Finding Text
SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? FEDERAL COMMUNICATIONS COMMISSION ? COVID-19 ? EMERGENCY CONNECTIVITY FUND PROGRAM ? FEDERAL ALN 32.009 2022-001 Internal Control Over Compliance With Special Tests and Provisions Requirements Criteria ? 47 CFR ? 54.1711 requires that Independent School District No. 831 (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 the District did not have sufficient controls in place within is Emergency Connectivity Fund Program to assure compliance with federal special tests and provisions requirements. Questioned Costs ? No reportable instances of noncompliance. Context ? At the time of our audit, the District did not have documentation of deployment or use for 66 devices to support the required unmet need. This did not result in a reportable instance of noncompliance. 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.