Finding Text
2022-004 Unmet Need Emergency Connectivity Fund (ECF) Program, Assistance Listing #32.009 Compliance Requirement: Special Tests ? Unmet Need Material Weakness in Internal Control over Compliance Criteria: To ensure that funding is focused on unmet need, the Commission requires schools, library, and consortia to certify, as part of their funding application, that they are only seeking support for eligible equipment and/or broadband provided to students and school staff who would otherwise lack access to connected devices and/or broadband connectivity sufficient to engage in remote learning. At the application stage, school need only provide the best estimates of their unmet need. They may use whatever method they deem appropriate for estimating unmet need and are not required to provide any documentation to support these estimates when they submit their ECF FCC Form 471 application. When schools file for requests for reimbursement, however, they should only request reimbursement for eligible equipment and services provided to students or school staff who would otherwise lack broadband services and/or devices sufficient to engage in remote learning. For example, if a school requested ECF funding to support the broadband services at the homes of 100 students based on an estimate of those that lacked services, but it determines during the school year that only 90 students have unmet need, the school should only seek reimbursement for the services provided to those 90 students. Schools may also be asked to provide documentation to support actual costs of assigned equipment and/or services after funds have been committed). Condition: During the fiscal year ended June 30, 2022, it does not appear that the District had a control in place to monitor unmet need and to ensure that the federal reimbursement was for students or staff who have an unmet need for the devices reimbursed by the federal program. Cause: The District does not appear to have a consistent process in place to validate unmet need requirements of the District for purposes of this federal program. Effect: The District could be out of compliance with federal requirements by receiving a reimbursement of federal funds for ECF devices and other services that were not provided to students or staff with unmet needs. Context/Sampling: While the District does monitor if there is an unmet need when providing devices, they do not have an established control to ensure there is an unmet need before reimbursement is requested, and therefore, no control testing could be performed on a sample of items. Repeat Finding From Prior Year: No Questioned costs: None reported. Recommendation: Control procedures should be implemented to ensure that devices/services are provided to students and staff with unmet needs (i.e. application for checkout with identifying reason for the need). Views of Responsible Officials: The Technology Services team did determine the unmet need for the devices utilizing a parent survey but did not have additional documentation to support that a control was in place to ensure unmet need before requesting reimbursement. We will ensure we have documentation that the unmet need still exists with any future requests for federal reimbursement.