Finding Text
Finding No.: 2022-010
Federal Agency: U.S. Department of Education (ED)
AL Program: 84.425 Education Stabilization Fund
ED Subprogram: 84.425A Education Stabilization Fund–State Educational Agency
(Outlying Areas) (ESF-SEA)
Federal Award No.: COVID-19 S425A210003
Area: Matching, Level of Effort, Earmarking
Questioned Costs: $0
Criteria:
In accordance with applicable matching, level of effort, earmarking requirements and section
18008 of the CARES Act, the State will maintain support for elementary and secondary education,
and State support for higher education, at least at the levels of such support that is the average of
such State’s support for elementary and secondary education and for higher education provided in
fiscal years 2017, 2018, and 2019. Such average is defined as the baseline.
Condition:
GDOE’s maintenance of effort for FY 2022 appears deficient, as follows:
Based on our reading of email communications from U.S. ED, Education Program Specialist,
Insular Areas, on August 9, 2023, we noted that GDOE’s Maintenance of Effort Data report is
under U.S. ED’s review. U.S. ED identified differences between levels of support reported by
GDOE and by Guam Office of the Governor. In GDOE’s report to U.S. ED, GDOE reported a
projected deficiency in MOE levels for FY 2022.
Cause:
GDOE did not enforce monitoring controls over compliance with applicable matching, level of
effort, earmarking requirements relative to maintenance of effort requirements.
Effect:
GDOE appears to be in noncompliance with applicable matching, level of effort, earmarking
requirements relative to maintenance of effort requirements. No questioned cost is reported
because GDOE is in the process of addressing differences identified by U.S. ED, and we are unable
to quantify the known deficiency.
Recommendation:
Responsible personnel should enforce monitoring controls over compliance with applicable
matching, level of effort, earmarking requirements relative to maintenance of effort requirements.
Prior to submitting the required Maintenance of Effort data report to U.S. ED, responsible
personnel should work in close liaison with Government of Guam and verify that the reported
amounts are consistent with the state’s overall levels.
Views of Responsible Officials:
The GDOE disagrees with the finding. GDOE does not meet the definition of a State, nor does
GDOE control the direct funding support (appropriations) for elementary and secondary education;
or higher education. GDOE can only provide its calculation based on the projected levels of
support (for elementary and secondary education) utilizing the formula guidance on MOE
calculations issued by USEd. The calculation is based on appropriation levels provided by the
Guam Legislature. Additionally, the figures calculated for FY22 are preliminary until the audited
financials are provided for final submission of MOE data. Preliminarily, GDOE calculated the OA
maintenance of effort to fall short by less than 1%.
Auditor Response:
We acknowledge that audited financial data from the Government of Guam is not available to
derive an exact amount; however, there appears to be general agreement that GDOE’s estimated
MOE for FY 2022 falls short of the required level.