Finding 634906 (2022-003)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2023-02-21

AI Summary

  • Core Issue: The District lacked adequate controls over the Emergency Connectivity Fund Program, leading to reimbursement requests for ineligible devices.
  • Impacted Requirements: Noncompliance with 47 CFR § 54.1711, which mandates support only for eligible equipment used by students and staff.
  • Recommended Follow-Up: The District should enhance internal controls and review compliance guidance to prevent future noncompliance and potential loss of funds.

Finding Text

SIGNIFICANT DEFICIENCY IN INTERNAL CONTROL OVER COMPLIANCE AND REPORTABLE INSTANCE OF NONCOMPLIANCE ? FEDERAL COMMUNICATIONS COMMISSION, EMERGENCY CONNECTIVITY FUND PROGRAM ? FEDERAL ALN 32.009 2022-003 Internal Control Over Compliance and Noncompliance With Special Tests and Provisions Requirements 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 that 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 had requested reimbursement for all 2,560 devices, however, 124 of those devices were never used or deployed, and thus not meeting the definition of eligible equipment for which the District could seek reimbursement. Questioned Costs ? $34,720. Context ? Of the 2,560 devices, 124 were not eligible to be reimbursed. At the time of our audit, the District did not have documentation of deployment or use for 124 devices to support the required unmet need. 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.

Categories

Questioned Costs Internal Control / Segregation of Duties Special Tests & Provisions Cash Management Significant Deficiency Equipment & Real Property Management

Other Findings in this Audit

  • 58463 2022-002
    Significant Deficiency
  • 58464 2022-003
    Significant Deficiency
  • 634905 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $8.71M
10.553 School Breakfast Program $1.67M
32.009 Emergency Connectivity Fund Program $751,843
21.027 Coronavirus State and Local Fiscal Recovery Funds $650,022
84.010 Title I Grants to Local Educational Agencies $470,310
93.575 Child Care and Development Block Grant $245,200
84.181 Special Education-Grants for Infants and Families $240,210
10.559 Summer Food Service Program for Children $230,965
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $221,589
84.367 Supporting Effective Instruction State Grants $211,312
84.027 Special Education_grants to States $189,847
84.365 English Language Acquisition State Grants $94,562
84.002 Adult Education - Basic Grants to States $70,088
84.424 Student Support and Academic Enrichment Program $40,261
84.048 Career and Technical Education -- Basic Grants to States $37,146
84.060 Indian Education_grants to Local Educational Agencies $24,793
84.173 Special Education_preschool Grants $19,467
84.425 Education Stabilization Fund $12,443
84.196 Education for Homeless Children and Youth $2,631