Finding Text
Federal Program Information:
Funding Agency: U.S. Department of Education
Title: Impact Aid
Federal Assistance Listing: 84.041
Passthrough: State of New Mexico Public Education Department
Award Year: 2023
Criteria: 20 U.S.C. Code 7703 – Payments for Eligible Federally Connected Children
(a)Computation of payment
(1)In general For the purpose of computing the amount that a local educational agency is eligible to receive under subsection (b) or
(d) for any fiscal year, the Secretary shall determine the number of children who were in average daily attendance in the schools
of such agency, and for whom such agency provided free public education, during the preceding school year and who, while in
attendance at such schools—
(A)
(i) resided on Federal property with a parent employed on Federal property situated in whole or in part within the
boundaries of the school district of such agency; or
(ii) resided on Federal property with a parent who is an official of, and accredited by, a foreign government and is a foreign
military officer;
(B) resided on Federal property and had a parent on active duty in the uniformed services (as defined in section 101 of title 37);
(C) resided on Indian lands;
Impact Aid Regulations
§ 222.35 How does a local educational agency count the membership of its federally connected children?
An applicant counts the membership of its federally connected children using one of the following methods:
(a) Parent-pupil survey. An applicant may conduct a parent-pupil survey to count the membership of its federally connected
children, which must be counted as of the survey date.
(b) Source check. A source check is a type of survey tool that groups children being claimed on the Impact Aid
application by Federal property. This form is used in lieu of the parent-pupil survey form to substantiate a pupil’s place of residence
or parent’s place of employment on the survey date.
(1) The source check must include sufficient information to determine the eligibility of the Federal property and the individual
children claimed on the form.
(2) A source check may also include:
(iv) Certification by the Bureau of Indian Affairs (BIA) or authorized tribal official regarding the eligibility of Indian lands.
Condition: The District did not have signed parent-pupil surveys for the survey date for the grant funds under audit. The District
also did not have a source check form with a listing of the students with a tribal official’s certification.
The District did have a source check form with nineteen students listed for the school year during the survey date, but there was no
certification by a tribal leader.
Questioned Costs: $493,534
The District had claimed 69 total students as children living on Federal land, four of which were children with disabilities. As none
of these students claimed have valid parent-pupil surveys or a valid source check, all student claimed on the application become
questioned costs. The District has received $493,534 from Impact Aid to date based upon this application under audit. Cause: The District had misunderstood the method of counting students for Impact Aid funding and the documentation required to
support this funding. The District had been counting students who had certificates of Indian blood no matter where they resided.
Effect: The District has been improperly claiming students who did not qualify for funding under the guidelines of Impact Aid.
Additionally, the District had not been obtaining the proper certification for those students who would qualify for funding under
Impact Aid. As such, funding which the District has been receiving under Impact Aid may be invalid, and the District may be
required to return those funds.
Auditor’s Recommendation: We recommend that the district put policies and procedures in place to properly identify students who
qualify under Impact Aid funding. After identification, we recommend that the District use the source check method to certify those
students as this requires obtaining one to three signatures, depending on the number of chapter’s who have students attending Jemez
Mountain Schools, rather than attempting to obtain the signature of each parent who’s children qualify because of where they live.
We also recommend that the District work to obtain as much certification as possible on the students who were part of this application
and any other applications which do not have parent-pupil surveys or source check certifications.
Responsable Official’s Plan:
Specific corrective action plan for finding:
The District will create policies and procedures to properly identify students.
Timeline for completion of corrective action plan:
December 2023
Employee position(s) responsible for meeting the timeline:
Federal Programs Director and Federal Programs Clerk
Schedule X