Finding 374517 (2023-001)

-
Requirement
B
Questioned Costs
$1
Year
2023
Accepted
2024-03-08

AI Summary

  • Core Issue: Classroom projectors costing over $5,000 were purchased without prior approval from the California Department of Education.
  • Impacted Requirements: Violations of 2 CFR sections 200.311, 200.313, and 200.439 regarding capital expenditures and equipment purchases.
  • Recommended Follow-Up: Ensure the District obtains prior approval from CDE for all capital purchases exceeding $5,000 to avoid potential fund recovery.

Finding Text

FINDING #2023-001: EDUCATION STABILIZATION FUNDS – EQUIPMENT AND OTHER CAPITAL EXPENDITURES (50000) Program Names: Elementary and Secondary School Emergency Relief II (ESSER II) Fund, Expanded Learning Opportunities (ELO) Grant: ESSER III State Reserve, Emergency Needs, and Expanded Learning Opportunities (ELO) Grant: ESSER III State Reserve, Learning Loss Assistance Listing Number: 84.425 Pass-Through Agency: California Department of Education (CDE) Federal Agency: U.S. Department of Education Criteria: Consistent with 2 CFR section 200.311 (real property), section 200.313 (equipment), and section 200.439 (equipment and other capital expenditures) ESF funds may be used to purchase equipment. Capital expenditures for general and special purpose equipment purchases are subject to prior approval by ED or the pass-through entity. Condition: Through testing of a representative sample of ESF expenditures, we noted that the classroom projector project did not appear to be pre-approved by the California Department of Education (CDE). Each purchase order provided for the purchase and installation of classroom projectors with a per unit cost in excess of $5,000 (including installation and other ancillary costs). Context: The condition was identified through the testing of ESF expenditures. Cause: District oversight. Effect: The funds spent on these purchases may be subject to review by or return to the awarding agency. Questioned Costs: $718,634 Repeat Finding: This is not a repeat finding. Recommendation: We recommend that the District obtain prior approval from CDE for all capital purchases from the Education Stabilization Fund in excess of $5,000. Views of Responsible Officials: See Corrective Action Plan on following page.

Corrective Action Plan

The District's procedure for purchases utilizing federal funds for goods in excess of $5,000 are submitted to the California Department of Education prior to purchase for approval. The District utilized COVID relief funds to upgrade classrooms with equipment consistent in the SVI classroom project. While the components of the SVI project are under the $5,000 threshold for prior approval collectively they are over this threshold. The components being under the $5,000 threshold resulted in an oversight of the needed preapproval for these purchases. Fiscal Services is developing a checklist of required steps in the procurement process when federal funds are being considered to ensure prior approval, if needed, is sought prior to purchase. The checklist will include an area where each component is listed to include delivery cost and installation and will include acknowledgement of whether these components collectively create one asset. This will allow other staff reviewing the checklist to determine if preapproval based on cost may be needed. The checklist will require approval of the department head of the requesting department acknowledging understanding of the federal purchasing requirements for capital expenditure as well as, approval of the Director, Fiscal Services and the District's Assistant Superintendent of Business Services.

Categories

Questioned Costs Equipment & Real Property Management Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
10.553 School Breakfast Program $1.59M
10.555 National School Lunch Program $748,757
84.367 Improving Teacher Quality State Grants $386,186
84.027 Special Education_grants to States $326,562
84.424 Student Support and Academic Enrichment Program $222,057
84.010 Title I Grants to Local Educational Agencies $94,532
84.425 Education Stabilization Fund $55,040
84.365 English Language Acquisition State Grants $54,460
84.181 Special Education-Grants for Infants and Families $30,148
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $23,992
10.665 Schools and Roads - Grants to States $6,551
84.173 Special Education_preschool Grants $3,017