Finding Text
Finding 2023-002 Significant Deficiency: Special Tests and 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
restricts use to no more than one connected device per patron and no more than one fixed
broadband connection per location. Provision also 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 related to service and equipment inventory requirements.
Condition: Out of 40 patrons selected for testing checked out equipment, three patrons were
noted as checking out two or more Chromebooks during the year with no proof of return for the
first Chromebook. Upon investigation by the Library, one of the patrons claimed a Chromebook
was returned, but no record of that return is noted within the system, one patron noted that
they only checked out the most recent Chromebook based on the system, and another patron
was actually an employee of the Library that was checking out the Chromebooks for the
Library’s outreach program. For those three patrons, applications could not be found by the
Library.
Cause: Controls over compliance put in place by management were not operating effectively as
it relates to these compliance requirements and therefore there was no compliance with special
tests and provisions.
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 equipment that is loaned
to the Library’s patron is properly recorded in the system and tracked through the return
process were not operating effectively. Of the 40 patrons tested, verification that the three
patrons did not have more than one Chromebook at a time could not be completed. Identification As A Repeat Finding: 2022-002
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 will review with staff the revised procedures to
assure that all records of loan equipment are accurate based on the retained signed applications
and electronic transaction history.