Finding Text
50000-Federal ? Program Implementation (Noncompliance and Material Weakness in Internal Controls over Compliance) Federal Programs Affected 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 FCC Report and Order 21-58, paragraph 5, Emergency Connectivity Funds (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. Additionally, FCC Report and Order 21-58, paragraph 54 states that 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 As the District?s asset and service inventories were not complete and did not contain all required elements, a determination could not be made regarding the total number of students and staff members who were provided with assets or services purchased with ECF support. We were therefore unable to verify the District?s compliance with program requirements related to unmet connectivity needs and per-user limitations. Questioned Costs This finding represents a material weakness in internal control over federal compliance. However, there were no questioned costs associated with this finding as we did not identify any unallowable expenditures as a result of the finding. Context The condition was identified through inquiries with District management and review of program records. Effect The District is not in compliance with program requirements related to unmet connectivity needs 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. 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.