FAC Explorer

Finding 46874 (2022-004)

Significant Deficiency
Requirement
FN
Questioned Costs
-
Year
2022
Accepted
2022-12-19
Audit: 45922
Organization: Los Angeles Unified School District (CA)
Auditor: Simpson and Simpson LLP

AI Summary

  • Core Issue: The District lacks sufficient internal controls for maintaining accurate records of equipment acquired under the Emergency Connectivity Fund (ECF) program, leading to non-compliance with the per-user limitation.
  • Impacted Requirements: Compliance with 47 CFR 54.1706 (c) regarding equipment limitations and 2 CFR 200.303 (a) for effective internal controls over Federal awards.
  • Recommended Follow-Up: Strengthen policies for equipment record-keeping, review year-end equipment lists for accuracy, and ensure compliance with the per-user limitation before submitting reimbursement requests.

Finding Text

Program Identification Finding Reference Number: F-2022-004 Assistance Listing Number: 32.009 Federal Program Title: Emergency Connectivity Fund Program (Significant Deficiency) Awarding Agency / Pass-Through Entity: Federal Communications Commission Award Number: Not Available Compliance Requirement: Equipment/Real Property Management; Special Tests and Provisions State Audit Guide Finding Code: 30000 and 50000 Criteria 47 CFR 54.1706 (c) states Emergency Connectivity Fund support for eligible equipment and services is limited to no more than one fixed broadband internet access connection per location, and one connected device and one Wi-Fi hotspot device per student, school staff member, or library patron. 2 CFR 200.303 (a) states that the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition During our audit, we noted that the District did not have sufficient controls in place within its Emergency Connectivity Fund (ECF) program to ensure that proper records were maintained for equipment acquired under the ECF program. The District utilized fundings from both ECF and another Federal grant, Elementary and Secondary School Emergency Relief II (ESSER II), for connectivity to meet the remote learning needs of students, school staff, and library patrons during the COVID-19 emergency period. We noted that eligible devices, such as connectivity devices and Wi-Fi hotspot devices, had originally been purchased using ESSER II grant. Subsequently, a portion of the costs were allocated/transferred to the ECF program. We obtained a list of equipment purchased with ECF funds for our review and noted that they were not in compliance with the ?per-user? limitation. The original listing of equipment indicated that twenty-six (26) individuals were distributed with more than one (1) device. After further inquiry, the District provided an updated equipment list which indicated that ten (10) individuals were distributed with more than one (1) device. Cause and Effect The condition was due to a lack of sufficient internal controls over maintaining accurate property/equipment records and internal controls over compliance with the ?per-user? limitation requirement. The District did not properly identify equipment funded with Federal awards to ensure maintenance of accurate property/equipment inventories. Also, the District did not maintain a proper tracking system to ensure compliance with the ?per-user? limitation requirement. Questioned Costs Not applicable. This finding is considered a programmatic non-compliance issue as well as a deficiency in the internal control system over equipment inventory management as the District has yet to submit the request for reimbursement. Recommendation We recommend that the District strengthen its policies and procedures related to maintaining accurate property/equipment records in order to comply with the program requirements. We also recommend that the District perform a thorough review of the year-end equipment list to ensure it is complete and accurate. We also recommend that the District review the listing of devices distributed to students/school staff to ensure that there are no other instances of non-compliance with the per-user limitation requirement, and that non-compliance devices be removed from the request for reimbursement to be submitted to the Federal Communications Commission. View of Responsible Officials and Corrective Action Plan The District acknowledges the need to strengthen the staff?s compliance to policies and procedures related to equipment tracking and property records. ECF is a new program and there was an urgent need for the District to provide the necessary equipment for connectivity to meet the remote learning needs of students/school staff during the COVID-19 emergency period. Beginning January 3, 2023, the District will provide additional training to staff as needed and will reiterate the policies and procedures to ensure compliance with program requirements. The District will conduct a thorough review of devices distributed to students/school staff prior to requesting any reimbursement from the program administrator to ensure compliance with the per-user limitation requirement. Name: Aaron Wai Title: Admin Services Manager, Information Technology Division E-mail: aaron.wai@lausd.net

Corrective Action Plan

Views of Responsible Officials, Corrective Action Plans, and Contact Information The District acknowledges the need to strengthen the staff?s compliance to policies and procedures related to equipment tracking and property records. ECF is a new program and there was an urgent need for the District to provide the necessary equipment for connectivity to meet the remote learning needs of students/school staff during the COVID-19 emergency period. Beginning January 3, 2023, the District will provide additional training to staff as needed and will reiterate the policies and procedures to ensure compliance with program requirements. The District will conduct a thorough review of devices distributed to students/school staff prior to requesting any reimbursement from the program administrator to ensure compliance with the per-user limitation requirement. Name: Aaron Wai Title: Admin Services Manager, Information Technology Division E-mail: aaron.wai@lausd.net

Categories

Equipment & Real Property Management Special Tests & Provisions

Other Findings in this Audit

  • 46865 2022-003
    Significant Deficiency Repeat
  • 46866 2022-003
    Significant Deficiency Repeat
  • 46867 2022-003
    Significant Deficiency Repeat
  • 46868 2022-003
    Significant Deficiency Repeat
  • 46869 2022-003
    Significant Deficiency Repeat
  • 46870 2022-003
    Significant Deficiency Repeat
  • 46871 2022-003
    Significant Deficiency Repeat
  • 46872 2022-003
    Significant Deficiency Repeat
  • 46873 2022-003
    Significant Deficiency Repeat
  • 46875 2022-005
    Material Weakness
  • 46876 2022-005
    Material Weakness
  • 46877 2022-005
    Material Weakness
  • 46878 2022-002
    Material Weakness Repeat
  • 46879 2022-002
    Material Weakness Repeat
  • 46880 2022-002
    Material Weakness Repeat
  • 46881 2022-002
    Material Weakness Repeat
  • 46882 2022-001
    Material Weakness Repeat
  • 46883 2022-001
    Material Weakness Repeat
  • 623307 2022-003
    Significant Deficiency Repeat
  • 623308 2022-003
    Significant Deficiency Repeat
  • 623309 2022-003
    Significant Deficiency Repeat
  • 623310 2022-003
    Significant Deficiency Repeat
  • 623311 2022-003
    Significant Deficiency Repeat
  • 623312 2022-003
    Significant Deficiency Repeat
  • 623313 2022-003
    Significant Deficiency Repeat
  • 623314 2022-003
    Significant Deficiency Repeat
  • 623315 2022-003
    Significant Deficiency Repeat
  • 623316 2022-004
    Significant Deficiency
  • 623317 2022-005
    Material Weakness
  • 623318 2022-005
    Material Weakness
  • 623319 2022-005
    Material Weakness
  • 623320 2022-002
    Material Weakness Repeat
  • 623321 2022-002
    Material Weakness Repeat
  • 623322 2022-002
    Material Weakness Repeat
  • 623323 2022-002
    Material Weakness Repeat
  • 623324 2022-001
    Material Weakness Repeat
  • 623325 2022-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.425 Covid-19 Elementary and Secondary School Emergency Relief (esser Ii) Fund $693.06M
84.425 Covid-19 American Rescue Plan Act (arp Act) Esser III Fund $392.28M
84.010 Every Student Succeeds Act (essa), Title I Part A Basic $331.33M
10.555 Child Nutrition School Programs Lunch $176.59M
10.558 Child Nutrition Child Care Food Program (ccfp) Claims $142.65M
84.027 Special Ed: Idea Basic Local Assistance Entitlement $110.06M
93.323 Covid-19 Epidemiology and Laboratory Capacity for Infectious Diseases (elc), School Based Covid-19 Testing $75.04M
10.553 Child Nutrition School Programs Breakfast $68.41M
84.425 Covid-19 Expanded Learning Opportunities (elo) Esser II Fund State Reserve $54.21M
10.559 Child Nutrition Summer Food Services Program Operations $28.67M
84.424 Essa Title Iv, Part A, Student Support and Academic Enrichment Grant Program $28.22M
84.367 Essa Title Ii, Part A, Supporting Effective Instruction $26.51M
32.009 Emergency Connectivity Fund Program $25.91M
10.555 Donated Food Commodities $24.70M
10.555 Covid-19 Child Nutrition School Nutrition Program (snp) Emergency Operational Costs Reimbursement (ecr) $13.30M
84.027 Special Ed: Individual with Disabilities Education (idea) Local Assistance, Part B, Sec.611 Early Intervening Services $13.17M
10.558 Child Nutrition Child Care Food Program - Cash in Lieu of Commodities $9.73M
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $9.37M
84.365 Title III English Learner Student $8.95M
84.002 Wioa - Adult Basic Ed/ela $8.66M
84.425 Covid-19 Governor's Emergency Education Relief (geer) Fund: Learning Loss Mitigation $7.11M
10.558 Covid-19 Child Nutrition Child and Adult Care Food Program (cacfp) Ecr $6.87M
84.027 Special Ed: Idea Mental Health Allocation Plan $6.53M
84.010 Essa, Comprehensive Support & Improvement (csi) $6.08M
84.048 Carl D. Perkins - Secondary Program, Sec131 $6.00M
84.173 Idea Preschool Expansion Grant $5.09M
84.002 Wioa - Ad Ed & Fam Lit/el - Civics $4.88M
84.425 Covid-19 Esser Fund California Community Schools Partnership Program $4.59M
84.002 Wioa - Adult Secondary Ed $3.72M
93.575 Covid-19 Child Development: Coronavirus Response and Relief Supplemental Appropriations (crrsa) Act - One Time Stipend $3.54M
84.425 Covid-19 Elo Grant Geer II $3.18M
93.596 General Child Care Center - Mandatory & Matching Fund $3.06M
84.425 Covid-19 Esser Fund $2.51M
97.039 Hazard Mitigation Grant Program $2.22M
84.126 Rehab- Transition Partnership Program/trans Part - Greater La $2.04M
12.U00 Reserve Officer Training Corps Vitalization Act $1.87M
84.048 Carl D. Perkins - Vocational and Technical Education, Sec 132 $1.74M
84.027 Special Ed: Idea Local Assistance, Private School Isps $1.68M
93.575 General Child Care Center - Block Grant $1.41M
84.377 School Improvement Grants $1.28M
84.173 Special Ed: Idea - Part B, Sec 619; Preschool Grants Early $1.23M
84.010 Essa, Title I Part A. Neglected $1.18M
84.181 Special Education-Grants for Infants and Families: Early Intervention Funds - Part C $1.17M
17.259 Wioa - T-1 Youth Source System $1.07M
93.505 Affordable Care Act (aca) Maternal, Infant, and Early Childhood Home Visiting Program $1.02M
84.011 Title I - Migrant Ed - Regular $874,537
10.559 Child Nutrition Summer Food Services Program Sponsor Administration $756,231
84.173 Special Ed: Idea - Part B, Sec 619; Preschool Grants Early Intervening Services $708,178
84.365 Title III Immigrant Student $507,829
84.425 Covid-19 Twenty-First Century Learning Centers Rate Increase Elementary and Secondary School Emergency Relief (esser Iii) State Reserve After School Programs $492,444
93.079 Cdcp - School Based Hiv/std Prevention $455,922
84.425 Covid-19 Arp Act - Homeless Children and Youth (arp-Hcy) Program $310,076
84.196 Education for Homeless Children & Youth $301,288
84.287 Twenty-First Century Community Learning Centers $299,829
93.600 Early Head Start $289,157
84.305 Air Credit Recovery $209,681
84.011 Title I - Migrant Ed - Summer $208,189
84.425 Covid-19 Coronavirus Aid, Relief, and Economic Security (cares) Act Esser Child Nutrition $207,015
93.994 Child Health Outreach Initiative - Whole Person Care $177,470
84.060 Indian Education $115,847
17.259 Wioa Youth $102,000
93.575 Cctr Programs Administered by California Department of Social Services $99,736
17.258 Workforce Innovation and Opportunity Act (wioa) - Worksource Educational Partnership - Adult $90,279
20.205 Highway Planning and Construction: Active Transportation Program $86,843
84.027 Special Ed: Idea - Supporting Inclusive Practices, Part B - Sec 611 $83,799
17.278 Wioa - Worksource Educational Partnership - Dislocated Workers $71,974
17.245 Employment Development Department Trade Act: Trade Adjustment Assistance (taa) $71,300
84.027 Special Ed: Idea - Alternate Dispute Resolution, Part B - Sec 611 $69,986
84.365 National Professional Development Grant, Project Royal $65,295
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) Tick Fire $49,003
93.566 California Department of Social Services Refugee Program Bureau $47,687
47.076 Usc - Math for America Los Angeles $47,577
10.665 Forest Reserve $42,851
12.900 Startalk: Exploring Arabic Through Technology, Startalk - Lausd $39,063
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) Getty Fire $34,567
84.011 Title I - Migrant Ed - School Readiness $32,656
84.010 Essa, Title I Part D. Delinquent $30,919
84.173 Preschool Expansion - Staff Development $26,402
84.365 Loyola Marymount University (lmu) Purposeful Engagement in Academic Rigor and Language Learning (pearll) Project $26,382
93.558 County Youth Jobs Program - Calworks $13,999
84.411 Wested Federal Investing in Innovation and Improvement Program I3 Grant $13,058
84.173 Special Ed: Idea - Preschool Capacity Building, Part B - Sec 619 2020-21 Embedded Instruction $9,504
10.649 Pandemic Electronic Benefit Transfer (ebt) Administrative Grant $5,814
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $4,527
10.574 Child Nutrition Team Nutrition Grants $3,893
94.014 Youth Service America Corporation $3,601
93.719 Arra - State Grants to Promote Health Information Technology $842
93.079 Youth Risk Behavior Survey Participation $500
16.839 Stop School Violence $421
93.575 Covid-19 Cares Act General Child Care and Development (cctr) $118