Washington's Oversight of ARP Esser Plans and Spending

Summary

Final audit report ED-OIG/A22US0094 of the U.S. Department of Education Office of Inspector General, dated September 20, 2023, titled Washington's Oversight of Local Educational Agency ARP ESSER Plans and Spending. A cover letter to State Superintendent Chris Reykdal is signed /s/ by Daniel Schultz, Director of Pandemic Relief Audits. The audit covered March 24, 2021, through October 31, 2022, and states that Washington did not have an adequate review and approval process to ensure that LEA ARP ESSER plans met all applicable requirements. It also states that Washington's reimbursement process did not include collecting or reviewing any expenditure-supporting documentation. Washington neither agreed nor disagreed with the findings but agreed with the recommendations.

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U.S. Department of Education
Office of Inspector General
Washington’s Oversight of Local
Educational Agency ARP ESSER
Plans and Spending
September 20, 2023
ED-OIG/A22US0094

ED OIG Oversight of Coronavirus Response Funds

NOTICE
Statements that managerial practices need improvements, as well as other conclusions
and recommendations in this report, represent the opinions of the Office of Inspector
General. The appropriate Department of Education officials will determine what
corrective actions should be taken.
In accordance with Freedom of Information Act (Title 5, United States Code,
Section 552), reports that the Office of Inspector General issues are available to
members of the press and general public to the extent information they contain is not
subject to exemptions in the Act.

UNITED STATES DEPARTMENT OF EDUCATION
OFFICE OF INSPECTOR GENERAL

Audit Services

400 MARYLAND AVENUE, S.W., WASHINGTON, DC 20202-1510
Promoting the efficiency, effectiveness, and integrity of the Department’s programs and operations.
September 20, 2023
Mr. Chris Reykdal
State Superintendent
Washington Office of Superintendent of Public Instruction
Old Capitol Building
600 Washington Street, S.E.
Olympia, WA 98504
Dear Mr. Reykdal:

Enclosed is our final report, “Washington’s Oversight of Local Educational Agency ARP ESSER Plans and
Spending,” Control Number ED-OIG/A22US0094. This report incorporates the comments you provided in
response to the draft report. The U.S. Department of Education’s policy is to expedite resolution by
timely acting on findings and recommendations. Therefore, if you have any additional comments or
information that you believe may have a bearing on the resolution of this audit, you should send them
directly to the following Department of Education official, who will consider them before taking final
Departmental action on this audit:
Adam Schott
Deputy Assistant Secretary for Policy and Programs
Delegated the Authority to Perform the Functions and Duties of the Assistant Secretary
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202
We appreciate your cooperation during this review. If you have any questions, please contact me at
(202) 262-1046 or Daniel.P.Schultz@ed.gov.
Sincerely,
Daniel Schultz /s/
Director of Pandemic Relief Audits
Enclosure

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Table of Contents
Results in Brief .................................................................................................................... 5
Introduction ........................................................................................................................ 8
Finding 1. Washington’s LEA ARP ESSER Plan Review and Approval Process Did Not
Ensure that Plans Met All Applicable Requirements ........................................................ 15
Finding 2. Washington’s Monitoring of LEAs’ Use of ARP ESSER Funds Could Be
Strengthened .................................................................................................................... 22
Appendix A. Scope and Methodology............................................................................... 29
Appendix B. Allowable Use of Funds ................................................................................ 33
Appendix C. Acronyms and Abbreviations ........................................................................ 36
Washington’s Comments .................................................................................................. 37

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Results in Brief
What We Did
The objectives of the audit were to determine whether the Washington Office of
Superintendent of Public Instruction (Washington) had an adequate oversight process in
place to ensure that (1) local educational agencies’ (LEA) American Rescue Plan (ARP)
Elementary and Secondary School Emergency Relief (ESSER) plans met applicable
requirements and (2) LEAs use ARP ESSER funds in accordance with applicable
requirements and their approved LEA ARP ESSER plans. Our audit covered March 24,
2021, through October 31, 2022.
For the first objective, we gained an understanding of Washington’s process for
reviewing and approving LEAs’ ARP ESSER plans, which consisted of both their Academic
and Student Well-Being Recovery Plan (Academic Plan) and their grant application. To
perform this work, we (1) reviewed the guidance and technical assistance that
Washington provided to LEAs on developing and submitting their ARP ESSER plans,
(2) reviewed Washington’s processes for reviewing and approving LEAs’ ARP ESSER
plans, (3) determined if Washington allocated funds and paid any ARP ESSER
reimbursement claims to LEAs without approved plans, and (4) reviewed the
completeness of ARP ESSER plans of two LEAs, Granger School District (Granger) and
Seattle Public Schools (Seattle).
For the second objective, we gained an understanding of Washington’s oversight of
LEAs’ use of ARP ESSER funds. To perform this work, we (1) reviewed the guidance and
technical assistance that Washington provided to LEAs on allowable uses of funds,
(2) reviewed Washington’s processes for monitoring LEAs’ uses of funds and annual
Consolidated Program Review (CPR) of selected LEAs, (3) tested the allowability of a
sample of 26 ARP ESSER expenditures at 2 LEAs, and (4) reviewed LEAs’ adherence to
applicable procurement requirements for the sample of 26 expenditures at 2 LEAs.
What We Found
Washington did not have an adequate review and approval process to ensure that LEA
ARP ESSER plans met all applicable requirements. As a result, the public did not have
sufficient insight into how the LEAs planned to spend ARP ESSER funds. Washington was
required to ensure that LEAs submitted ARP ESSER plans that were complete and timely;
however, we found that Washington did not ensure LEAs’ compliance with all Federal
requirements and guidance for creating transparent and understandable plans. During
the audit, Washington was responsive to the issues we identified and initiated
corrective action to ensure that Federal requirements and guidance were met.

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Washington could also strengthen its monitoring of LEAs to provide additional assurance
that LEAs used ARP ESSER funds for allowable purposes and followed applicable
regulations. The ARP ESSER program was considered a higher risk program for 2022
according to 2 Code of Federal Regulations (C.F.R.) section 200.519(c)(2) and identified
as such in the Office of Management and Budget’s 2 C.F.R. Part 200, Appendix XI,
Compliance Supplement (April 2022). The Pandemic Response Accountability
Committee, located within the Council of the Inspectors General on Integrity and
Efficiency, stated that the unprecedented amount of money made available for
pandemic relief and quick distribution of most funds put the money at a higher risk for
fraud. Washington used its iGrants system to approve LEA ARP ESSER grant applications
and reimburse LEAs for ARP ESSER expenditures; however, the reimbursement process
did not include collecting or reviewing any expenditure-supporting documentation, even
on a sample basis. Washington relied on its CPR process to review selected LEA
expenditures for compliance with Federal education program requirements; however,
Washington did not modify its CPR process to take into consideration the higher risk
associated with ARP ESSER expenditures to ensure selection of APR ESSER expenditures.
We identified issues related to procurement for just 1 of the 26 expenditures that we
reviewed at 2 LEAs, but Washington nevertheless may not have sufficient assurance that
ARP ESSER expenditures were allowable given the issues noted with its reimbursement
and CPR process.
What We Recommend
We recommend that the Assistant Secretary for the Office of Elementary and Secondary
Education ensure that Washington has taken appropriate corrective actions for LEAs
with approved ARP ESSER plans so that these plans meet all applicable requirements.
We also recommend that Washington be required to fully document its review and
approval of ARP ESSER plans for LEAs that have not yet submitted their plans, once they
have been submitted, to ensure that they comply with all program requirements.
Additionally, we recommend that the Assistant Secretary for the Office of Elementary
and Secondary Education require Washington to develop and implement, for both the
reimbursement and monitoring processes, protocols to sample LEA expenditures
charged to ARP ESSER, and to review supporting documentation, including procurement
process documentation, to ensure that applicable Federal, State, and local requirements
are met.
Washington’s Comments and Our Response
We provided a draft of this report to Washington for comment. Washington neither
agreed nor disagreed with the findings but agreed with the recommendations.
Washington described actions it has taken or plans to take in response to

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recommendation 1.1 and recommendation 2.1. Washington’s comments were not fully
responsive to recommendation 1.2. Specifically, Washington’s comments did not
address LEAs’ timely submission of their ARP ESSER plans and its documentation of the
review and approval of these plans. Washington’s described actions for
recommendation 1.1 and recommendation 2.1 are responsive if implemented as
described. Washington also requested updates to the report related to the number of
State-Tribal education compact schools and its monitoring of educational service
districts, as well as other revisions to provide more contextual information. In addition,
the Department provided technical comments. We revised the report with the updated
information provided by Washington and made clarifying edits in response to the
Department’s comments. The full text of Washington comments is included as an
appendix (see Washington’s Comments).

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Introduction
Background
On March 13, 2020, the President declared a national emergency due to the coronavirus
pandemic. In response, Congress passed three coronavirus pandemic relief acts within a
1-year period that provided about $275 billion for an Education Stabilization Fund to
prevent, prepare for, and respond to the coronavirus, including $189.5 billion for the
Elementary and Secondary School Emergency Relief (ESSER) funds.
•
The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), enacted on
March 27, 2020 (Public Law 116-136), provided about $13.2 billion in ESSER
funds to address the impact that the coronavirus pandemic had and continues
to have on elementary and secondary schools.
•
The Coronavirus Response and Relief Supplemental Appropriations Act
(CRRSAA) was signed into law on December 27, 2020 (Public Law 116-260),
authorizing an additional $54.3 billion in supplemental ESSER funds to help
States and school districts safely reopen schools, measure, and effectively
address significant learning loss, and take other actions to mitigate the impact
of the coronavirus pandemic on the students and families who depend on
elementary and secondary schools.
•
The American Rescue Plan (ARP) was signed into law on March 11, 2021 (Public
Law 117-2), authorizing $122 billion in ARP ESSER funds to help State
educational agencies (SEA) and local educational agencies (LEA) safely reopen
and sustain the safe operation of schools and address the impact of the
coronavirus pandemic on students.
ARP ESSER Funds
On March 24, 2021, the U.S. Department of Education (Department) awarded about
$81 billion of ARP ESSER funds to SEAs, approximately two-thirds of each SEA’s total
allocation. To receive its remaining funds, each SEA was required to submit a plan to the
Office of Elementary and Secondary Education (OESE) for approval that explained how
the SEA would use ARP ESSER funds to safely reopen schools; support sustained access
to in-person instruction; and to address the academic, social, emotional, and mental
health needs of students. By December 2021, the Department had approved all SEA
plans and awarded the remaining $41 billion in ARP ESSER funds to SEAs. The
Washington SEA plan was submitted in June 2021 and was approved by the Department
in November 2021.

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State Educational Agency Reserve
Under ARP, SEAs were allowed to reserve up to 10 percent of their total ARP ESSER
allocation for use by the SEA. Section 2001(f) of the ARP required the SEA to set aside
funds for certain activities and interventions that respond to students’ academic, social,
and emotional needs and to address the disproportionate impact of the coronavirus
pandemic on student subgroups, with Department guidance emphasizing that SEAs
should focus their efforts on underserved student subgroups in particular. Specifically,
from the State’s total ARP ESSER allocation, the SEA was required to spend at least
•
five percent for the implementation of evidence-based interventions aimed
specifically at addressing learning loss, such as summer learning or summer
enrichment, extended day, comprehensive afterschool programs, or extended
school year programs;
•
one percent for evidence-based summer enrichment programs; and
•
one percent for evidence-based comprehensive afterschool programs.
Additionally, an SEA may use up to one-half of 1 percent of its total ARP ESSER allocation
for administrative costs and up to 2.5 percent of its total ARP ESSER allocation for
emergency needs as determined by the State to address issues related to the
coronavirus pandemic.
Subgrants to Local Educational Agencies
ARP section 2001(d)(1) required the SEA to allocate not less than 90 percent of its total
ARP ESSER allocation to LEAs in the State (including charter schools that are LEAs) to
help meet a wide range of needs arising from the coronavirus pandemic, including
reopening schools safely; sustaining their safe operation; and addressing students’
social, emotional, mental health, and academic needs resulting from the coronavirus
pandemic. SEAs were required to allocate ARP ESSER funds to LEAs based on their
respective shares of funds received under Title I, Part A of the ESEA in fiscal year
(FY) 2020. Additionally, SEAs were required to allocate ARP ESSER funds to LEAs in an
expedited and timely manner and, to the extent practicable, not later than 60 days after
receiving their ARP ESSER funds.
Local Educational Agencies’ ARP ESSER Plans
The interim final requirements (IFR) for the ARP ESSER funds, effective April 22, 2021,
require each LEA receiving ARP ESSER funds to develop and submit to the SEA a plan for

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its use of ARP ESSER funds (86 Federal Register (FR) 21198-99).1 The LEA must submit
the plan in accordance with procedures and by the deadline established by the SEA2 and
make the plan publicly available on the LEA’s website. At a minimum, the LEA ARP ESSER
plan must describe
1. the extent to which and how the funds will be used to implement prevention
and mitigation strategies that are, to the greatest extent practicable, consistent
with the most recent Center for Disease Control and Prevention (CDC) guidance
on reopening schools, in order to continuously and safely open and operate
schools for in-person learning;
2. how the LEA will use the funds it reserves under section 2001(e)(1) of the ARP to
address the academic impact of lost instructional time through the
implementation of evidence-based interventions, such as summer learning or
summer enrichment, extended day, comprehensive afterschool programs, or
extended school year;
3. how the LEA will spend its remaining ARP ESSER funds consistent with section
2001(e)(2) of the ARP; and
4. how the LEA will ensure that the interventions it implements, including but not
limited to the interventions implemented under section 2001(e)(1) of the ARP to
address the academic impact of lost instructional time, will respond to the
academic, social, emotional, and mental health needs of all students,
particularly those students that are disproportionately impacted by the
coronavirus pandemic, including students from low-income families, students of
color, English learners, children with disabilities, students experiencing
homelessness, children in foster care, and migratory students.
In developing its plan, an LEA was required to engage in meaningful consultation with
stakeholders including students; families; school and district administrators (including
special education administrators); and teachers, principals, school leaders, other
educators, school staff, and their unions. The LEA was also required to engage in
meaningful consultation with each of the following to the extent present in or served by
the LEA: Tribes; civil rights organizations (including disability rights organizations); and

1 Under the ARP, and as reiterated in the IFR, each LEA was required to submit a Safe Return to In-
Person Instruction and Continuity of Services Plan. Under the IFR, each LEA was also required to submit
a plan for its use of ARP ESSER funds. For this audit, we limited our review to LEAs’ use of funds plans.
2 The SEA must establish a deadline for an LEA to submit its plan that is reasonable and should be no
more than 90 days after receiving its ARP ESSER allocation, per 86 FR 21199.

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stakeholders representing the interests of children with disabilities, English learners,
children experiencing homelessness, children and youth in foster care, migratory
students, children who are incarcerated, and other underserved students.
Additionally, the LEA had to provide the public the opportunity to provide input on the
development of the plan and take such input into account. The IFR also mandates that
LEA ARP ESSER plans be accessible on the LEA websites, including to parents with
limited English proficiency and individuals with a disability. This requirement is intended
to help ensure that all parents can access and understand the information in an LEA’s
ARP ESSER plan, consistent with the Department’s interpretation of Title VI of the Civil
Rights Act of 1964 and existing obligations to parents with disabilities under the
Americans with Disabilities Act.
Local Educational Agencies’ Use of ARP ESSER Funds
Section 2001(e)(1) of the ARP requires LEAs to reserve at least 20 percent of their ARP
ESSER funds to address the academic impact of lost instructional time, also known as
learning loss, through the implementation of evidence-based interventions, for example
by providing intensive or high-dosage tutoring or accelerating learning. LEAs must
ensure that these interventions respond to students’ academic, social, and emotional
needs and address the disproportionate impact of the coronavirus pandemic on
underrepresented student subgroups.
LEAs may use the remaining 80 percent of their ARP ESSER funds for a broad range of
activities, including any activities allowed under the ESEA, the Individuals with
Disabilities Education Act, the Strengthening Career and Technical Education for the
21st Century Act, and the Adult Education and Family Literacy Act.
For example, LEAs may use ARP ESSER funds to
•
implement COVID-19 prevention strategies to safely reopen schools and
maximize in-person instruction and align with public health guidance, including
upgrading school facilities for healthy learning environments;
•
address the mental health needs of students, including using funds to hire
counselors and other staff;
•
provide integrated student support services, including by using full-service
community schools and assisting homeless children and youth in attending and
participating in school activities;
•
provide students with evidence-based summer learning and enrichment
programs, including through partnerships with community-based organizations;
•
connect K–12 students to high-quality home internet and devices; and

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•
stabilize and diversify the educator workforce.
LEAs can also use ARP ESSER funds for any activity deemed allowable under section
18003(d) of the CARES Act and section 313(d) of CRRSAA. See Appendix B for a summary
of allowable uses of ESSER funds under the CARES Act, CRRSAA, and ARP.
Maintenance of Equity
Section 2004(b) and (c) of the ARP includes new fiscal equity requirements that are a
condition for SEAs and LEAs receiving ARP ESSER funds, called maintenance of equity
(MOEquity). MOEquity provisions help ensure that schools and LEAs serving large
proportions of historically underserved groups of students receive an equitable share of
State and local funds. MOEquity requirements ensure that in FYs 2022 and 2023
1. an SEA does not disproportionately reduce per-pupil State funding to high-need
LEAs,
2. an SEA does not reduce per-pupil State funding to the highest-poverty LEAs
below their FY 2019 level,
3. an LEA does not disproportionately reduce State and local per-pupil funding in
high-poverty schools,3 and
4. an LEA does not disproportionately reduce the number of full-time-equivalent
staff per-pupil in high-poverty schools.
According to the Department’s Frequently Asked Questions on ARP ESSER MOEquity
Requirements (dated July 26, 2022), MOEquity exceptions for LEAs may be granted by
the SEA or Department for various reasons. Under section 2004(c)(2) of the ARP, an LEA
does not need to maintain equity if the LEA meets one or more of the following criteria:
•
has a total enrollment of less than 1,000 students;
•
operates a single school;
•
serves all students within each grade span with a single school; or
•
demonstrates an exceptional or uncontrollable circumstance, such as
unpredictable changes in student enrollment or a precipitous decline in the
financial resources of the LEA, as determined by the Department.

3 According to the ARP, a high-poverty school is, with respect to a school served by an LEA, a school that
is in the highest quartile of schools served by the LEA based on the percentage of economically
disadvantaged students in the school.

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Additionally, the Department determined that timing and implementation challenges
due to the pandemic (specifically related to LEA budgeting) are examples of exceptional
or uncontrollable circumstances that justify a limited exception to the local MOEquity
requirements for FYs 2022 and 2023. An LEA experiencing these circumstances may
demonstrate that it is excepted from the requirements for a given year by certifying to
the SEA that it will not implement an aggregate reduction in combined State and local
per-pupil funding in that year.
According to the final requirements for the ARP ESSER Fund, effective July 8, 2022, each
State must publish the names of the LEAs that are excepted under each exception
category (87 FR 34790). Each State must determine the most appropriate way to publish
and list this information so that parents, families, and the general public in the State will
be able to access and understand the information.
Washington Office of Superintendent of Public Instruction
The Washington Office of Superintendent of Public Instruction (Washington) is charged
with overseeing public K–12 education in the State. Washington has 295 school districts,
7 State-Tribal education compact schools, and 12 additional jurisdictions, including
educational service districts. Washington’s total ARP ESSER allocation is $1.85 billion. As
of October 31, 2022, the end of our audit period, Washington had drawn down
$592 million (32 percent) of its total ARP ESSER allocation. As a part of this audit, we
selected two Washington LEAs for review, Granger School District (Granger) and Seattle
Public Schools (Seattle).
Granger School District
Granger was allocated approximately $6.4 million in ARP ESSER funds. In its approved
ARP ESSER plan, Granger stated that it planned to use its 20 percent learning loss
reserve ($1.3 million) for extended summer school services and tutoring; and the
remainder of its funds for school facility repairs and improvements, improving indoor air
quality, educational technology, student assessments and other tools to address
learning loss, training and supplies to minimize the spread of infectious disease, and
purchases to allow all students equal access to education. Granger officials stated that
the school district consists of three schools: an elementary, middle, and high school. The
total district population is about 1,500 students.

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Seattle Public Schools
Seattle was allocated approximately $93 million in ARP ESSER funds. In its approved ARP
ESSER plan, Seattle stated that it planned to use its 20 percent learning loss reserve
($19 million) for special education and a virtual learning academy; and the remainder of
its funds for transportation, school facility repairs and improvements, special education,
mental health, and activities to address learning loss. The school district consists of
104 schools from preschool to 12th grade. The total district population is about
50,050 students.

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Finding 1. Washington’s LEA ARP ESSER Plan
Review and Approval Process Did Not Ensure
that Plans Met All Applicable Requirements
Washington did not have an adequate review and approval process to ensure that LEA
ARP ESSER plans timely met all applicable requirements. Washington’s oversight
activities included providing guidance and technical assistance to LEAs on the
development of ARP ESSER plans and performing reviews of LEA ARP ESSER plans using
standardized checklists as part of its approval process. Washington was required to
ensure that LEAs submitted ARP ESSER plans that were complete and timely; however,
we found that Washington did not ensure LEAs’ compliance with all Federal
requirements and guidance for creating transparent and understandable plans within a
reasonable time, with the Department noting in its IFR and State plan template that this
should occur no later than 90 days after an LEA receives its ARP ESSER allocation. This
occurred because Washington officials prioritized implementing State Legislative
requirements, issued shortly before Federal requirements, when developing its
guidance for LEAs and its processes for reviewing and approving LEA ARP ESSER plans.
As a result, the public did not have sufficient insight into how the LEAs planned to spend
ARP ESSER funds. Specifically, 20 LEAs did not submit ARP ESSER plans timely and 2 LEAs
were reimbursed for ARP ESSER expenditures without a complete ARP ESSER plan.
During the audit, Washington was responsive to the issues we identified and initiated
corrective action to ensure that Federal requirements were met.
Guidance and Technical Assistance Provided to LEAs
Washington provided guidance and technical assistance to its LEAs on authorized uses
of Federal coronavirus pandemic funding and how to develop and submit their LEA ARP
ESSER plans through planning guides, emails, webinars, website postings, and phone
calls. On April 19, 2021, Washington released a planning guide to LEAs in response to
the passage of a Washington State law4 (on February 1, 2021) and ARP (on March 11,
2021). The planning guide was issued 3 days before the Department published its IFR for
LEA ARP ESSER plans. The IFR required LEAs to describe in their LEA ARP ESSER plans the
extent to which and how ARP ESSER funds would be used for authorized activities and
post them publicly. The planning guide did not direct LEAs to describe the extent to
which and how ARP ESSER funds, specifically, would be used for authorized activities

4 Washington State Legislature House Bill 1368 required LEAs to submit an Academic and Student Well-
Being Plan to the superintendent of public instruction to address student needs that were anticipated
due to school closures and extended time in remote learning mode due to the coronavirus pandemic.

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since that was not required by State law. Instead, the guide directed LEAs to complete a
survey template that asked questions about addressing student needs, called the
Academic and Student Well-being Recovery Plan (Academic Plan). LEAs were required to
submit their Academic Plan to Washington by June 1, 2021, after receiving approval
from their school boards and posting the Academic Plan on their websites. The planning
guide referred to a three-phase approach that included LEAs reviewing and updating
their plans in the last two phases. However, Washington officials told us that if LEAs did
update their plans, Washington was not involved in reviewing and approving any
updates.
Washington followed its existing grants administration process and next instructed LEAs
to prepare separate grant applications for both the 20 percent ARP ESSER learning loss
reserve and the remaining 80 percent of their ARP ESSER funds. The applications were
made available to LEAs on June 15, 2021, and July 1, 2021, respectively. Each application
was to include a description of the extent to which and how ARP ESSER funds would be
used for authorized activities. LEAs were required to present the applications to their
school boards to be voted on at a public meeting. Upon receiving school board approval,
LEAs were to submit the grant applications to Washington for review and approval
before spending funds but no later than August 31, 2024. Washington did not instruct
LEAs to post their grant applications publicly or submit them within a reasonable time,
that should have been no later than 90 days after they received their allocation, even
though doing so was necessary to meet Federal requirements and guidance.
Based on a review of documents and other information provided by Washington, we
determined that each LEA’s Academic Plan, along with its grant applications,
represented its ARP ESSER plan as these documents, collectively, included the required
information. We found that Washington provided LEAs with guidance and technical
assistance on authorized uses of Federal coronavirus pandemic funding. However,
Washington’s guidance to LEAs did not include the Federal requirements and guidance
to develop and submit an LEA ARP ESSER plan within a reasonable time (but no later
than 90 days after they received their allocation) and to post the plan on their website.
During the audit, Washington initiated corrective action in response to the issues we
identified to ensure that Federal requirements were met.
Washington’s Review and Approval of LEA ARP ESSER Plans
Washington had two review processes for the LEA Academic Plan and grant application.
Each process included reviewers using a tracking spreadsheet to record the review and
approval of each LEA’s ARP ESSER plan. For the Academic Plan, a team of six reviewers
inputted information into a tracking spreadsheet, with each Academic Plan being
assigned to one individual to review. The spreadsheet included details on each LEA’s
Academic Plan submission including a review for completeness, the existence of school

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board approval, and confirmation of posting to the LEA’s website. However, the
spreadsheet was incomplete and not up to date. For example, it was missing listings for
LEAs that received an ARP ESSER allocation. A Washington official stated that it had not
been updated. An official said that a small number of LEAs required clarification from
Washington or had an incomplete question on their plan. An official stated that
reviewers provided technical assistance to the LEAs by phone or email. Academic Plans
were eventually submitted by all LEAs and approved by Washington during the course of
our audit. For the grant applications, one person who reviewed all applications
maintained a tracking spreadsheet to record that they also received school board
approval and that funds were being requested only for ARP ESSER-approved activities.
However, the spreadsheet did not track all LEA grant application submission details,
such as confirmation of public posting to the LEA’s website and submission within a
reasonable time, but no more than 90 days after the LEA received its ARP ESSER
allocations. The reviewer would request a supervisor to perform a secondary review and
also ask the LEA for more information on how an expenditure was linked to the
pandemic when they received an application for a questionable expense. The reviewer
stated that 10 to 15 percent of applications were not initially approved for two
reasons—first, if the application lacked enough detail in the description of planned uses
of funds and second, if the application did not comply with a requirement surrounding
an apportionment for learning loss, as described above. Ultimately, all grant applications
were approved after Washington provided technical assistance to each LEA.
Washington used its existing iGrants system for administering the ARP ESSER grant
funds to LEAs. In July 2021, after the State of Washington Legislature approved the State
to spend the ARP ESSER funds, Washington allocated ARP ESSER subgrants to the LEAs
based on each LEA’s share of funds received under Part A of Title I of the ESEA.
Washington provided LEAs with separate allocations for the 20 percent of funds
reserved for addressing the academic impact of lost instructional time and for the
remaining 80 percent of funds. As described above, Washington required LEAs to submit
through the iGrants system a grant application with narratives explaining how they
planned to spend their ARP ESSER funds and a budget. This was to be done before they
were able to spend funds, but no later than August 31, 2024. To receive reimbursement
for funds, the LEA must have an approved grant application in the iGrants system.
The approved ARP ESSER grant budget was exported into the iGrants system, and the
expenditures were assigned to the appropriate budget code. Once this was completed,
LEAs could begin to request reimbursement of ARP ESSER funds. LEAs can submit a
claim against the approved budgets monthly.

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Washington’s Processes Did Not Ensure Public Access to Full
ARP ESSER Plans
Washington’s processes for reviewing and approving LEAs’ ARP ESSER plans did not
ensure that all Federal requirements were met. For example, we found that two LEAs
did not submit complete ARP ESSER plans to Washington for approval. The two LEAs
were missing a part of their ARP ESSER plan, the Academic Plan, despite Washington
already approving and reimbursing their ARP ESSER expenditures totaling about
$54,000. Washington instructed LEAs to submit Academic Plans by June 1, 2021;
however, the two LEAs did not submit Academic Plans until January 2023, after we
notified Washington of this issue.
In addition, Washington did not ensure that LEAs publicly posted their entire ARP ESSER
plans to their websites, which, as noted above, comprised both the Academic Plan and
the grant application as is necessary to comply with the IFR. We found that LEAs only
posted the Academic Plan5 component of their ARP ESSER plans to their websites.
However, the Academic Plan did not require LEAs to include a description of the extent
to which and how ARP ESSER funds, specifically, would be spent on authorized activities,
one of the Federal requirements. Instead, Washington met this requirement by
requiring each LEA to submit a school board-approved grant application describing its
planned uses of ARP ESSER funds. However, we found that Washington did not require
LEAs to post these grant applications online, as required by Federal requirements. Upon
our notifying Washington of this oversight in January 2023, Washington sent an email to
LEAs requiring them to post their grant applications online. We then verified that
Seattle, Granger, and an additional eight randomly selected LEAs corrected the issue by
posting the complete plans to their websites.
Lastly, Washington did not ensure that LEAs submitted grant applications within a
reasonable time, which the Department noted in its IFR should be no later than 90 days
after an LEA receives its ARP ESSER allocation. Washington allocated the ARP ESSER
funds to LEAs in July 2021. We found that six LEAs did not submit grant applications
within 90 days of receiving their allocation, and one of the six still had not submitted its
grant application at the time of our analysis 17 months later.6 In addition, Washington
officials identified another 14 LEAs that had not yet submitted grant applications.

5 The Academic Plan was a survey completed by LEAs that had four questions that pertained to
requirements of the Federal law—public input, public posting of the plan, and support for students.
6 The audit team judgmentally selected 11 LEAs to review the submission of their grant application
component of the LEA ARP ESSER plan. We found that six of the 11 had not submitted an application
within 90 days of receiving an allocation.

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Washington provided outreach to these 15 LEAs, and within 2 weeks 9 LEAs had not yet
submitted a grant application, 4 submitted a grant application, and 2 rejected the
funding.
Each LEA receiving ARP ESSER funds must develop a plan for the LEA’s use of ARP ESSER
funds that includes a description of how the funds will be used to implement strategies
consistent with most recent CDC guidance and statutory requirements; consult with
stakeholders and seek public input on its ARP ESSER plan, and make the plan publicly
available on their website; and submit the plan to the SEA by an SEA-determined
deadline, which should be reasonable but no more than 90 days after receiving its ARP
ESSER allocation, according to 86 FR 21198–21200 (April 22, 2021).
In addition, 2 Code of Federal Regulations (C.F.R.) section 200.303(a) states that the
effective internal controls a non-Federal entity must establish and maintain over its
Federal award provide reasonable assurance that it is managing its award in compliance
with Federal statutes, regulations, and the terms and conditions of its award. These
internal controls should be compliant with the Government Accountability Office’s
(GAO) “Standards for Internal Control in the Federal Government” or the Committee of
Sponsoring Organizations of the Treadway Commission’s “Internal Control Integrated
Framework,” May 2013 (COSO Report). According to the COSO Report, a component of
internal control is control activities, which an organization implements through policies
that establish what is expected and in procedures that put policies into action.
Also, the GAO’s “Standards for Internal Control in the Federal Government” includes
principles focused on control activities, use of quality information, and internal
communication. Section 10.03 states that
[m]anagement clearly documents internal control and all transactions and other
significant events in a manner that allows the documentation to be readily
available for examination. The documentation may appear in management
directives, administrative policies, or operating manuals, in either paper or
electronic form. Documentation and records are properly managed and
maintained.
In addition, section 13.02 states that
[m]anagement designs a process that uses the entity’s objectives and related
risks to identify the information requirements needed to achieve the objectives
and address the risks. Information requirements consider the expectations of
both internal and external users. Management defines the identified
information requirements at the relevant level and requisite specificity for
appropriate personnel.

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Lastly, section 13.03 states that, “[m]anagement identifies information requirements in
an iterative and ongoing process that occurs throughout an effective internal control
system. As change in the entity and its objectives and risks occurs, management changes
information requirements as needed to meet these modified objectives and address
these modified risks.”
Based on interviews and our review of Washington’s guidance, Washington officials
prioritized complying with State Legislative requirements, put in place shortly before
Federal requirements were issued, when developing the ARP ESSER plan guidance for
LEAs and their processes for reviewing submitted plans. Washington officials stated that
they were unaware that some Federal requirements were not covered under the State
requirements—specifically, that LEAs must make plans for their use of ARP ESSER funds
publicly available on their websites, with information specific to their uses of funds
consistent with applicable sections of and activities authorized under the ARP, and that
these plans must be submitted to the SEA within a reasonable time, which should be no
later than 90 days after receiving an ARP ESSER allocation. In addition, Washington did
not have formal written policies and procedures for reviewing and approving LEA ARP
ESSER plans.
During the audit, Washington sent a mass email to LEAs requiring them to post grant
applications as required by ARP ESSER;7 however, all LEAs lacked a publicly posted grant
application for a significant period of time after having been allocated ARP ESSER funds.
As a result, the public dissemination and transparency requirements of the ARP ESSER
program were not fully met, and the public was not fully aware of how ARP ESSER funds
were planned to be allocated and spent by their LEAs.
Recommendations
We recommend that the Assistant Secretary for the Office of Elementary and Secondary
Education—
1.1 For LEAs with approved ARP ESSER plans, ensure that Washington has taken
appropriate corrective actions so that these plans meet all ARP ESSER requirements.
1.2 For LEAs that have not yet submitted their ARP ESSER plans, require Washington to
fully document its review and approval of these plans, once they have been
submitted, to ensure that they comply with all ARP ESSER requirements.

7 At the time of our draft report, nine LEAs had not yet submitted a grant application.

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Washington’s Comments
Washington neither agreed nor disagreed with the finding but agreed with the
recommendations. In response to recommendation 1.1, Washington stated that it
completed corrective action for the issues identified. In response to recommendation
1.2, Washington stated that it will pursue a legal requirement that LEAs publicly post
their annual budget.
OIG Response
Washington’s comments were responsive to recommendation 1.1; however, its
comments were not fully responsive to recommendation 1.2. Specifically, Washington’s
comments did not address LEAs’ timely submission of their ARP ESSER plans and its
documentation of the review and approval of these plans. We did not revise the
recommendations in response to Washington’s comments.

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Finding 2. Washington’s Monitoring of LEAs’ Use
of ARP ESSER Funds Could Be Strengthened
We found that Washington’s monitoring of LEAs could be strengthened to provide
additional assurance that LEAs used ARP ESSER grant funds for allowable purposes and
followed applicable regulations. Washington used its iGrants system to approve LEA ARP
ESSER grant budgets and grant applications and process LEA ARP ESSER claims for
reimbursement. However, the claim reimbursement process did not include collecting
or reviewing any expenditure-supporting documentation. As stated below, we identified
one expenditure that did not follow procurement requirements. Washington used its
Consolidated Program Review (CPR) process to review selected LEA expenditures for
compliance with Federal education program requirements, but its CPR process was not
modified to take into consideration the higher risk associated with ARP ESSER
expenditures to ensure selection of APR ESSER expenditures. As a result, Washington
may not have sufficient assurance that ARP ESSER expenditures were allowable.
We selected a sample of 26 ARP ESSER expenditures out of 113,647 expenditures at
2 LEAs to test for allowability. We reviewed supporting documentation for the sample
and identified one procurement-related issue where it was unclear why the selected
vendor was chosen and what criteria were used for selection. For the remaining
25 expenditures, we found that the LEAs used ARP ESSER grant funds for allowable
purposes and followed applicable requirements and policies.
Washington’s Oversight of LEA MOEquity Requirements
The audit team identified that 295 of 313 LEAs requested and received an MOEquity
exception from Washington for FY 2022.8 For an LEA seeking an MOEquity exception for
an exceptional or uncontrollable circumstance, Washington required the LEA to submit
an attestation certifying that it would not implement an aggregate reduction in State
and local per-pupil funding. The remaining 18 LEAs did not seek an exception and
received approval from Washington for meeting MOEquity requirements. Washington
officials stated that LEAs not seeking an exception were required to submit their funding
calculation to Washington for review. If the funding calculation failed the requirements,

8 Of the 295 LEAs that received an exception to MOEquity requirements, 167 LEAs cited that they have a
total enrollment of less than 1,000 students, 116 LEAs cited that they serve all students in a single
building, 113 LEAs cited that they experienced an exceptional or uncontrollable circumstance, and
71 LEAs cited that they operate a single school. The number of LEAs cited is more than 295 because
many of the LEAs met the criteria for more than one exception.

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a Washington official said they provided technical assistance to the LEA to either correct
the calculation or request an exception.
We found that Granger requested an ARP ESSER MOEquity exception for serving all
students in a single building. Seattle requested an exception for an exceptional or
uncontrollable circumstance and did not reduce the aggregate State and local per-pupil
funding. Also, they both provided the required certification, and received confirmation
from Washington that all required documentation was provided to support their
exemption.
Washington’s Reimbursement Process
Washington reimburses LEA ARP ESSER expenditure claims monthly. As stated above,
Washington used its iGrants system to reimburse LEAs for ARP ESSER expenditures. The
process of reviewing LEA expenditures is an automated process using edit checks. After
the budget has been approved, Washington officials enter allowable expenditures into
the iGrants system. All allowable activities are assigned an ARP ESSER object code and
have an associated budgeted cost. During the reimbursement process, the iGrants
system will flag and not pay a claim if it is above the budgeted amount. Washington
requires the LEA to submit an attestation with the expenditure claims that the claims
are “true and accurate.” Any claim that has an allowable ARP ESSER object code and is
within the budgeted amount will be approved. Washington does not require LEAs to
provide supporting documentation for any expenditures. Washington officials stated
that the expenditure-supporting documentation could be reviewed as part of an LEA’s
single audit9 or the CPR monitoring process if selected as part of the review.
Washington’s Monitoring Process
Washington only reviews LEA expenditure-supporting documentation if the LEA is
selected for an annual CPR. Officials select a sample of LEAs to review each year, then
select a sample of expenditures from those LEAs and review the corresponding
supporting documentation. During the coronavirus pandemic, Washington officials said

9 An annual single audit is an audit conducted in accordance with the Single Audit Act Amendments of
1996; the Office of Management and Budget’s Uniform Administrative Requirements, Cost Principles,
and Audit Requirements for Federal Awards (2 Code of Federal Regulations Part 200); the Office of
Management and Budget’s Compliance Supplement; and Government Auditing Standards. A non-
Federal entity that expends $750,000 or more during the non-Federal entity's fiscal year in Federal
awards must have a single audit conducted.

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they performed fewer CPRs due to the restrictions in place. Washington selected the
following number of LEAs to perform CPRs during each of the past 4 school years:
•
2019–2020—95 LEAs selected for review,
•
2020–2021—0 LEAs selected for review,
•
2021–2022—14 LEAs selected for review, and
•
2022–2023—60 LEAs selected for review.
Prior to 2022, Washington’s monitoring selection was primarily organized by region with
all LEAs in the region scheduled to be reviewed. In addition, every year, Washington
reviewed the four LEAs receiving the largest amount of Federal funding (Seattle,
Spokane, Tacoma, and Yakima) and another 10 LEAs that were selected based on risk.
Washington officials stated that they started using a monitoring selection approach that
is solely risk-based in the 2022–2023 school year. LEAs are selected for review based on
the results of Washington’s new risk assessment rubric that considers such factors as
findings from State auditor reports, length of time since last review, and Federal
allocation amounts. Washington officials stated that ESSER funds were calculated into
the Federal allocation amount for the 2022–2023 risk assessment.
The CPR process steps are documented in Washington’s Federal Fiscal Cross-Cutting
Checklist. The checklist describes each requirement and its source, such as the specific
State or Federal regulation. It also lists the evidence to review when determining
compliance. The reviewer’s determination on each requirement is entered into an
electronic system called Program Monitor. Determinations can range between varying
levels of compliance to noncompliance. In a case of noncompliance, corrective action is
required.
Once the LEA is selected, Washington officials will review the grant claims report to
determine what Federal grants the LEA received during the year. The Washington
monitoring team requests expenditure and transaction reports and reviews LEA policies
and procedures related to grant claims, accounts payable, payroll and procurement.
Washington officials will then select a sample of expenditures, based on judgmental

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selection of transactions for review determined by the amount of Federal funding, and
request the supporting documentation for the transactions.10
During the CPR, Washington officials will request the LEA’s expenditure and transaction
reports. Washington officials will then review the reports and compare them to the
iGrants report to ensure that the information matches. In addition, for payroll review,
Washington officials will identify sampled employees and determine if a selected
employee is to be paid by the program or paid by multiple programs. If the employee is
to be paid by multiple programs, the reviewer checks the monthly time and effort
paperwork to ensure the appropriate program is charged. Lastly, Washington officials
will ensure that the time and effort paperwork are signed and dated, and that the
location, certifications, and classifications are correct. For non-payroll transactions,
Washington officials will review supporting documentation, verify that the correct
object code is being used, and review journal entries. For payments that require
competitive procurement, officials will determine that all applicable policy is met, and if
the expenditure is more than $25,000, Washington officials will verify that the vendor is
not suspended or disbarred.
One LEA Did Not Always Follow its Procurement Process
During the audit, we reviewed 26 ARP ESSER expenditures out of 113,647 expenditures
at 2 LEAs to ensure the expenditures were allowable and supportable and that the LEAs
followed applicable requirements and policies. We identified one expenditure for which
the LEA failed to document adequate reasons as to why the vendor was selected in the
procurement process. Seattle Public Schools awarded a transportation contract valued
for at least $890,315 using ARP ESSER funds for the 2021–2022 school year.
According to Seattle Public Schools Procedure 6220SP.D, Contracting for Services, “[t]he
district shall obtain contracted services which will provide the greatest assurance that
the desired services will be provided on time and within budget, while minimizing cost
and risk to the district.”

10 Washington officials said that they judgmentally select expenditures that appear high risk, including
credit card purchases, employee reimbursements, travel, large dollar expenses that are over the bid
threshold, payments to unusual vendors, food purchases, and those with an unusual description that
appear to be unallowable for the program. Moving forward, Washington plans to include random
sampling in fiscal reviews, along with the current method of judgmental sampling.

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Seattle’s policy states that for all contracts, the district will conduct a selection process
and prepare documentation for the selection process. The policy for Competitive
Process for Service Contracts above $75,000, states that
[w]here the District requires the same or similar services for several unrelated
projects over an extended period, it may solicit statements of qualifications
from vendors in the field. The statements are evaluated, and vendors who have
the necessary qualifications and are available when the services are needed are
selected. This process should be performed every three to five years, to assure
open competition among vendors.
In addition, Seattle’s Procedure 6220SP.D policy states that the following
documentation and approvals are required for contracts:
Each Initiator shall be responsible for providing procurement with
documentation as required for the competitive solicitation, which typically
includes the following: a memo from the Initiator recommending an award to
the vendor or contractor, the evaluation results for the request for proposal or
request for qualifications, reference checks for the successful vendor, a copy of
the Board minutes approving the contract, and a copy of the final, executed
contract.
Because the contract used an open-ended purchase order to be paid based on services
rendered, we were unable to determine if the selected vendor’s costs were lower than
those of other bidders. Seattle provided score cards and reviewer notes when the audit
team requested justification for the selected vendor. Based on our review of this
documentation, we were unable to determine how the vendor was selected over the
other vendors who submitted qualifications and if it represented the best value to the
LEA. The selected vendor did not receive the best overall score; in fact, they received
one of the lower scores.
LEA Monitoring Could Be Strengthened
Washington’s claims reimbursement process did not include a review of supporting
documentation for any LEA ARP ESSER expenditures, even on a sample basis. In
addition, although Washington does review expenditures as part of its CPR process, it
did not modify its process so that ARP ESSER expenditures would be selected for review.
A non-Federal entity must establish and maintain effective internal control over the
Federal award that provides reasonable assurance that it is managing the award in
compliance with Federal statutes, regulations, and the terms and conditions of its award
(2 C.F.R. section 200.303(a)). These internal controls should be compliant with the
Comptroller General of the United States’ guidance in the U.S. Government

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Accountability Office’s (GAO) Standards for Internal Control in the Federal Government
(September 2014) or the Committee of Sponsoring Organizations of the Treadway
Commission’s Internal Control Integrated Framework. One component of internal
control is control activities. Section 10.01 of GAO’s Standards for Internal Control in the
Federal Government states that management should design control activities to achieve
objectives and respond to risks.
Also, the non-Federal entity is responsible for oversight of the operations of the Federal
award supported activities. The non-Federal entity must monitor its activities under
Federal awards to assure compliance with applicable Federal requirements and
performance expectations are being achieved. Monitoring by the non-Federal entity
must cover each program, function, or activity (2 C.F.R. section 200.329 (a)). Further,
State grantees (pass-through entities) are required to establish monitoring priorities
based on the risks posed by each subgrantee and monitor the fiscal activity of
subgrantees as necessary to ensure that the subaward is used for authorized purposes,
complies with Federal statutes, regulations, and the terms and conditions of the
subaward; and that subaward performance goals are achieved (2 C.F.R. section
200.332).
In addition, as it relates to the Seattle expenditure in question, the accounting practices
of a non-Federal entity must provide for adequate documentation to support costs
charged to the Federal award (2 C.F.R. section 200.400 (d)).
Lastly, a non-Federal entity must perform a cost or price analysis in connection with
every procurement action in excess of the simplified acquisition threshold including
contract modifications. The method and degree of analysis varies, but as a starting
point, the non-Federal entity must make independent estimates before receiving bids or
proposals. Further, a non-Federal entity must negotiate profit as a separate element of
the price for each contract in which there is no price competition and in all cases where
cost analysis is performed. To establish a fair and reasonable profit, consideration must
be given to the complexity of the work to be performed, contractor risk and investment,
the amount of subcontracting, past performance, and industry profit rates in the
surrounding geographical area for similar work (2 C.F.R. section 200.324(a) and (b)).
Washington officials stated that they cannot review all expenditures during the
reimbursement process due to the lack of staff to conduct the reviews timely.
Washington uses the CPR process to review a sample of expenditures based on a risk
analysis.
ARP ESSER is a new program with its own unique requirements and a wide range of
authorized activities, providing an unprecedented amount of funding for elementary
and secondary education in the United States. As a result, there is substantial interest in

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how and on what funds are being spent, and in ensuring that they are being spent
appropriately. There is also inherent and higher risk associated with ARP ESSER given
the size and nature of this emergency program.  The Department and the Office of
Management and Budget recognized this by designating the Education Stabilization
Fund, which includes ARP ESSER, as higher risk.11 Washington should likewise consider
ARP ESSER to be a higher risk program and take steps, using a risk-based approach, to
provide greater assurance that LEAs’ ARP ESSER expenditures meet all applicable
requirements. Without such oversight controls in place, Washington is at risk of not
identifying expenditures by its LEAs for unallowable or unapproved purposes and other
instances of noncompliance.
Recommendation
We recommend that the Assistant Secretary for the Office of Elementary and Secondary
Education require that Washington—
2.1 In order to address the heightened risk associated with ARP ESSER funds, for the
reimbursement and monitoring processes, develop and implement protocols to
sample LEA expenditures charged to ARP ESSER, and to review supporting
documentation, including procurement process documentation, to ensure that
applicable Federal, State, and local requirements are met.
Washington’s Comments
Washington neither agreed nor disagreed with the finding but agreed with the
recommendation. First, Washington stated that it will update its processes for
reimbursing and monitoring LEAs to ensure that expenditures are sampled and tested
for compliance with applicable Federal requirements. Second, Washington stated that it
reviewed ARP ESSER expenditures using its CPR process.
OIG Response
Washington’s first comment about revising the reimbursement and monitoring process
is responsive to the recommendation.  In response to Washington’s second comment,
we clarified the report noting that the CPR process does not ensure that ARP ESSER
funds are selected for review, given the heightened risks.

11 The Education Stabilization Fund, consisting of ESSER and other pandemic relief programs, was
designated as higher risk in the Office of Management and Budget’s Compliance Supplements for 2021,
2022, and 2023. This designation was made pursuant to 2 C.F.R. section 200.519(c)(2).

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Appendix A. Scope and Methodology
Our audit objectives were to determine whether Washington had an adequate oversight
process in place to ensure that (1) LEAs’ ARP ESSER plans met applicable requirements
and (2) LEAs use ARP ESSER funds in accordance with applicable requirements and their
approved LEA ARP ESSER plans. Our audit covered March 24, 2021, through October 31,
2022. We held an exit conference on May 30, 2023, and discussed our audit
observations with Washington officials.
To achieve our objective, we gained an understanding of the following laws, regulations,
Department guidance, and grant documents relevant to ARP ESSER:
•
The CARES Act, March 27, 2020
•
CRRSAA, December 27, 2020
•
The ARP, March 11, 2021
•
2 C.F.R. part 200, Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards
•
Washington, Seattle, and Granger procurement policies
•
The Department’s ARP ESSER Fact Sheet
•
The Department’s ESSER and Governor’s Emergency Education Relief Use of
Funds frequently asked questions, updated December 7, 2022
•
The Department’s frequently asked questions, ARP ESSER, MOEquity
Requirements, July 26, 2022
•
The Department’s letter on liquidation deadline to the American Association of
School Administrators, May 13, 2022
•
The Department’s ARP ESSER, “Using Covid-Relief funds for facility upgrades,
renovations, and construction,” September 2, 2021
•
The Department’s COVID 19 Handbook, “Roadmap to Reopening Safely and
Meeting All Students’ Needs”
•
The Department’s “Strategies for Using American Rescue Plan Funding to
Address the Impact of Lost Instructional Time”
•
The Department’s “How ARP Funds Can Prevent and Respond to Crime and
Promote Public Safety,” June 2021
•
GAO’s Green Book, “Standards for Internal Control in the Federal Government,”
September 2014

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•
The COSO Report, May 2013
We gained an understanding of Washington’s oversight and monitoring activities
through interviews with SEA and LEA officials. We interviewed employees and officials
from Washington, Granger, and Seattle who had significant roles in establishing,
implementing, administering, or monitoring the ARP ESSER program. To assess the
reliability of the testimonial evidence, we compared information obtained from
interviews with records related to Washington’s oversight and monitoring activities
when provided by the interviewees. We concluded that the testimonial evidence we
obtained was sufficiently reliable within the context of our audit objective.
Additionally, we reviewed documents and records. We reviewed documents identifying
Washington’s staff who had a role in establishing, administering, or monitoring the ARP
ESSER program. We reviewed Washington’s guidance and technical assistance
documents provided to LEAs regarding ARP ESSER plans and funding. We reviewed
written policies and procedures to gain an understanding of how Washington monitored
LEAs’ use of ARP ESSER funds, including the CPR, reimbursement process, and MOEquity
determinations. We also reviewed the tools that Washington used to monitor LEA ARP
ESSER plans and LEAs’ use of ARP ESSER funds. The purpose of these document reviews
was to gain an understanding of how Washington administered and monitored ARP
ESSER funds.
Internal Controls
We obtained an understanding of all five GAO areas of internal control (control
environment, risk assessment, control activities, information and communication, and
monitoring) relevant to Washington’s oversight and monitoring activities for the ARP
ESSER program. We concluded that all five components of internal control were
significant to our audit objective.
•
Control environment—oversight structure, oversight for the internal control
system, assignment of responsibility and delegation of authority, and
documentation of Washington’s internal control system.
•
Control activities—design of appropriate types of control activities, design of
control activities at various levels, documentation of responsibilities through
policies, and periodic review of control activities.
•
Information and Communication—use quality information and communicate it
internally and externally.
•
Monitoring—establish and operate monitoring activities to monitor the internal
control system and evaluate results.

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•
Risk assessment—risk identification, analysis of risk, responses to risk, including
consideration of the potential for fraud.
As discussed in our findings, we identified weaknesses in Washington’s ARP ESSER
oversight processes, particularly with respect to its control activities and monitoring
processes.
Sampling Methodology
To determine if Washington had an adequate oversight process to ensure that LEAs use
ARP ESSER funds in accordance with applicable requirements and their approved LEA
ARP ESSER plans, we reviewed activities at 2 LEAs and tested a sample of
26 expenditures in total from the 2 LEAs. We judgmentally selected the LEA with the
largest ARP ESSER funding allocation. For the second LEA selected, we excluded LEAs
that received an ARP ESSER allocation of less than $5 million and had expended less
than 25 percent of their allocation. We chose this sampling strategy to ensure the
selection of an LEA with a significant allocation amount and an LEA with significant grant
fund expenditures. Our LEA sample was not a statistical sample and cannot be
projected. We selected Granger School District (Granger) and Seattle Public Schools
(Seattle).
For Granger, we selected a sample of 13 expenditures from a total population of
3,885 line items. The population of expenditures were comprised of expenditures
categorized for learning loss (20 percent of the LEA’s ARP ESSER allocation) and the
remaining expenditures (80 percent of the LEA’s ARP ESSER allocation).
•
From the learning loss population, we randomly selected three expenditures
greater than $2,000.
•
From the other expenditures population, we selected the three vendors with
the largest total expenditure amount and picked the highest dollar expenditure
from each vendor. Then, we randomly selected seven additional expenditures
greater than $5,000.
For Seattle, we selected a sample of 13 expenditures from a total population of
109,762 line items. Like Granger, the population of Seattle’s expenditures were
comprised of expenditures categorized for learning loss (20 percent of the LEA’s ARP
ESSER allocation) and the remaining expenditures (80 percent of the LEA’s ARP ESSER
allocation).
•
From the learning loss population, we randomly selected three expenditures
greater than $10,000.
•
From the other expenditures population, we selected the two vendors with the
largest total expenditure amount and picked the highest dollar expenditure

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from each vendor. Then, we selected the highest dollar expenditure from a
vendor that was judgmentally selected. The vendor was chosen so we could
compare expenditures from the same vendor used by Granger. Next, we
randomly selected seven expenditures greater than $10,000.
Use of Computer-Processed Data
We relied, in part, on computer-processed data from Granger’s and Seattle’s accounting
systems. We used a list of expenditures provided by each LEA from their accounting
system to select a sample of expenditures to test for allowability. To assess the
reliability of the expenditure data, we reviewed the amount of ARP ESSER funds
expended to ensure that it was less than the total allocation. Also, we verified the
individual expenditures’ totals to evidence provided as support for each sampled
expenditure. We did not identify any issues and concluded that the data in Granger’s
and Seattle’s accounting systems were sufficiently reliable for the purposes of our audit.
Compliance with Standards
We conducted this performance audit in accordance with generally accepted
government auditing standards. Those standards require that we plan and perform the
audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our
findings and conclusions based on our audit objective. We believe that the evidence
obtained provides a reasonable basis for our finding and conclusions based on our audit
objective.
We remotely conducted our audit from August 2022 through June 2023. We discussed
the results of our audit with Washington’s officials on May 30, 2023.

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Appendix B. Allowable Use of Funds
Activities that an LEA may support with ESSER funds include:12
1. Any activity authorized by the ESEA, including the Native Hawaiian Education
Act and the Alaska Native Educational Equity, Support, and Assistance Act
(20 United States Code (U.S.C.) 6301 et seq.).
2. Any activity authorized by the Individuals with Disabilities Education Act
(20 U.S.C. 1400 et seq.).
3. Any activity authorized by the Adult Education and Family Literacy Act
(29 U.S.C.3271 et seq.).
4. Any activity authorized by the Carl D. Perkins Career and Technical Education
Act of 2006 (20 U.S.C. 2301 et seq.).
5. Any activity authorized by subtitle B of title VII of the McKinney-Vento Homeless
Assistance Act (42 U.S.C. 11431 et seq.).
6. Coordinating preparedness and response efforts of LEAs with State, local, Tribal,
and territorial public health departments, and other relevant agencies, to
improve coordinated responses among such entities to prevent, prepare for,
and respond to COVID-19.
7. Providing principals and other school leaders with the resources necessary to
address the needs of their individual schools.
8. Activities to address the unique needs of low-income children or students,
students with disabilities, English learners, racial and ethnic minorities, students
experiencing homelessness, and children and youth in foster care, including how
outreach and service delivery will meet the needs of each population.
9. Developing and implementing procedures and systems to improve the
preparedness and response efforts of LEAs.
10. Training and professional development for staff of the LEA on sanitation and
minimizing the spread of infectious diseases.
11. Purchasing supplies to sanitize and clean the facilities of the LEA, including
buildings operated by such LEA.
12. Planning for, coordinating, and implementing activities during long-term
closures, including providing meals to eligible students, providing technology for

12 According to CARES Act section 18003(d), CRRSA Act section 313(d), and ARP Act section 2001(e).

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online learning to all students, providing guidance for carrying out requirements
under the IDEA and ensuring other education services can continue to be
provided consistent with all Federal, State, and local requirements.
13. Purchasing educational technology (including hardware, software, and
connectivity) for students who are served by the LEA that aids in regular and
substantive educational interaction between students and their classroom
instructors, including low-income students and students with disabilities, which
may include assistive technology or adaptive equipment.
14. Providing mental health services and supports, including through the
implementation of evidence-based full-service community schools.
15. Planning and implementing activities related to summer learning and
enrichment and supplemental after-school programs, including providing
classroom instruction or online learning during the summer months and
addressing the needs of low-income students, students with disabilities, English
learners, migrant students, students experiencing homelessness, and children
and youth in foster care.
16. Addressing the academic impact of lost instructional time among an LEA’s
students, including low-income students, students with disabilities, English
learners, racial and ethnic minorities, students experiencing homelessness, and
children and youth in foster care, including by:
a. Administering and using high-quality assessments that are valid and reliable
to accurately assess students’ academic progress and assist educators in
meeting students’ academic needs, including through differentiating
instruction.
b. Implementing evidence-based activities to meet the comprehensive needs
of students.
c. Providing information and assistance to parents and families on how they
can effectively support students, including in a distance learning
environment.
d. Tracking student attendance and improving student engagement in distance
education.
17. School facility repairs and improvements to enable operation of schools to
reduce risk of virus transmission and exposure to environmental health hazards,
and to support student health needs.
18. Inspection, testing, maintenance, repair, replacement, and upgrade projects to
improve the indoor air quality in school facilities, including mechanical and non-
mechanical heating, ventilation, and air conditioning systems, filtering,

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purification and other air cleaning, fans, control systems, and window and door
repair and replacement.
19. Developing strategies and implementing public health protocols including, to
the greatest extent practicable, policies in line with guidance from the CDC for
the reopening and operation of school facilities to effectively maintain the
health and safety of students, educators, and other staff.
20. Other activities that are necessary to maintain the operation of and continuity
of services in the LEA and continuing to employ existing staff of the LEA.

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Appendix C. Acronyms and Abbreviations
Academic Plan
Academic and Student Well-being Recovery Plan
ARP
American Rescue Plan
CARES Act
Coronavirus Aid, Relief, and Economic Security Act
CDC
Center for Disease Control and Prevention
C.F.R.
Code of Federal Regulations
COSO Report
Committee of Sponsoring Organization of the Treadway
Commission's Internal Control Integrated Framework
CPR
Consolidated Program Review
CRRSAA
Coronavirus Response and Relief Supplemental Appropriations
Act
Department
U.S. Department of Education
ESEA
Elementary and Secondary Education Act of 1965
ESSER
Elementary and Secondary School Emergency Relief
FR
Federal Register
FY
fiscal year
GAO
U.S. Government Accountability Office
Granger
Granger School District
IFR
Interim Final Requirements
LEA
local educational agency
MOEquity
Maintenance of Equity
OESE
Office of Elementary and Secondary Education
SEA
State educational agency
Seattle
Seattle Public Schools
U.S.C.
United States Code
Washington
Washington Office of Superintendent of Public Instruction

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Washington’s Comments

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