Finding Text
Federal Program Affected Program Name: COVID-19 Emergency Connectivity Fund Program Assistance Listing Number: 32.009 Pass-Through Entity: N/A ? Direct Award Federal Agency: Federal Communications Commission Criteria or Specific Requirements In accordance with Federal Communications Commission (FCC) Report and Order 21-58 paragraphs 116-118, COVID-19 Emergency Connectivity Fund (ECF) Program participants are required to maintain asset and service inventories of the devices and services purchased with ECF Program support. Asset inventories are required to contain the following elements: (a) device type, (b) device make/model, (c) equipment serial number, (d) the name of the person to whom the device was provided, and (e) the dates the device was loaned out and returned to the school. The asset inventory for devices not provided to individual students or school staff, but used to provide service to multiple eligible users must include the following information: (a) device type, (b) device make/model, (c) equipment serial number, (d) the name of the school or library employee responsible for that device, and (e) the dates the device was in service. Service records must include (a) type of service provided, (b) broadband plan details, including: upload and download speeds and monthly data cap, (c) the name(s) of the person(s) to whom the service was provided, and for fixed broadband service; (d) the service address, and (e) the installation date of service, and (f) the last date of service (as applicable). 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 asset or service inventories for Wi-Fi hotspots purchased using ECF support, as inventory records are not up-to-date and do not contain all of the aforementioned required elements. In addition, the District did not maintain adequate documentation to substantiate unmet need and per-user limitations. 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. Effect The District is not in compliance with the Equipment or Restricted Purpose Special Tests for the ECF Program. Questioned Costs Due to lack of records to substantiate the unmet need, which was the primary goal of the program, we identify the entire program reimbursement of $377,062 as questioned costs. Context The condition was identified through inquiries with District management and review of program records. 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 new federal programs.