Burlington Community School District's Use of Elementary and Secondary School Emergency Relief Grant Funds (ED-OIG/F24CA0172)

Summary

U.S. Department of Education Office of Inspector General Flash Report ED-OIG/F24CA0172, Burlington Community School District's Use of Elementary and Secondary School Emergency Relief Grant Funds, dated August 9, 2024 and addressed to Iowa Department of Education Director McKenzie Snow. Burlington in Iowa was allocated approximately $16.5 million in ESSER funds for 8 schools serving about 3,300 students and had spent about $13.5 million, 82 percent, as of August 15, 2023. The OIG reviewed 20 non-personnel expenditures totaling $3,202,646 from July 1, 2022 through June 30, 2023 and found all allowable and in accordance with requirements, with key procurement requirements met. Because it identified no exceptions, the report makes no recommendations, and Iowa agreed with the finding.

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U.S. Department of Education
Office of Inspector General
Burlington Community School
District’s Use of Elementary and
Secondary School Emergency
Relief Grant Funds
August 9, 2024
ED-OIG/F24CA0172

FLASH REPORT

NOTICE
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.

August 9, 2024
McKenzie Snow
Director
Iowa Department of Education
400 E 14th St
Des Moines, IA 50319
Dear Director Snow:

Enclosed is our final report, “Burlington Community School District’s Use of Elementary and Secondary
School Emergency Relief Grant Funds,” Control Number ED-OIG/F24CA0172. This report incorporates
the comments you provided in response to the draft report. The U.S. Department of Education’s policy is
to expedite audit 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
flash review, you should send them directly to the following Department of Education official, who will
consider them before taking final Departmental action on this review:
Adam Schott
Delegated the Authority to Perform the Functions and Duties of the Assistant Secretary
Office of Elementary and Secondary Education
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
(916) 213-7630 or Ben.Sanders@ed.gov.
Sincerely,

/s/

Ben C. Sanders
Regional Inspector General for Audit

Enclosure

Flash Report
ED-OIG/F24CA0172
U.S. Department of Education, Office of Inspector General
Results in Brief
Burlington Community School District’s Use of Elementary and
Secondary School Emergency Relief Grant Funds
Why the OIG Performed
This Work
Congress passed three coronavirus
relief acts within a 1-year period that
provided more than $275 billion for
an Education Stabilization Fund to
prevent, prepare for, and respond to
the coronavirus, which the President
declared as a national emergency in
March 2020. This included
$189.5 billion for Elementary and
Secondary School Emergency Relief
(ESSER), funds intended to provide
vital support to States, local
educational agencies, and schools to
address the impact of the
coronavirus. Support, in part,
includes activities designed to help
students and educators safely return
to and sustain in-person instruction,
and that address the educational
inequities exacerbated by the
coronavirus pandemic and students’
social, emotional, mental health, and
academic needs.
Ensuring that ESSER funds are used
for allowable purposes is critical to
help address the needs of students
and educators. The Burlington
Community School District
(Burlington) was allocated
approximately $16.5 million in ESSER
funds to support 8 schools serving
about 3,300 students.
We performed this review to
determine whether Burlington
expended ESSER grant funds for
allowable purposes in accordance
with applicable requirements.
What Did the OIG Find?
We determined that all the ESSER expenditures we reviewed for Burlington were
allowable and in accordance with applicable requirements. Allowable activities generally
include those authorized by the Elementary and Secondary Education Act, Individuals with
Disabilities Education Act, Adult Education and Family Literacy Act, Carl D. Perkins Career
and Technical Education Act of 2006, and subtitle B of title VII of the McKinney-Vento
Homeless Assistance Act. It also includes activities listed in section A-3 of the U.S.
Department of Education’s Frequently Asked Questions document for the ESSER and
Governor’s Emergency Education Relief Programs.
We also found that Burlington complied with key Federal procurement requirements,
including those covering the procurement methods to be followed and contract cost,
price, and provisions, when procuring the goods or services associated with each ESSER
expenditure we reviewed.
What Are the Next Steps?
Because we identified no exceptions, our report does not include recommendations.
However, our results are limited to the ESSER expenditures we reviewed, and it is critical
that any remaining ESSER funds continue to be used appropriately.
We provided a draft of this report to the Iowa Department of Education (Iowa) for
comment, and copied Burlington on that transmittal. We summarize Iowa’s comments,
which included feedback from Burlington, at the end of the finding and provide the full
text of the comments at the end of the report (Iowa Department of Education’s
Comments). Iowa agreed with our finding. In the feedback it provided to Iowa, Burlington
stated that it agreed with the information in this report and would ensure that all
remaining ESSER funds are used for allowable purposes in accordance with applicable
requirements.

U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0172
1
Purpose
The objective of our flash review was to determine whether the Burlington Community
School District (Burlington) expended Elementary and Secondary School Emergency
Relief (ESSER)1 grant funds for allowable purposes in accordance with applicable
requirements. This flash review report presents the results of our review.
Burlington Community School District
The Burlington Community School District in Iowa is a local educational agency (LEA) in a
remote town setting with 8 schools serving about 3,300 students. Burlington was
allocated approximately $16.5 million in ESSER funds. As of August 15, 2023, Burlington
had spent about $13.5 million (82 percent) of its $16.5 million ESSER allocation to
address the impacts of the coronavirus pandemic. In its approved American Rescue Plan
Act (ARP) ESSER plan, Burlington noted that it planned to use its ARP ESSER funds for
evidence-based accelerated learning interventions in literacy, mathematics, and social-
emotional-behavioral health (including mental health); expansion of summer school
offerings; and improvements in school facilities to reduce the risk of virus transmission
and improve indoor air quality.
Results of Our Review
For the selected transactions covered by our review, Burlington expended ESSER grant
funds for allowable purposes and in accordance with applicable requirements. We
selected and reviewed 20 non-personnel ESSER expenditures (19 percent) from a total
population of 108 non-personnel expenditures for the period July 1, 2022, through
June 30, 2023 (review period).2 We used a judgmental, risk-based process to select the

1 ESSER is one of multiple emergency relief funds comprising the Education Stabilization Fund, which
was first authorized and funded under the Coronavirus Aid, Relief, and Economic Security Act (March 27,
2020), and for which Congress later provided additional funding under the Coronavirus Response and
Relief Supplemental Appropriations Act (December 27, 2020) and the American Rescue Plan (March 11,
2021). Under ESSER, the U.S. Department of Education awarded grants to State educational agencies for
the purpose of providing local educational agencies with emergency relief funds to address the impacts
that the coronavirus pandemic had on elementary and secondary schools and their students.
2 We limited the scope of our review to non-personnel expenditures; personnel expenditures were
excluded because they represented a relatively small percentage of all ESSER expenditures (non-
personnel and personnel) during our review period.

U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0172
2
20 expenditures, which represented $3,202,646 (61 percent) of the $5,278,074 in total
non-personnel ESSER expenditures during our review period.
We reviewed each expenditure to determine whether it was (1) connected to the
coronavirus pandemic (intended to prevent, prepare for or respond to the coronavirus
pandemic, including its impact on the social, emotional, mental health, and academic
needs of students); (2) an authorized use of ESSER funds under applicable law and
regulations; and (3) reasonable and necessary and otherwise permissible under the
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards (Uniform Guidance, 2 Code of Federal Regulations (C.F.R.) part 200). We
also performed additional work, as needed, to determine whether Burlington complied
with key Federal procurement requirements, specifically those covered under 2 C.F.R.
sections 200.320 (methods of procurement to be followed), 200.324 (contract cost and
price), and 200.327 (contract provisions), when procuring the goods or services
associated with each expenditure. We interviewed Burlington officials to gain a basic
understanding of how they used ESSER funds, and their processes for approving and
monitoring ESSER expenditures.
An LEA can use ESSER funds for any activity deemed allowable under section 18003(d) of
the Coronavirus Aid, Relief, and Economic Security Act (P.L. 116-136); section 313(d) of
the Coronavirus Response and Relief Supplemental Appropriations Act (P.L. 116-260);
and section 2001(e) of ARP (P.L. 117-2). These activities generally include any activity
authorized by the Elementary and Secondary Education Act, Individuals with Disabilities
Education Act, Adult Education and Family Literacy Act, Carl D. Perkins Career and
Technical Education Act of 2006, and subtitle B of title VII of the McKinney-Vento
Homeless Assistance Act; as well as those listed in section A-3 of the U.S. Department of
Education’s Frequently Asked Questions document for the ESSER and Governor’s
Emergency Education Relief Programs (May 2021, and updated on December 7, 2022).
We determined that all 20 (100 percent) expenditures that we reviewed for Burlington
were used for allowable purposes and in accordance with applicable requirements.
These expenditures were generally for school facility repairs, air quality improvements,
asbestos abatement, and construction management. They were connected to the
coronavirus pandemic, authorized uses of ESSER funds under applicable law and
regulations, and reasonable and necessary and otherwise permissible under Uniform
Guidance. In addition, we found that Burlington complied with the key Federal
procurement requirements covered under 2 C.F.R. sections 200.320 (methods of
procurement to be followed), 200.324 (contract cost and price), and 200.327 (contract
provisions) when procuring the goods or services associated with each expenditure.
Because all the expenditures we reviewed were for allowable purposes and in
accordance with applicable requirements, we make no recommendations in this report.

U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0172
3
However, our results are limited to the ESSER expenditures we reviewed, and it is critical
that any remaining ESSER funds continue to be used appropriately.
Iowa Department of Education’s Comments
The Iowa Department of Education (Iowa) agreed with our finding. In the feedback that
it provided to Iowa, Burlington stated that it agreed with the information in this report
and would ensure that all remaining ESSER funds are used for allowable purposes in
accordance with applicable requirements.

U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0172
4
Appendix A. Scope and Methodology
Our review covered Burlington’s non-personnel ESSER expenditures from July 1, 2022,
through June 30, 2023 (review period). We limited our scope to non-personnel
expenditures because they accounted for the vast majority (84 percent) of all ESSER
expenditures (non-personnel and personnel) during our review period. We limited our
internal control work to gaining a basic understanding of how Burlington’s accounting
system was used to account for ESSER funds and how to interpret accounting codes. We
conducted our review remotely from February 2024 through June 2024. We discussed
the results of our review with Burlington and Iowa officials on June 11, 2024.
Sampling Methodology
To determine whether Burlington expended ESSER grant funds for allowable purposes in
accordance with applicable requirements, we selected and reviewed 20 non-personnel
expenditures (19 percent) from a total population of 108 non-personnel expenditures
for the period July 1, 2022, through June 30, 2023. We used a judgmental, risk-based
process to select the 20 expenditures for review. We selected three expenditures,
including the two largest expenditures, because they were high dollar (each exceeded
$100,000) and paid to a vendor whose goods and services accounted for more than
80 percent of the LEA’s non-personnel ESSER expenditures during our review period. We
selected the remaining 17 expenditures using one or a combination of high dollar
amount, vendor name, unclear transaction description, and duplicate amount. The
20 expenditures represented $3,202,646 (61 percent) of the $5,278,074 in total non-
personnel ESSER expenditures during our review period. The results of our testing apply
only to the expenditures reviewed and cannot be projected to the universe of non-
personnel ESSER expenditures.
Use of Computer-Processed Data
We relied, in part, on computer-processed data (LEA expenditure data) from
Burlington’s accounting system. Burlington provided us with a PDF document (report
generated from its accounting system) that contained its ESSER expenditure data from
July 1, 2022, through June 30, 2023. We converted the PDF document to a spreadsheet
for quicker review and analysis. To assess the completeness of the expenditure data in
the spreadsheet, we compared total expenditures in the spreadsheet to total
expenditures in the four quarterly ESSER expenditure reports that Burlington submitted
to the Iowa Department of Education for our review period. To assess the reliability of
the expenditure data in the spreadsheet, we reviewed supporting documentation, such
as invoices and proof of payment, for the 20 expenditures covered by our review. We
did not identify any issues and concluded that the expenditure data in the spreadsheet
were reliable for their intended use.

U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0172
5
Compliance with Standards
We conducted our work in accordance with OIG quality control standards and the
Council of the Inspectors General on Integrity and Efficiency’s “Quality Standards for
Federal Offices of Inspector General,” which require that we conduct our work with
integrity, objectivity, and independence. We believe that the information obtained
provides a reasonable basis for our conclusions.

U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0172
6
Appendix B. Acronyms and Abbreviations
ARP
American Rescue Plan Act
Burlington
Burlington Community School District
C.F.R.
Code of Federal Regulations
ESSER
Elementary and Secondary School Emergency Relief
Iowa
Iowa Department of Education
LEA
local educational agency
Uniform Guidance
Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards

U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0172
7
Iowa Department of Education’s Comments

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