Sedro-Woolley School District No. 101
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 Grantor Name: Federal Communications Commission
Federal Award/Contract Number: 145240
Pass-through Entity Name: N/A
Pass-through Award/Contract Number: N/A
Known Questioned Cost Amount: $395,009
Prior Year Audit Finding: Yes, Finding 2022-001
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 $395,009 in ECF Program funds to purchase laptops and Wi-Fi hotspots services for students.
Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant 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 an unmet need. Recipients are prohibited from seeking reimbursement for eligible equipment and services used solely at the school or held for future use (for ein other wordsai.e., warehousing).
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 and services 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 and services provided to students and school staff. Specifically, the District purchased laptops and Wi-Fi hotspots based on its estimate of unmet need, and it requested reimbursement for these purchases totaling $395,009. However, the District did not maintain documentation showing it provided each laptop and Wi-Fi hotspot paid with program funds to a student with unmet need.
Cause of Condition
Allowable activities and costs/restricted purpose – unmet need
As communicated in the prior audit finding, Ddistrict staff thought the determination of unmet need provided during the application process was sufficient to comply with this requirement. Since As the funding spanned two fiscal years, the District had already distributed devices and requested reimbursement before prior to identifying this issue in the prior audit. the prior audit identified this issue. ThereforeAs a result, the District they did not take additional action perform additional procedures during the reimbursement process to only request reimbursement for specific students with a documented unmet need.
As communicated in the prior audit finding, the District thought the determination of unmet need provided during the application process was sufficient to comply with this requirement. Since the funding spanned two fiscal years, the District had already distributed devices and requested reimbursement before the prior audit identified this issue. The District did not take any additional action and is waiting for audit resolution from the federal grantor.
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 and services 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 and services the District charged to the award addressed unmet needs. However, the lack of a documented 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’s Office 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 granting 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 and services provided to students with unmet need, and maintain documentation demonstrating compliance.
District’s Response
At the time of grant approval and award the District believed we met all conditions to expend this grant on computers and hotspots for students that were forced into remote learning due to Covid-19. Due to the large number of districts that received this finding, the state has approached the ECF Grantor to provide a waiver because the instructions related to unmet need were unclear to most. Moving forward, we have a full understanding of the requirements for unmet need and will expend future grants accordingly.
Auditor’s Remarks
We value our partnership with the District in striving for transparency in public service. When auditing federal programs of any kind, governments must provide documentation to substantiate that they met the award requirements. As is our practice and audit standards require, we will review the status of this finding during our next audit. SAO continues to advocate for clear, timely guidance from federal agencies.
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.