SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? FEDERAL COMMUNICATIONS COMMISSION, EMERGENCY CONNECTIVITY FUND PROGRAM ? FEDERAL ALN 32.009 2022-002 Internal Control Over Compliance With Special Tests and Provisions Finding Summary 47 CFR ? 54.1711 requires that the District only seek support for eligible equipment provided to students and school staff who would otherwise lack connected devices sufficient to engage in remote learning. During our audit, we noted the District did not have sufficient controls in place within its Emergency Connectivity Fund Program to assure compliance with federal special tests and provisions requirements. We noted that the District requested federal reimbursement for purchased technology devices prior to those devices being used or deployed, and thus not yet meeting the definition of eligible equipment for which the District could seek reimbursement. Corrective Action Plan Actions Planned ? The finding resulted from a timing issue caused by unfamiliarity with a new federal program. The District subsequently deployed all devices for which it was reimbursed to students in accordance with the unmet needs defined and approved in its award applications. The District understands the applicable guidance and will ensure that future reimbursement requests under the Emergency Connectivity Fund Program will not be made until after the equipment has been placed in service. Official Responsible ? Director of Finance and Operations, Christopher Kampa. Planned Completion Date ? March 31, 2023. Disagreement With or Explanation of Finding ? The District is in agreement with this finding. Plan to Monitor ? The District?s Director of Finance and Operations, Christopher Kampa, will assure appropriate internal controls are in place to verify future compliance with special tests and provisions requirements for the Emergency Connectivity Fund Program.