Finding Text
Finding 2023-001 Significant Deficiency: Equipment and Real Property Management
– Control and Compliance Finding; Special Test and Control Provisions - Control and
Compliance Finding
ALN 32.009 – Emergency Connectivity Fund
Federal Agency: Federal Communication Commission
Pass-Through Entity: Universal Service Administrative Co.
Criteria Or Specific Requirement: The compliance provisions of the federal program require
the dates the device or other piece of equipment was loaned out and returned to the school or
library, or the date the school or library was notified that the device or other piece of equipment
was missing, lost, or damaged be retained for program records. The provisions also restricts use
to no more than one connected device per patron and no more than one fixed broadband
connection per location, and requires that equipment only be provided to patrons who would
otherwise lack broadband services and/or devices sufficient to engage in remote learning.
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 application related to the checking out of either a hotspot or
Chromebook offered by the Library was not retained or completed correctly. This application
should be retained and used to determine eligibility and proper inclusion in the system.
Cause: Controls over compliance put in place by management were not operating effectively as
it relates to these compliance requirements and therefore the compliance with equipment and
real property and special tests and provision requirements were not met.
Effect: The possibility exists that noncompliance with federal requirements could go undetected
without proper controls over compliance.
Questioned Costs: Not applicable.
Context: Internal controls as designed by the Library were to ensure patrons signed and
properly completed the relevant application depending on the type of equipment requested. A
signed application was not retained for 8 of 40 checkouts tested for equipment and real property
and special test and provision requirements, and 2 of 40 applications appeared to not have been
properly filled out. Identification As A Repeat Finding: 2022-001
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: Management continues to implement tightened procedures
and train staff to assure that all applications are completed, signed, dated and retained
correctly for any equipment loaned to Library patrons.