Clark County School District's Use of Elementary and Secondary School Emergency Relief Funds (ED-OIG/F24NY0207)
Summary
U.S. Department of Education Office of Inspector General Final Flash Report ED-OIG/F24NY0207, Clark County School District's Use of Elementary and Secondary School Emergency Relief Funds, dated March 31, 2025, transmitted by Sean Dawson, Assistant Inspector General for Audit, to the Nevada Department of Education. The report states that the objective was to determine whether Clark expended American Rescue Plan (ARP) ESSER grant funds for allowable purposes in accordance with applicable requirements. It states that Clark was allocated approximately $778 million in ARP ESSER funds and that OIG determined all the ARP ESSER expenditures it reviewed were allowable and that Clark complied with key Federal procurement requirements. The report states that it does not include recommendations.
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- Issuer
- U.S. Department of Education, Office of Inspector General
- Document type
- Report
- Date
- 2025-03-31
Cite this document
“Clark County School District's Use of Elementary and Secondary School Emergency Relief Funds (ED-OIG/F24NY0207).”
U.S. Department of Education, Office of Inspector General, dated 2025-03-31. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/clark-county-school-district-esser/
, SHA-256 e5f4ab1a253ef2ceb4e762028a8e65736010262710a3a71d465d4819de888c2c.Full text
U.S. Department of Education
Office of Inspector General
Clark County School District’s Use
of Elementary and Secondary
School Emergency Relief Funds
March 31, 2025
ED-OIG/F24NY0207
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
March 31, 2025
Jhone M. Ebert
Superintendent of Public Instruction
Nevada Department of Education
700 E. Fifth Street
Carson City, NV 89701
Dear Superintendent Ebert:
Enclosed is our final report, “Clark County School District’s Use of Elementary and Secondary School
Emergency Relief Funds,” Control Number ED-OIG/F24NY0207. 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 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 flash review:
Hayley Sanon
Acting 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
(202) 987-0173 or Sean.Dawson@ed.gov.
Sincerely,
/s/
Sean Dawson
Assistant Inspector General for Audit
Enclosure
400 MARYLAND AVENUE, S.W., WASHINGTON, DC 20202-1510
Promoting the efficiency, effectiveness, and integrity of the Department’s programs and operations.
U.S. Department of Education, Office of Inspector General
Results in Brief
Clark County School District’s Use of Elementary and Secondary School
Emergency Relief Funds
Why the OIG Performed What Did the OIG Find?
This Work We determined that all the ARP ESSER expenditures we reviewed for Clark were allowable
Congress passed three coronavirus relief and in accordance with applicable requirements. An LEA could use ARP ESSER funds for a
acts within a 1-year period that broad range of activities listed in any of the coronavirus relief acts and identified in
provided more than $275 billion for an U.S Department of Education guidance, including any activities authorized by several
Education Stabilization Fund to prevent, Federal education laws.
prepare for, and respond to the
We also found that Clark complied with key Federal procurement requirements,
coronavirus, which the President
including those covering the procurement methods to be followed and contract cost,
declared as a national emergency in
price, and provisions, when procuring the goods or services associated with each ARP
March 2020. This included $189.5 billion ESSER expenditure we reviewed.
for Elementary and Secondary School
Emergency Relief (ESSER) funds, What Are the Next Steps?
intended to provide vital support to Because we identified no exceptions for the ARP ESSER expenditures that we reviewed,
States, local educational agencies, and our report does not include recommendations.
schools to address the impact of the
coronavirus. Support, in part, includes We provided a draft of this report to the Nevada Department of Education for comment.
activities designed to help students and Since the draft report did not include recommendations, written comments on our draft
educators safely return to and sustain report were not provided.
in-person instruction; address the
educational inequities exacerbated by
the coronavirus pandemic; and address
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 Clark County School
District (Clark) was allocated
approximately $778 million in American
Rescue Plan (ARP) ESSER funds to
support 383 schools serving about
304,565 students.
We performed this review to determine
whether Clark expended ARP ESSER
grant funds for allowable purposes in
accordance with applicable
requirements.
Final Flash Report ED-OIG/F24NY0207
Purpose
The objective of this flash review was to determine whether the Clark County School
District (Clark) expended American Rescue Plan (ARP) 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.
Clark County School District
Clark, located in Las Vegas, Nevada, is a local educational agency (LEA) with 383 schools
serving about 304,565 students. Clark was allocated approximately $778 million in ARP
ESSER funds and as of December 13, 2024, had expended 98 percent of its funds.
According to Nevada’s Federal Relief Tracker, Clark budgeted 45 percent of funds for
staff, 35.7 percent for supplies, 16.2 percent for services, and 3.1 percent for other
purposes. 2 Clark’s approved ARP ESSER plan was to use its funds for technology,
instructional materials, mental health services, teacher and support staff development,
COVID-19 mitigation and response, and the development of a web-based public
database system.
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 ARP
(March 11, 2021). Under ESSER, the U.S. Department of Education awarded grants to State educational
agencies to provide 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
This information is from the Nevada Department of Education’s Federal Relief Tracker, which is
updated periodically.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0207 1
Results of Our Review
For the selected transactions covered by our review, Clark expended ARP ESSER grant
funds for allowable purposes and in accordance with applicable requirements. We
selected and reviewed 24 non-personnel ARP ESSER expenditures 3 from a total
population of 17,592 ARP ESSER non-personnel expenditures for the period July 1, 2023,
through June 30, 2024 (review period). For these 24 non-personnel expenditures, we
used a judgmental, risk-based process to select 4 and a stratified non-statistical random
sample process to select the other 20 expenditures. These expenditures represented
$7.66 million (6 percent) of the total $135.58 million 4 in non-personnel ARP ESSER
expenditures during our review period.
We reviewed each expenditure to determine whether it was (1) connected to the
coronavirus pandemic and 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 ARP ESSER funds under applicable
laws and regulations; and (3) reasonable and necessary and otherwise permissible
under the Uniform Administrative Requirements, Cost Principles, and Audit
Requirements for Federal Awards (2 Code of Federal Regulations (C.F.R.) part 200). We
also performed additional work, as needed, to determine whether Clark 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 Clark officials to gain a basic
understanding of how they used ARP ESSER funds, and their processes for approving
and monitoring ARP ESSER expenditures.
An LEA could use ARP ESSER funds for a broad range of activities listed in any of the
coronavirus relief acts and identified in U.S. Department of Education guidance,
including any activities authorized by several Federal education laws.
We determined that all 24 expenditures that we reviewed for Clark were used for
allowable purposes and in accordance with applicable requirements. These
expenditures were generally for technology, educational materials and software,
3
We limited the scope of our review to non-personnel expenditures; personnel expenditures were
excluded because Clark’s non-personnel expenditures represented 57 percent of the total expenditures
within our review period.
4
This did not include $5.90 million in indirect costs during our review period.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0207 2
textbooks, employee training and development services, mental health services,
licensed professionals, and consulting services for a web-based public database system.
Each expenditure was connected to the coronavirus pandemic, an authorized use of
ESSER funds under applicable laws and regulations, and reasonable and necessary and
otherwise permissible under 2 C.F.R. part 200. In addition, we found that Clark complied
with 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.
Nevada Department of Education’s Comments
The Nevada Department of Education did not provide written comments to this report
because it did not have recommendations.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0207 3
Appendix A. Scope and Methodology
Our review covered Clark’s ARP ESSER expenditures from July 1, 2023, through
June 30, 2024, our review period. We limited the scope of our review to ARP ESSER
funds because Clark’s ARP ESSER funds represented the highest dollar amount ($778
million) of all ESSER funds ($1.2 billion) that were allocated to them. We also limited our
internal control work to gain a basic understanding of the process that Clark used to
account for ARP ESSER funds, including the accounting system and accounting codes
used by Clark. We conducted our review remotely from October 2024 through February
2025. We discussed the results of our review with Clark and Nevada Department of
Education officials on February 5, 2025.
Sampling Methodology
To determine whether Clark expended ARP ESSER grant funds during our review period
for allowable purposes in accordance with applicable requirements, we selected and
reviewed 24 non-personnel expenditures from a total population of 17,592 non-
personnel expenditures using a combination of a risk-based judgmental selection and a
stratified non-statistical random sample process. The 24 expenditures represented
$7.66 million (6 percent) of the total $135.58 5 million in non-personnel ARP ESSER
expenditures during our review period. We selected four expenditures using a
judgmental, risk-based process considering one or a combination of the following
criteria: high-dollar transaction amount, missing supplier, missing purchase order, or
unique descriptions. We selected 20 expenditures using a stratified non-statistical
random sample process. Since the expenditures were selected using both a risk-based
judgmental selection and a stratified non-statistical random sample process, the results
of our testing cannot be projected to the universe of ARP ESSER expenditures.
Use of Computer-Processed Data
We relied on computer-processed data from Clark’s accounting system, which included
data from the LEA’s general ledger. Clark provided us this information in a spreadsheet.
To assess the completeness of the expenditure data in the spreadsheet, we compared
total expenditures in the spreadsheet to the total expenditures in the monthly
expenditure reports that Clark submitted to the Nevada 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 our
5
This did not include $5.90 million in indirect cost during our review period.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0207 4
sample of 24 expenditures. We did not identify any issues and concluded that the
expenditure data in the spreadsheet were reliable for their intended use in this review.
Compliance with Standards
We conducted our work in accordance with the Office of Inspector General quality
control standards and the Council of the Inspectors General on Integrity and Efficiency
“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/F24NY0207 5
Appendix B. Acronyms and Abbreviations
ARP American Rescue Plan
Clark Clark County School District
C.F.R. Code of Federal Regulations
ESSER Elementary and Secondary School Emergency Relief
LEA local educational agency
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0207 6
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