Finding 634882 (2022-002)

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE ? FEDERAL COMMUNICATIONS COMMISSION, EMERGENCY CONNECTIVITY FUND PROGRAM ? FEDERAL ALN 32.009 2022-002 Internal Control Over Compliance With Special Tests and Provisions Criteria ? 47 CFR ? 54.1711 requires that 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 its Emergency Connectivity Fund Program to assure compliance with federal special tests and provisions requirements. We noted that the District requested federal reimbursement for purchased technology devices prior to those devices being used or deployed, and thus not yet meeting the definition of eligible equipment for which the District could seek reimbursement. Questioned Costs ? None. Our testing did not indicate any instances of noncompliance with these requirements. All devices tested for which the District received reimbursement were deployed within the period of performance to individuals for which the District had documented an unmet need as approved in its funding applications. Context ? Of 25 devices tested, reimbursement was requested for 23 prior to the date at which the devices were being used or deployed to meet an unmet need. This was not a valid statistical sample. 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.