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Douglas County School District's Use of Elementary and Secondary School Emergency Relief Funds (ED-OIG/F24NY0205)

Summary

A final flash report, ED-OIG/F24NY0205, dated March 31, 2025, from the U.S. Department of Education Office of Inspector General on Douglas County School District's use of Elementary and Secondary School Emergency Relief Funds. The OIG reports that Douglas was allocated approximately $4.1 million in ARP ESSER funds and that of the 16 expenditures it reviewed, 12 were allowable, and that four expenditures totaling $5,416 were unallowable because they were for advertising and public relations costs prohibited under 2 C.F.R. section 200.421(e). The OIG recommends that the Nevada Department of Education require Douglas to return the $5,416 to the U.S. Department of Education or reallocate the funds to other allowable costs, and the Nevada Department of Education agreed with the finding and recommendation.

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Issuer
U.S. Department of Education, Office of Inspector General
Document type
Report
Date
2025-03-31

Cite this document

“Douglas County School District's Use of Elementary and Secondary School Emergency Relief Funds (ED-OIG/F24NY0205).” U.S. Department of Education, Office of Inspector General, dated 2025-03-31. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/douglas-county-school-district-esser/, SHA-256 88371235e61c65885fa796aebd961a6de064f1d2f9e3a42dc169517d4f141249.

Full text

               U.S. Department of Education
               Office of Inspector General



Douglas County School District’s
Use of Elementary and Secondary
School Emergency Relief Funds
March 31, 2025
ED-OIG/F24NY0205

FLASH REPORT
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



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, “Douglas County School District’s Use of Elementary and Secondary School
Emergency Relief Funds,” Control Number ED-OIG/F24NY0205. 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 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
 Douglas 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 of the 16 expenditures that we reviewed, 12 were allowable and in
Congress passed three coronavirus relief   accordance with applicable requirements. Four expenditures totaling $5,416 were
acts within a 1-year period that           unallowable because they were for advertising and public relations costs prohibited under
provided more than $275 billion for an     the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Education Stabilization Fund to prevent,   Federal Awards (2 Code of Federal Regulations part 200).
prepare for, and respond to the            Additionally, we found that Douglas complied with key Federal procurement
coronavirus, which the President           requirements, including those covering the procurement methods to be followed and
declared as a national emergency in        contract cost, price, and provisions, when procuring the goods or services associated with
March 2020. This included $189.5 billion   each ARP ESSER expenditure we reviewed.
for Elementary and Secondary School
Emergency Relief (ESSER), funds            What Is the Impact?
intended to provide vital support to       Payments made for prohibited advertising and public relations costs are considered
States, local educational agencies, and    improper payments. Improper payments can negatively impact the integrity of Federal
schools to address the impact of the       programs, erode public trust in a non-Federal entity such as a local educational agency,
coronavirus. Support, in part, includes    and waste taxpayer resources.
activities designed to help students and
                                           What Are the Next Steps?
educators safely return to and sustain
                                           We made one recommendation to address the unallowable expenditures that we
in-person instruction, and that address
                                           identified to ensure ARP ESSER funds are used in accordance with applicable
the educational inequities exacerbated
                                           requirements.
by the coronavirus pandemic and
students’ social, emotional, mental        The Nevada Department of Education agreed with our finding and recommendation. We
health, and academic needs.                summarized the Nevada Department of Education’s comments and provided the OIG’s
                                           response at the end of the finding. We also provided the Nevada Department of
Ensuring that ESSER funds are used for
                                           Education’s comments at the end of the report (see Nevada Department of Education
allowable purposes is critical to help
                                           Comments).
address the needs of students and
educators. The Douglas County School
District (Douglas) was allocated
approximately $4.1 million in American
Rescue Plan (ARP) ESSER funds to
support 16 schools serving about
5,312 students.
We performed this review to determine
whether Douglas expended ARP ESSER
grant funds for allowable purposes in
accordance with applicable
requirements.




                                              Final Flash Report                                          ED-OIG/F24NY0205
                Purpose
                The objective of this flash review was to determine whether the Douglas County School
                District (Douglas) 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.

                Douglas County School District
                Douglas County School District, located in Minden, Nevada, is a local educational agency
                (LEA) in a distant town setting with 16 schools serving about 5,312 students.
                Douglas was allocated approximately $4.1 million in ARP ESSER funds and as of
                November 29, 2024, had expended 100 percent of its funds. According to Nevada’s
                Federal Relief Tracker, Douglas budgeted 41.9 percent of funds for staff, 26.8 percent
                for supplies, 28.7 percent for services, and 2.6 percent for other purposes. 2 Douglas’
                approved ARP ESSER plan was to use its funds, in part, to address learning loss as a
                result of the coronavirus pandemic by investing in instructional strategies; teacher
                training; educational technology; and support for instructional skills recovery. The
                remainder of its funds were to be used, in part, for providing social and emotional
                mental health services, summer learning, and supplemental after school programs;
                purchasing cleaning supplies; and cleaning facilities.




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 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
 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/F24NY0205                                                                                       1
               What We Did
               We selected and reviewed 16 non-personnel ARP ESSER expenditures (30 percent) from
               a total population of 53 non-personnel expenditures for the period July 1, 2023, through
               June 30, 2024. 3 We used a judgmental, risk-based process to select 6 of these
               expenditures and a non-statistical random sample process to select the other
               10 expenditures. The 16 expenditures represented $1,044,260 (90 percent) of the total
               $1,158,197 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
               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 law 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 Douglas 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 non-personnel expenditure. We interviewed Douglas 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.


               What We Found
               We determined that of the 16 expenditures reviewed, 12 (75 percent) were allowable
               and in accordance with applicable requirements. Four (25 percent) expenditures
               totaling $5,416 were unallowable because they were for advertising and public relations
               costs prohibited under 2 C.F.R. section 200.421(e). Additionally, we found that Douglas
               complied with key Federal procurement requirements, including those covered under
               2 C.F.R. sections 320 (methods of procurement to be followed); 200.324 (contract cost



3
 We limited the scope of our review to non-personnel expenditures; personnel expenditures were
excluded because Douglas’ non-personnel expenditures represented 97 percent of the total
expenditures within our review period.


U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0205                                                                                       2
              and price); and 200.327 (contract provisions) when procuring the goods or services
              associated with each ARP ESSER expenditure.

              Unallowable Expenditures
              Douglas improperly charged $5,416 to its ARP ESSER grant for four expenditures for
              advertising and public relations costs. Douglas categorized these expenditures—which
              included apparel for district staff, a working lunch, parade registration, and pins for
              years of service—as being for “activities necessary to maintain the operation and
              continuity of services, employing existing staff, and coordinating activities.” However,
              the expenditures were associated with an LEA marketing project that involved Douglas
              contracting for services to “develop branding, marketing, promotion, and
              communication with current and prospective stakeholders.” Further, Douglas did not
              explain how this use of funds helped the district prevent, prepare for, or respond to the
              coronavirus pandemic. The Uniform Administrative Requirements, Cost Principles, and
              Audit Requirements for Federal Awards (2 C.F.R. part 200) provides for specific
              circumstances under which costs for advertising and public relations are allowable, and
              U.S. Department of Education guidance on the ESSER program identifies various types of
              outreach to students and families as permissible uses of grant funds. However, based on
              our review of all available information, we concluded that these four expenditures were
              unallowable.

              According to 2 C.F.R. section 200.421(e), unallowable advertising and public relations
              costs include, among other things, costs of meetings or other events related to other
              activities of the entity, including displays, demonstrations, and exhibits; costs of
              promotional items and memorabilia; and costs of advertising and public relations
              designed solely to promote the recipient or subrecipient. Therefore, these expenditures
              should not have been charged to the ARP ESSER grant or any other Federal grant.

              Although no other expenditures we reviewed were improperly charged to the ARP
              ESSER grant, there may have been improper charges to one of the LEA’s ARP ESSER or
              other Federal grants in periods not covered by our review. Improper payments can
              negatively impact the integrity of Federal programs, erode public trust in non-Federal
              entities such as LEAs, and waste taxpayer resources.




U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0205                                                                                       3
              What We Recommend
              We recommend that the Acting Assistant Secretary for the Office of Elementary and
              Secondary Education require the Nevada Department of Education to require Douglas
              to—

                  1. Return to the U.S. Department of Education the $5,416 that Douglas improperly
                     charged to the ARP ESSER grant for its LEA marketing project or reallocate the
                     funds to other allowable costs. Identify any additional improper charges to the
                     ARP ESSER grant for the LEA marketing project, including those made during
                     periods not covered by our review, and if applicable, return the funds to the
                     U.S. Department of Education or reallocate them to other allowable costs.

              Nevada Department of Education’s Comments
              The Nevada Department of Education agreed with the finding and recommendation.
              The Nevada Department of Education stated that it implemented corrective actions for
              Douglas to return the $5,416 improperly charged to the ARP ESSER grant. This included
              issuing a management letter with the current status and progress on addressing the
              finding, with an expectation that Douglas’ repayment will be completed by June 1, 2025.

              OIG Response
              The Nevada Department of Education’s proposed corrective actions, if implemented as
              described, are partially responsive to our recommendation. Its planned return of funds
              identified as improperly charged to the ARP ESSER grant is responsive to the first part of
              our recommendation. However, its proposed corrective actions do not address the
              second part of our recommendation, which recommends that the Nevada Department
              of Education identify any additional improper charges to the ARP ESSER grant for the
              LEA marketing project, including those made during periods not covered by our review,
              and if applicable, return the funds to the U.S. Department of Education or reallocate
              them to other allowable costs.




U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0205                                                                                       4
              Appendix A. Scope and Methodology
              Our review covered Douglas’ 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 Douglas’ ARP ESSER funds represented the highest dollar amount
              ($4.1 million) of all ESSER funds ($6.5 million) that were allocated to them. We also
              limited our internal control work to gain a basic understanding of the process that
              Douglas used to account for ARP ESSER funds, including the accounting system and
              accounting codes used by Douglas. We conducted our review remotely from
              October 2024 through January 2025. We discussed the results of our review with
              Douglas officials on January 14, 2025.

              Sampling Methodology
              To determine whether Douglas expended ARP ESSER grant funds during our review
              period for allowable purposes in accordance with applicable requirements, we selected
              and reviewed 16 non-personnel expenditures (30 percent) from a total population of
              53 non-personnel expenditures using a combination of judgmental, risk-based and non-
              statistical random sample processes. The 16 expenditures represented $1,044,260
              (90 percent) of the total $1,158,197 in non-personnel ARP ESSER expenditures during
              our review period. We selected 6 of these 16 expenditures using a judgmental, risk-
              based process in which we considered 1 or more of the following criteria: high-dollar
              transaction, vague purchase description, or unique vendor description. We selected the
              other 10 expenditures using a non-statistical random sample process. Since the
              expenditures were selected using both judgmental, risk-based and non-statistical
              random sample processes, 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 Douglas’ accounting system, which
              included data from the LEA’s general ledger. Douglas provided this information in a PDF
              document, which we converted to 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 four quarterly expenditure reports that
              Douglas 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 sample of
              16 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.




U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0205                                                                                      5
              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/F24NY0205                                                                                        6
              Appendix B. Acronyms and Abbreviations
               ARP             American Rescue Plan

               C.F.R.          Code of Federal Regulations

               Douglas         Douglas County School District

               ESSER           Elementary and Secondary School Emergency Relief

               LEA             local educational agency




U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0205                                                                  7
              Nevada Department of Education’s Comments




U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0205                                          8


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