Finding Text
FEDERAL COMMUNICATIONS COMMISSION
EMERGENCY CONNECTIVITY FUND PROGRAM - AL NUMBER 32.009
AUDIT PERIOD - YEAR ENDED JUNE 30, 2023
2023-001 Activities Allowed or Unallowed
Criteria or specific requirement: Office of Management and Budget (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 unallowable costs totaling $228,436 were paid from the Emergency Connectivity Fund for 722 connected devices that were purchased primarily for on-campus access and were not distributed to students for off-campus remote learning.
Cause: Lack of internal controls and management oversight of program expenditures.
Effect: Unallowable costs of $228,436 were paid from the Emergency Connectivity Fund.
Questioned costs: The amount of questioned costs was $228,436.
Context: 722 out of 1,522 devices purchased were not primarily for off-campus use and resulted in unallowable costs.
Identification as a repeat finding: No
Recommendation: The District should contact the Federal Communications Commission for guidance regarding this matter and implement controls over program expenditures.
Views of responsible officials: Based on the information that we had available at the time and based on guidance provided by our E-rate consultant and from conferring with other schools that were also applying for ECF funding, we were within compliance as we understood the requirements to be. The deadline to apply for this wave of funding was before they had finished writing and released the guidelines for this additional one-time funding. We performed the required survey and ordered precisely the number of devices as indicated in the forms that answered that they did not have a reliable internet device at home. The District will contact the Federal Communications Commission for guidance on the matter. If necessary, the computers in question will be distributed in the appropriate manner in accordance with the regulation.