Finding Text
Criteria or Specific Requirements
In accordance with FCC Report and Order 21-58 paragraph 5, ECF Program support shall be used by schools to meet the otherwise unmet connectivity needs of students and school staff during the COVID-19 pandemic. In accordance with FCC Report and Order 21-58 paragraph 54, ECF Program support shall not be used to fund more than one connected device and more than one Wi-Fi hotspot per students or school staff member during the COVID-19 emergency period.
Condition
The District did not maintain adequate documentation to substantiate some of the unmet need and per-user limitations. Based on the available records, the District was able to substantiate unmet need for 144 computers (unit costs of $1,101.12).
Questioned Costs
Due to lack of records to substantiate the some unmet need, which was the primary goal of the program, we identify $75,425.84 as questioned costs out of the total reimbursement of $233,987.12 (devices only) as questioned costs.
(A)
Unmet Need
144
(B)
Per Unit Costs
$ 1,101.12
(C) = (A) x (B)
Calcualted Allowable Costs
$ 158,561.28
(D)
Amount Received
$ 233,987.12
(E) = (D) - (C)
Questioned Costs
$ 75,425.84
Context
The condition was identified through inquiries with District management and review of program records.
Effect
The District is not in compliance with the Restricted Purpose Special Tests for the ECF Program.
Cause
Due to the time-sensitive need to maintain connectivity for student learning, the District did not prioritize adequate record-keeping in accordance with program requirements.
Repeat Finding
No.
Recommendation
The District should ensure that program requirements are reviewed and adequate controls over compliance are in place prior to commencing program activities under federal programs.
Corrective Action Plan and Views of Responsible Officials
The IT Manager, prior to the filing of any E-Rate or ECF grant documents, have all entries approved by his supervisor. The IT Manager will also set a meeting to review any documentation related to any applications for funding prior to submitting an application to ensure the District is prepared to adequately meet all funding requirements.