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2022-002 50000 ? Federal Compliance (Significant Deficiency, Noncompliance) Federal Program Affected Federal Agency: U.S. Department of Education Pass-Through Agency: California Department of Education (CDE) Assistance Listing Number: 84.425U Program Name: COVID-19 Elementary and Secondary School Emergency Relief III (ESSER III) Fund: Learning Loss Compliance Requirements: A/B (Activities Allowed or Unallowed and Allowable Costs/cost Principles) Criteria or Specific Requirements The United States Department of Education has approved a delegation agreement with the California Department of Education (CDE) that authorizes the CDE to establish indirect cost rates for California local education agencies (LEAs). The CDE has been delegated authority to calculate and approve indirect cost rates annually for LEAs. For the Education Stabilization Fund (ESF) Program in fiscal year 2021-2022, Education Code Section 38101(c) limits school district indirect costs to the lesser of the District?s individual CDE approved indirect cost rate, or the statewide average indirect rate. For ESF programs included under the Expanded Learning Opportunities (ELO) Grant, indirect costs are not allowable. Condition The District charged unallowable indirect costs totaling $10,937 to the ELO Grant portion of the ESF Program. Questioned Costs The condition identified above resulted in $10,937 of questioned costs for unallowable indirect costs charged to the grant funds Context The condition was identified through recalculation of all of the indirect costs charged to the federal programs.Effect The District has charged unallowable expenditures to the federal program. Cause The condition identified appears to be due to the District not being familiar with the indirect cost requirements for each of the ESF federal programs. Repeat Finding No. Recommendation It is recommended that the District implement a review process for indirect costs, which should include review of relevant grant agreements and relevant federal guidance. Corrective Action Plan and Views of Responsible Officials The District is aware of this incorrect charge and has implemented procedures that include verification of the appropriateness of indirect costs charged to restricted programs.