Finding Text
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCE OF NONCOMPLIANCE ? FEDERAL COMMUNICATIONS COMMISSION, EMERGENCY CONNECTIVITY FUND PROGRAM ? FEDERAL ALN 32.009 2022-003 Internal Control Over Compliance and Noncompliance With Special Tests and Provisions Requirements Criteria ? 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. Condition ? During our audit, we noted that 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 had requested reimbursement for all 2,560 devices, however, 124 of those devices were never used or deployed, and thus not meeting the definition of eligible equipment for which the District could seek reimbursement. Questioned Costs ? $34,720. Context ? Of the 2,560 devices, 124 were not eligible to be reimbursed. At the time of our audit, the District did not have documentation of deployment or use for 124 devices to support the required unmet need. Repeat Finding ? This is a current year finding. Cause ? This was an oversight by district personnel, due to unfamiliarity with a new federal program. Effect ? Noncompliance with the special tests and provisions requirements could be viewed as a violation of the award agreement and result in loss of funds. Recommendation ? We recommend that the District review its internal control procedures relating to special tests and provisions for the Emergency Connectivity Fund Program. The District should review the compliance guidance issued by the Federal Communications Commission to familiarize itself with federal compliance requirements specific to the Emergency Connectivity Fund Program. View of Responsible Official and Planned Corrective Actions ? The District agrees with the finding. The District intends to review its procedures relating to special tests and provisions requirements to ensure compliance in the future with any additional federal awards. The District has separately issued a Corrective Action Plan related to this finding.