Rochester School District No. 401
September 1, 2022 through August 31, 2023
2023-001 The District did not have adequate internal controls for ensuring compliance with allowable activities and costs, and restricted purpose requirements.
Assistance Listing Number and Title:
32.009, COVID-19 – Emergency Connectivity Fund Program
Federal Agency Name:
Federal Communications Commission
Federal Award/Contract Number:
ECF2290001403
Pass-through Entity Name:
N/A
Pass-through Award/Contract Number:
N/A
Known Questioned Cost Amount:
$405,807
Prior Year Audit Finding:
N/A
Background
The Emergency Connectivity Fund (ECF) Program provides funding to meet the needs of students and school staff who would otherwise lack access to connected devices and broadband connections sufficient to engage in remote learning. This is referred to as “unmet need.” In fiscal year 2023, the District spent $405,807 in ECF Program funds to purchase laptops for students.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls.
Allowable activities and costs
ECF Program recipients may only seek reimbursement for eligible devices and services provided to students and staff with unmet need. Recipients are prohibited from seeking reimbursement for eligible equipment and services used solely at the school or held for future use (in other words, warehousing).
Office of the Washington State Auditor sao.wa.gov
Restricted purpose – unmet need
When submitting applications to the Federal Communications Commission (FCC), schools only had to provide an estimate of their students’ and staff’s unmet need. However, when requesting reimbursement, the District could only request program funds for eligible equipment and services provided to students and school staff with actual unmet need.
Description of Condition
Allowable activities and costs/restricted purpose – unmet need
The District estimated unmet need for eligible equipment when it applied for ECF Program funds. However, our audit found the District’s internal controls were ineffective for ensuring it documented the determination of actual unmet need and only requested reimbursement for equipment provided to students. Specifically, the District purchased laptops, based on its estimate of unmet need, and it requested reimbursement for these purchases totaling $405,807. However, the District did not provide all of the laptops to students with unmet need. In addition, 92 of the 1,000 laptops purchased were stored in the District’s libraries to be used by students, but not checked out.
We consider these deficiencies in internal controls to be material weaknesses that led to material noncompliance.
Cause of Condition
Allowable activities and costs/restricted purpose – unmet need
District staff believed they had complied with federal requirements by documenting their blanket justification for unmet need, which was based on the fact that all the laptops included proprietary software use by the school. However, staff could not demonstrate that students needed the software to complete schoolwork remotely.
Effect of Condition and Questioned Costs
Allowable activities and costs/restricted purpose – unmet need
Because the District did not have documentation supporting whether it provided eligible equipment to students with actual unmet need, it cannot demonstrate compliance with the program’s requirements. Given the nature of the program and circumstances, it is likely that at least some of the equipment the District charged to the award addressed unmet needs. However, the lack of a documented
Office of the Washington State Auditor sao.wa.gov
assessment of students’ actual unmet need means that all costs are unsupported. Since we do not have a reasonable basis for estimating how much of the District’s expenditures are allowable, we are questioning all unsupported costs.
Federal regulations require the Office of the Washington State Auditor to report known questioned costs that are greater than $25,000 for each type of compliance requirement. We question costs when we find the District does not have adequate documentation to support expenditures.
Recommendation
We recommend the District work with the awarding agency to determine audit resolution.
We further recommend the District establish and follow internal controls to ensure staff fully understand the requirements for ECF awards. Specifically, the District should request reimbursement only for eligible equipment provided to students with unmet need, and maintain documentation demonstrating compliance.
District’s Response
Rochester School District does not concur with the audit finding. Funds were not misused and were spent for the intended purpose. In preparing for remote learning, the District felt the responsibility to ensure online learning was safe for students by providing them with a device that had internet content filtering. Another priority was ensuring equity of access and opportunity for all students no matter the quality of device they had at home. In addition, the district does not have the technology staff needed to troubleshoot personally owned devices. Using the grant funding, the District purchased Chromebooks that had Linewize/Classwize (internet filtering software, classroom management software) as well as state testing software for things like WIDA and SBA testing. Also, we installed Zoom, Screencastify, and student diagnostic testing software on the district devices. Having the devices preloaded with this software allowed our technology department to push software updates to each device and have the ability to remote into the devices to troubleshoot as needed. The software mentioned above would allow students to successfully participate in remote learning, if needed.
In addition, the District did conduct a survey of families and identified 1,898 students were in need of a school issued device. This grant purchased 1,000 Chromebooks. Every student in Rochester received a district issued Chromebook. In our inventory process, we did not tie the newly purchased Chromebooks to students identified as having a need; however, all those in need
Office of the Washington State Auditor sao.wa.gov
received a district device. With 1,898 students identified as having “unmet need” and 1,000 Chromebooks purchased, there should not be questioned costs as the costs are more than supported.
The District thanks the Auditor’s Office for their professionalism and thorough review.
Auditor’s Remarks
The State Auditor’s Office is sympathetic to the significant challenges the District faced during the COVID-19 pandemic, and deeply respects its commitment to student learning despite these challenges. SAO knows that in many cases, governments across Washington received significant pandemic-era federal funds without also receiving clear guidance on how to use them. Then, and now, SAO continues to advocate for clear, timely guidance from federal agencies to make sure Washington governments are not put in a difficult position at audit time. However, when auditing federal programs of any kind, governments must provide documentation to substantiate that they met the grant requirements. As is our practice and audit standards require, we will review the status of this finding during our next audit. We value our partnership with the District in striving for transparency in public service.
Applicable Laws and Regulations
Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings.
Title 2 CFR Part 200, Uniform Guidance, section 303 Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements.
The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
Title 47 CFR Part 54, Universal Service, Subpart Q, Emergency Connectivity Fund, describes the ECF Program requirements.