Requirement
FN
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 18333
Organization: School District of the City of St. Louis (MO)
Auditor: Rubinbrown LLP

AI Summary

  • Core Issue: Missing signed equipment use agreements for students receiving remote connectivity devices.
  • Impacted Requirements: Compliance controls under Uniform Guidance were not effectively implemented, risking eligibility for federal program benefits.
  • Recommended Follow-Up: Management should enhance processes to ensure all equipment use agreements are properly documented and retained for compliance with federal grant requirements.

Finding Text

Finding 2022-003 Significant Deficiency: Equipment and Real Property Management ? Control Finding; Special Test and Provisions: Restricted Purpose - Control Finding ALN 32.009 ? Emergency Connectivity Fund Federal Agency: Federal Communication Commission Pass-Through Entity: Universal Service Administrative Co. Criteria Or Specific Requirement: Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with the requirements of the federal program. Condition: The signed equipment use agreement related to the student?s remote connectivity was not retained. This agreement should be obtained for any student that checks out equipment through the District and retained. Cause: Controls over compliance put in place by management were not operating effectively as it relates to these compliance requirements. Effect: The possibility exists that an ineligible student could receive wireless service through a connected device, or exceed the limit on the number of connected devices. Questioned Costs: Not applicable. Context: Internal controls as designed by the District were to ensure students signed the use agreement for equipment checked out. A signed use agreement was unable to be located for 21 out of 40 students tested for equipment and real property and special test and provision requirements. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management review its processes and controls surrounding applicable compliance requirements to improve the existing system such that it will ensure compliance with the requirements of federal grants. Views Of Responsible Officials: The District will review and adjust the current process and make necessary adjustments to ensure each student with an ECF device will have the necessary documentation in their file. The District will also develop an additional contract to distinguish between an ECF device versus a regular district issued device.

Corrective Action Plan

Finding 2022-003 Personnel Responsible For Corrective Action: Cheryl Vannoy, Deputy Superintendent, Accountability, Data & Technology Services Anticipated Completion Date: June 30, 2023 Corrective Action Plan: The Information Technology Department will revise the Technology Issue and Reclamation Plan to include two reconciliation periods, one after technology issuance in the summer/fall, and the other after technology reclamation in the spring/summer, to ensure that all contracts and documentation accounted for have the correct corresponding contract in the devices profile in the database where the documents are kept.

Categories

Equipment & Real Property Management Subrecipient Monitoring Eligibility Significant Deficiency

Other Findings in this Audit

  • 21409 2022-002
    Significant Deficiency Repeat
  • 21410 2022-002
    Significant Deficiency Repeat
  • 21411 2022-002
    Significant Deficiency Repeat
  • 21413 2022-004
    Significant Deficiency
  • 21414 2022-005
    Significant Deficiency
  • 597851 2022-002
    Significant Deficiency Repeat
  • 597852 2022-002
    Significant Deficiency Repeat
  • 597853 2022-002
    Significant Deficiency Repeat
  • 597854 2022-003
    Significant Deficiency
  • 597855 2022-004
    Significant Deficiency
  • 597856 2022-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.553 School Breakfast Program $4.30M
32.009 Covid-19: Emergency Connectivity Fund Program $2.36M
10.555 National School Lunch Program $1.41M
10.558 Child and Adult Care Food Program $1.02M
84.424 Student Support and Academic Enrichment Program $989,098
84.002 Adult Education - Basic Grants to States $969,421
84.367 Improving Teacher Quality State Grants $850,777
84.425 Covid-19: Education Stabilization Fund $725,947
84.048 Career and Technical Education -- Basic Grants to States $626,546
21.027 Covid-19: Coronavirus State and Local Fiscal Recovery Funds $560,670
10.582 Fresh Fruit and Vegetable Program $477,723
10.559 Summer Food Service Program for Children $454,663
84.027 Special Education_grants to States $333,567
84.365 English Language Acquisition State Grants $327,904
93.566 Refugee and Entrant Assistance_state Administered Programs $234,407
12.000 Air Force Rotc $223,046
84.173 Special Education_preschool Grants $204,389
12.000 Army Rotc $99,587
84.377 School Improvement Grants $75,971
12.000 Naval Rotc $52,761
16.839 Stop School Violence $44,618
84.010 Title I Grants to Local Educational Agencies $40,582
10.575 Farm to School Grant Program $34,513
12.000 Marines Rotc $33,399