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ED OIG F25CA0219: State and Local Educational Agencies' Use of Digital Wallet-Related Technologies and Services (June 11, 2025)

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               U.S. Department of Education
               Office of Inspector General




State and Local Educational
Agencies’ Use of Digital Wallet-
Related Technologies and
Services
June 11, 2025
ED-OIG/F25CA0219

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



June 11, 2025

TO:       Hayley Sanon
          Acting Assistant Secretary
          Office of Elementary and Secondary Education

FROM:     Keith Cummins /s/
          Acting Deputy Assistant Inspector General for Audit

SUBJECT: Final Flash Report, “State and Local Educational Agencies’ Use of Digital Wallet-Related
         Technologies and Services,” Control Number ED-OIG/F25CA0219

Attached is the subject final report that consolidates the results of our review of “State and Local
Educational Agencies’ Use of Digital Wallet-Related Technologies and Services,” Control Number ED-
OIG/F25CA0219. We have provided an electronic copy to your audit liaison officer. We received your
comments in response to our draft report.

We appreciate your cooperation during this review. If you have any questions, please contact me at
(202) 657-8542 or Keith.Cummins@ed.gov; or Ben Sanders, Director, Elementary and Secondary
Education Oversight Team, at (916) 213-7630 or Ben.Sanders@ed.gov.

Attachment




                                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
State and Local Educational Agencies’ Use of Digital Wallet-Related
Technologies and Services



Why the OIG Performed                     What Did the OIG Find?
This Work                                 Forty-five SEAs responded to our survey regarding the use of digital wallets to facilitate
Digital interactions with government      the administration of Department grant funds. Twelve of those SEAs reported using digital
services have increased over time,        wallets to help administer some of their Department grants during our review period, and
particularly since the start of the       three of these planned to continue using digital wallets in 2025. SEAs primarily relied on
coronavirus pandemic in March 2020.       one digital wallet vendor to help administer their Department grant funds. That vendor,
We learned through prior OIG work         used by 11 of the 12 SEAs, was responsible for helping to administer more than
that some State educational agencies      95 percent of the Department grant funds for which SEAs reported using digital wallets.
(SEA) were using digital wallet-related   SEAs used digital wallets almost exclusively for their pandemic relief Department grants,
technologies and services (digital        including the GEER, EANS, and Elementary and Secondary School Emergency Relief Fund
wallet) to help administer their          (ESSER) grants. SEAs most commonly used digital wallets for automated direct deposit
Governor’s Emergency Education            reimbursement or payment, built in controls for fund use, and tracking of funds; and
Relief Fund (GEER) and Emergency          several SEAs reported that they relied, at least partially, on their digital wallet vendors to
Assistance to Non-Public Schools          help ensure that applicable Federal grant requirements were followed.
(EANS) grants. However, there is
                                          According to the SEAs that responded to our survey, a small number of LEAs used digital
limited public information regarding
                                          wallets to help administer their Department grant funds during our review period. Only
digital wallets and how or to what
                                          one SEA reported that its LEAs used digital wallets, and that SEA further reported that
extent SEAs and local educational
                                          only 5 to 10 LEAs in the State used digital wallets. Although LEAs’ use of digital wallets
agencies (LEA) may be using them for
                                          appeared to be limited based on the survey results, the full extent of LEAs’ digital wallet
their Federal education grants.
                                          usage is not known since 6 SEAs did not complete the survey and 15 of the 45 respondent
We performed this review to               SEAs reported that they did not know whether their LEAs used digital wallets to help
determine the extent to which SEAs        administer Department grant funds.
and LEAs use digital wallets to
                                          What Are the Next Steps?
facilitate the administration of
                                          Because our report presents information on digital wallets that SEAs provided through the
U.S. Department of Education
(Department) grant funds. Our review      survey, it does not include recommendations. This informational report provides insights
covered the period from October 1,        into the extent of SEAs’ and LEAs’ use of digital wallets during our review period and their
2022, through December 31, 2024.          planned use of digital wallets in 2025, information that may be of interest to key
                                          stakeholders, including the Department, SEAs and LEAs, students and their parents,
For purposes of this review, we define
                                          Congress, and the general public.
“digital wallet” as a software-based
process provided by a third-party         We provided a draft of this report to the Office of Elementary and Secondary Education
vendor that facilitates the
                                          (OESE) for comment. We summarize OESE’s comments at the end of the “What We
disbursement to or expenditure of
                                          Found” section and provide the full text of the comments at the end of the report (OESE
Federal education grant funds by
                                          Comments). OESE stated that it found the report to be informative and helpful for the
beneficiaries, such as teachers,
                                          Department and OESE.
students, families, and nonpublic
schools.




                                                 Flash Report                                              ED-OIG/F25CA0219
                  Purpose
                  The objective of our flash review was to determine the extent to which State
                  educational agencies (SEA) and local educational agencies (LEA) use digital wallet-
                  related technologies and services (digital wallet) 1 to facilitate the administration of
                  U.S. Department of Education (Department) grant funds. This flash review report
                  presents the results of our review.


                  What We Did
                  We surveyed the SEAs in all 50 States and Washington, D.C. (51 entities total) about
                  their experiences and their LEAs’ experiences using digital wallets to facilitate the
                  administration of Department grant funds from October 1, 2022, through December 31,
                  2024. 2 We achieved an 88 percent response rate based on 45 completed surveys. The
                  survey results represent information provided by the 45 respondent SEAs and should
                  not be projected to the 6 SEAs that did not complete the survey. This report presents
                  information that is focused primarily on the 12 SEAs that reported using digital wallets. 3
                  We also held post-survey case study follow-up discussions with four SEAs that we
                  judgmentally selected to further explore their responses to survey questions and
                  provide contextual information. We selected these four SEAs for follow-up discussions
                  because they either reported information that was unique in some way or were easily
                  accessible and willing to share additional information with us (see the Methodology
                  section for additional information regarding our judgmental selections).

                  Each respondent SEA reported whether it and its LEAs used digital wallets to help
                  administer Department grant funds. The SEAs using digital wallets reported additional
                  information, which in part included the digital wallet vendors used and for which
                  Department grants, the amount of funds administered using digital wallets by




1
 For purposes of this review, we defined “digital wallet” as a software-based process provided by a
third-party vendor that facilitates the disbursement to or expenditure of Federal education grant funds
by beneficiaries, such as teachers, students, families, and nonpublic schools.
2
    See Appendix B for the list of survey questions posed to SEAs.
3
 We do not opine on the pros and cons of digital wallets in this report. Rather, we present and
summarize information on digital wallets that SEAs provided through the survey instrument. See the
Reliability of SEA-Provided Survey Responses section for the work we performed to minimize potential
errors and problems with SEA-reported information.


U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                             1
              Department grant, the features and services provided by digital wallet vendors, and any
              challenges or technical issues that they experienced using digital wallet.


              What We Found
              SEAs used digital wallets more often than LEAs, with 12 (27 percent) of the
              45 respondent SEAs reporting that they used digital wallets to help administer some of
              their Department grants during our review period. Only 1 SEA reported that its LEAs
              used digital wallets, noting that statewide, only 5 to 10 LEAs used digital wallets.
              Although LEAs’ use of digital wallets appeared to be limited based on the survey results,
              the full extent of LEAs’ digital wallet usage is not known since 6 SEAs did not complete
              the survey and a third (15) of the 45 respondent SEAs reported that they did not know
              whether their LEAs used digital wallets during our review period.

              One vendor provided the digital wallet services and technologies for 11 of the 12 SEAs
              that reported using digital wallets and for the vast majority (about 95 percent) of the
              Department grant funds administered by those SEAs with the help of digital wallets.
              With the exception of a Title I, Part A of the Elementary and Secondary Education Act of
              1965 (Title I) grant at one SEA, SEAs used digital wallets exclusively for pandemic relief
              Department grants and primarily to help administer their Emergency Assistance to
              Non-Public Schools (EANS) grants. In the following sections, we summarize information
              reported by SEAs, including information on the vendors used, impacted Department
              grants, and related funding; factors that SEAs considered when selecting vendors;
              commonly used digital wallet features and services; SEA oversight and monitoring of
              digital wallet contracts and vendor performance; SEA feedback on digital wallets and
              vendors and future plans for using digital wallets; and LEAs’ use of digital wallets.

              SEAs’ Use of Digital Wallets
              Collectively, the 12 SEAs that used digital wallets during our review period reported
              using 5 digital wallet vendors to help administer some of their Department grant funds,
              with 3 of the 12 SEAs reporting that they used multiple vendors. The SEAs primarily
              relied on one digital wallet vendor to help administer their Department grant funds, and
              that vendor was responsible for more than 95 percent of the Department grant funds
              for which digital wallets were used across 11 of the 12 SEAs. The SEAs used digital
              wallets almost exclusively for their pandemic relief Department grants, including the
              Governor's Emergency Education Relief Fund (GEER), Elementary and Secondary School
              Emergency Relief Fund (ESSER), and EANS grants. Digital wallets were primarily used for
              pandemic relief Department grants, in part, because some SEAs did not have the
              administrative processes, internal structures, or resources to effectively and timely
              administer those grants, particularly the EANS grant. For example, for EANS, SEAs
              obligated funds and provided services or assistance (including through contractors) to


U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                       2
              eligible nonpublic schools at a level that some SEAs were not accustomed to and thus
              required processes, structures, and resources that some States likely did not have in
              place. Below, we provide two visuals presenting information on Department grant funds
              administered using digital wallets by grant (see Figure 1) and information on the number
              of SEAs using digital wallets and administered grants and funding by vendor (see
              Table 1).

              Figure 1. Funds Administered Using Digital Wallets by Department Grant




U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                    3
                     Table 1. Number of SEAs Using Digital Wallets and Administered Grants and Funding
                     by Vendor

                         Number of       Pandemic Relief     Non-Pandemic Relief     Funding Administered by Digital
             Vendor
                           SEAs              Grant                 Grant                Wallet Vendor (Percent)

                A             11        GEER, EANS, ESSER               -                     $741,301,116
                                                                                              (95.4 percent)

                B             1               ESSER                     -                      $17,020,599
                                                                                               (2.2 percent)
                C             1               ESSER                     -                      $1,437,940
                                                                                               (0.2 percent)

                D             1            EANS, ESSER               Title I 4                 $13,965,992
                                                                                               (1.8 percent)
                E             1               ESSER                     -                      $3,297,000
                                                                                               (0.4 percent)
                 -          Total               -                       -                     $777,022,647
                                                                                              (100 percent)



                     Although SEAs primarily used digital wallets for their pandemic relief Department
                     grants, one SEA used a digital wallet to help administer its Title I (non-pandemic relief)
                     grant funds (see Vendor D in Table 1). The SEA used Title I grant funds to provide high
                     dosage tutoring to students attending eligible Title I schools. The SEA told us that it
                     chose to use a digital wallet for its Title I grant because of the tracking and oversight
                     features built into the digital wallet platform, features that made it easy for the SEA to
                     identify Title I-eligible schools and move funds to cover the cost of services provided to
                     eligible students attending those schools. According to the SEA, the digital wallet
                     platform also provided it with an opportunity to braid Title I grant funds with ESSER
                     grant funds to expand the impact of an academic acceleration initiative that was funded
                     primarily by ESSER. Lastly, the SEA noted that the digital wallet platform helped it to
                     expand student access to tutoring providers and match eligible students with high
                     quality tutoring providers more efficiently and with minimal administrative burden.




4
    One SEA used Vendor D’s digital wallet platform to help administer $4,069,564 in Title I grant funds.


U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                               4
                  Factors SEAs Considered When Selecting Digital Wallet Vendors
                  Seven of the 12 SEAs reported that they selected the digital wallet vendor, in part,
                  because of the vendor’s reputation. Other factors that many SEAs considered were the
                  security features, ease of use of the vendor’s platform, and whether the vendor was the
                  only entity that could perform the services. Table 2 lists the main factors that the
                  12 SEAs considered when selecting digital wallet vendors and the number of SEAs that
                  considered those factors. 5

                  Table 2. Factors that the 12 SEAs Considered When Selecting Digital Wallet Vendors
                                                                                   Number of SEAs that
                                              Factor
                                                                                   Considered the Factor
                   Vendor reputation                                                         7
                   Security features                                                         5
                   Ease of use of the vendor’s platform                                      5
                   Only vendor able to perform services                                      5
                   Highest scoring, lowest cost provider, or both (as determined
                                                                                             3
                   through SEA’s procurement process)
                   Vendor platform could operate well with SEA systems                       2


                  Digital Wallet Features and Services
                  The digital wallet features and services most commonly used by the 12 SEAs were
                  automated direct deposit reimbursement or payment, built in controls for fund use, and
                  tracking of funds. All but one SEA reported using these three features and services.
                  Other features and services commonly used by SEAs were generating reports on fund
                  distribution, receipt and invoicing through the digital wallet vendor platform, online
                  ordering of goods and materials, and use of the digital wallet vendor’s preapproved
                  marketplace. Figure 2 provides a visual representation of the digital wallet features and
                  services commonly used by SEAs and the number (and percent) of SEAs that used them.




5
    SEAs could select multiple factors when completing the survey.


U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                           5
              Figure 2. Digital Wallet Features and Services Commonly Used by the 12 SEAs




              SEA Oversight and Monitoring of Digital Wallet Contracts and
              Vendor Performance
              All 12 SEAs reported that they relied, at least in part, on their own contract monitoring
              activities to ensure that applicable Federal grant requirements were followed. Seven
              SEAs relied exclusively on their own contract monitoring activities, whereas the other
              five SEAs relied on both their own contract monitoring activities and their digital wallet
              vendors to ensure that applicable Federal grant requirements were followed. Additional
              survey results related to SEA oversight and monitoring of digital wallet contracts and
              vendor performance include the following.

                  •   All 12 SEAs reported that they documented in writing the roles and
                      responsibilities of the digital wallet vendors in relation to the goods or services
                      those vendors provided in support of the Department grants.
                  •   Eleven SEAs reported that the digital wallet vendor performed at or above the
                      minimum performance level established in the contract. The remaining SEA
                      selected “neither agree nor disagree” in response to the survey question in this
                      area.
                  •   Nine SEAs reported that they used performance metrics to monitor the digital
                      wallet vendor’s performance against applicable contractual requirements.




U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                            6
              SEA Feedback on Digital Wallets and Vendors, and Future Plans
              SEAs generally reported positive feedback regarding their experiences with digital
              wallets and vendors. For example, during a post-survey case study follow-up discussion
              that we held with an SEA, the SEA told us that using the digital wallet was helpful
              because the digital wallet vendor generated expenditure reports that the SEA could use
              to quickly review and identify unallowable expenses (through sort and search functions).
              That SEA also noted that using the digital wallet reduced the administrative burden and
              number of employees it needed to administer the grant. However, as discussed below,
              two SEAs initially experienced minor technical issues using digital wallets to help
              administer their Department grant funds. A few SEAs reported that they plan to use
              digital wallets in 2025 but not thereafter, generally aligning with when their existing
              pandemic relief grant funds will be fully expended or expire.

              SEAs’ Challenges and Issues with Digital Wallets and Vendors
              Two of the 12 SEAs reported that while using digital wallets, they experienced technical
              issues related to application usability, user interface, and functionality of the vendors’
              platforms that required significant modifications to meet SEA requirements and align
              with agency processes. One SEA used two different digital wallet vendors to help
              administer its EANS and ESSER grants, and it reported having technical challenges with
              both vendors. During a post-survey case study follow-up discussion that we held with
              this SEA, the SEA told us that it needed a digital wallet platform that would
              accommodate its reimbursement payment processes and enable it to pay entities for
              goods and materials after receiving those items. Initially, neither vendor had a digital
              wallet platform that included the reimbursement payment functionality that the SEA
              needed. However, the SEA told us that it worked closely with both vendors to modify
              the functionality of their platforms to accommodate the SEA’s reimbursement payment
              processes. Another SEA reported (through its completed survey) that initially the digital
              wallet vendor did not always follow established controls. However, because the SEA
              held weekly meetings with the vendor, the SEA was able to identify this issue early on
              and worked with the vendor to timely correct things.




U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                       7
                  SEAs’ Planned Use of Digital Wallets in 2025
                  Three of the 12 SEAs reported that they plan to continue using digital wallets in 2025.
                  They plan to continue using digital wallets to help administer their remaining EANS and
                  ESSER grant funds. 6 We followed up with one of the other nine SEAs to better
                  understand why it did not plan to use digital wallets in 2025 and beyond. According to
                  an SEA official working in external affairs, the SEA used a digital wallet for its EANS grant
                  because it had not previously administered a grant similar to EANS and it did not have
                  the internal structure or processes in place to administer such a grant. The official noted
                  that once the SEA fully expended its EANS grant funds, it no longer had a need for the
                  digital wallet services unique to EANS.

                  LEAs’ Use of Digital Wallets
                  The full extent of LEAs’ use of digital wallets is not known because 6 SEAs did not
                  complete the survey and 15 (33 percent) of the 45 respondent SEAs reported that they
                  did not know if their LEAs used digital wallets. However, based on information provided
                  by the 30 respondent SEAs with knowledge of their LEAs’ use of digital wallets, LEAs did
                  not appear to use digital wallets to help administer Department grant funds very often.
                  In fact, only one SEA reported having LEAs that used digital wallets during our review
                  period. 7 That SEA further reported that only about 5 to 10 LEAs used digital wallets,
                  representing less than 7 percent of the 156 LEAs in the State and 0.1 percent of the
                  9,994 LEAs across the 30 respondent SEAs knowledgeable about their LEAs’ use of
                  digital wallets.

                  How LEAs Used Digital Wallets
                  The SEA reported that the LEAs used digital wallets to help administer both their Federal
                  (for example, Title I) and State and local program funds. The SEA added that LEAs used
                  digital wallets primarily for ordering goods and materials, noting that the digital wallet



6
  After our survey was administered, the Department notified all chief state school officers that it was
modifying the time period to liquidate obligations under the Education Stabilization Fund, including
ESSER, GEER, EANS, and all other programs funded by the Coronavirus Response and Relief
Supplemental Appropriations and American Rescue Plan acts, to end on March 28, 2025. In response to
this action, 16 States and the District of Columbia filed a lawsuit against the Department on April 10,
2025, and a related motion for preliminary injunction on April 11, 2025. On May 6, 2025, a federal judge
issued a preliminary injunction order that, in part, temporarily prohibited the Department from
enforcing the March 28, 2025, liquidation deadline against the 16 States and District of Columbia while
the case was being litigated or until further court order.
7
    Twenty-nine SEAs reported that their LEAs did not use digital wallets during our review period.


U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                             8
                vendor provided a platform for teachers 8 working in those districts to purchase
                materials and supplies from office and school supply vendors online and receive them
                quickly. According to the SEA, the platform also provided authorized school personnel in
                those LEAs with access to a dashboard displaying key financial information, including the
                status of purchases and remaining funds available. These LEAs plan to continue using
                digital wallets in this manner for the foreseeable future.

                Office of Elementary and Secondary Education Comments
                The Office of Elementary and Secondary Education (OESE) stated that it was interesting
                to understand the extent of survey respondents’ usage of digital wallet applications and
                helpful for the Department and OESE to know that some SEAs and LEAs still intend to
                continue using these technologies for funds management until the closeout of the
                applicable grants.




8
 Teachers submit their purchase requests, which are subject to review and approval by school
administrators prior to purchase, through the digital wallet platform. School administrators review the
purchase requests for allowability and compliance with applicable requirements.


U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                          9
               Appendix A. Scope and Methodology
               Our review covered SEAs’ and LEAs’ use of digital wallets to facilitate the administration
               of Department grant funds from October 1, 2022, through December 31, 2024. We
               limited our review to the SEAs (and their LEAs) in the 50 U.S. States and District of
               Columbia (51 SEAs total). We conducted our review remotely from December 2024
               through April 2025. We discussed the results of our review with officials from OESE and
               the Department’s Office of the General Counsel on April 23, 2025.

               Methodology
               To accomplish our objective, we first gained a basic understanding of digital wallets and
               how they could be used to help administer Federal education grants by reviewing
               publicly available information. We then developed a web-based survey with questions
               designed to obtain key information about SEAs’ and LEAs’ use of digital wallets. To
               ensure that the survey questions would be interpreted in the way we intended and
               provide the information we sought, we (1) tested the survey internally, (2) shared a
               draft of the survey with OESE and solicited feedback on the survey instructions and
               questions, and (3) piloted the survey and spoke with two SEAs to obtain feedback on
               their experience answering survey questions and using the web-based survey. We
               refined the survey as needed based on the feedback provided by OESE and the two pilot
               SEAs. Next, we distributed the refined survey to the remaining 49 SEAs and requested
               that they complete the survey. 9

               We then reviewed the responses provided by the 45 SEAs that completed the survey
               and identified four SEAs as good candidates for post-survey case study follow-up
               discussions to further explore their responses to survey questions and provide
               contextual information. We judgmentally selected the four SEAs for follow-up
               discussions because they either reported information that was unique in some way or
               were easily accessible and willing to share additional information with us. Specifically,
               we selected the four SEAs based on the following.

                   o   SEA 1. Only SEA to use a digital wallet for a non-pandemic relief Department
                       grant (Title I grant).
                   o   SEA 2. Only SEA with LEAs that used a digital wallet to help administer their
                       Department grant funds.




9
 We did not send the refined survey to the two pilot SEAs because we concluded that they had already
provided the requested information as part of the pilot testing of the survey.


U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                           10
                  o   SEA 3. SEA reported having challenges with multiple digital wallet vendors and
                      platforms.
                  o   SEA 4. SEA was one of the two pilot SEAs, and thus easily accessible and willing
                      to provide additional information about its experience with digital wallets.
              Lastly, we summarized the survey responses and case study information in ways that
              could be easily understood and interpreted by readers of this report. Our survey
              primarily covered (1) the number of SEAs that used digital wallets, the vendors used,
              and the Department grants and related funding amounts administered by SEAs using
              digital wallets; (2) the factors SEAs considered when selecting vendors; (3) the digital
              wallet features and services commonly used by SEAs; (4) SEA oversight and monitoring
              of digital wallet contracts and feedback on digital wallets and vendor performance,
              including challenges faced; and (5) LEAs’ use of digital wallets.

              Reliability of SEA-Provided Survey Responses
              We did not independently verify the accuracy of the SEAs’ self-reported information,
              but we took a series of steps—from survey development through survey review and
              analysis—to minimize potential errors and problems. To identify the survey questions,
              we held several internal discussions with OIG team members and senior officials and
              spoke with subject matter experts such as OESE and SEAs. To improve the survey (as
              needed) and verify the clarity, length of time of administration, and understandability of
              the survey questions, we piloted the survey to two SEAs and solicited their feedback. To
              identify obvious or material technical errors in reporting, we examined survey responses
              for missing data, irregularities, and input errors; and followed up with the applicable
              SEAs and performed additional research as needed to resolve those reporting errors.

              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/F25CA0219                                                                                       11
              Appendix B. Survey Questions for SEAs
              Section I. Identifying Questions
              1.   Name of SEA.
              2.   Name of the person completing the survey.
              3.   Job title of the person completing the survey.
              4.   Phone number of the person completing the survey.
              5.   Email address of the person completing the survey.

              Section II. SEA’s Use of Digital Wallet-Related Technologies and Services
              6. Did the SEA use digital wallets to facilitate the administration of U.S. Department of
                 Education grant funds between October 1, 2022, and December 31, 2024?
                 (Check one.)
                   ☐ Yes.
                   ☐ No. (proceed to Question No. 19)
                   ☐ Other. (Please explain.)
              7. For which U.S. Department of Education grants does/did the SEA use digital wallets?
              8. For the U.S. Department of Education grants identified in Question No. 7, please list
                 which vendor(s) the SEA uses/used for digital wallets, the date (month and year) the
                 SEA began using the vendor(s), and the amount of grant funds that the vendor
                 administered (disbursed or processed).
              9. What goods or services do/did the digital wallet vendors typically provide for the
                 SEA? (Check all that apply.)
                   ☐ Automated direct deposit reimbursement or payment.
                   ☐ Tracking of funds.
                   ☐ Reports on fund distribution.
                   ☐ Built in controls for fund use.
                   ☐ Ordering of goods or materials.
                   ☐ Receipts and invoices submitted through platform.
                   ☐ Preapproved marketplace.
                   ☐ Other. (Please explain.)
              10. Has the SEA experienced any problems or challenges using digital wallets to
                  facilitate the administration of U.S. Department of Education grant funds?
                   ☐ Yes.
                   ☐ No. (proceed to Question No. 12)
                   ☐ Other. (Please explain.)




U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                      12
              11. What digital wallet-related problems or challenges has the SEA experienced?
                  (Check all that apply.)
                  ☐ Privacy or security concerns/challenges.
                  ☐ Technical issues or other challenges related to application usability and user
                    interface.
                  ☐ Inadequate technical support from the digital wallet vendor.
                  ☐ Digital wallet vendor not fulfilling one or more of its contractual obligations.
                  ☐ Other. (Please explain.)
              12. Does the SEA identify the digital wallet vendors as contractors or subrecipients?
                  (Check one.)
                  ☐ Contractors.
                  ☐ Subrecipients.
                  ☐ Other. (Please explain.)
              13. When digital wallets are used, how does the SEA ensure that applicable U.S.
                  Department of Education grant requirements are being followed? (Check one.)
                  ☐ The SEA conducts its own contract or subrecipient monitoring activities to
                    ensure that applicable Federal grant requirements are followed.
                  ☐ The SEA relies on the digital wallet vendors to ensure that applicable Federal
                    grant requirements are followed.
                  ☐ The SEA conducts its own contract or subrecipient monitoring activities AND
                    relies on the digital wallet vendors to ensure that applicable Federal grant
                    requirements are followed.
                  ☐ Other. (Please explain.)

              Most Recent Digital Wallet Vendor Experience
              14. What goods or services does/did the digital wallet vendor provide to the SEA?
                  (Check all that apply.) Note: Please answer this question based on the SEA’s
                  experience with the digital wallet vendor that it most recently executed a contract
                  with.
                  ☐ Automated direct deposit reimbursement or payment.
                  ☐ Tracking of funds.
                  ☐ Reports on fund distribution.
                  ☐ Built in controls for fund use.
                  ☐ Ordering of goods or materials.
                  ☐ Receipts and invoices submitted through platform.
                  ☐ Preapproved marketplace.
                  ☐ Other. (Please explain.)




U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                       13
              15. Has the SEA documented in writing the roles and responsibilities of the digital wallet
                  vendors in relation to the goods or services those vendors provide in support of the
                  U.S. Department of Education grant? (Check one.) Note: Please answer this question
                  based on the SEA’s experience with the digital wallet vendor that it most recently
                  executed a contract with.
                  ☐ Yes.
                  ☐ No.
                  ☐ Other. (Please explain.)
              16. Does/Did the SEA use performance metrics to monitor the digital wallet vendor’s
                  performance against applicable contractual requirements? (Check one.)
                  Note: Please answer this question based on the SEA’s experience with the digital
                  wallet vendor that it most recently executed a contract with.
                  ☐ Yes.
                  ☐ No.
                  ☐ Other. (Please explain.)
              17. Why did the SEA choose the selected digital wallet vendor? (Check all that apply.)
                  Note: Please answer this question based on the SEA’s experience with the digital
                  wallet vendor that it most recently executed a contract with.
                  ☐ Vendor reputation.
                  ☐ Security features.
                  ☐ Could operate well with SEA systems.
                  ☐ Ease of use of the vendor’s platform.
                  ☐ Only vendor available to perform the required services.
                  ☐ Other. (Please explain.)
              18. Please provide your level of agreement with this statement: “The SEA’s digital wallet
                  vendor performs/performed at or above the minimum performance level
                  established in the contract.” (Check one.) Note: Please answer this question based
                  on the SEA’s experience with the digital wallet vendor that it most recently executed
                  a contract with.
                  ☐ Strongly Agree.
                  ☐ Agree.
                  ☐ Neither agree nor disagree.
                  ☐ Disagree.
                  ☐ Strongly Disagree.




U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                       14
              Future Plans (if applicable)
              19. Does the SEA plan to use or continue to use the services of a digital wallet vendor to
                  facilitate the administration of U.S. Department of Education grant funds during
                  calendar year 2025? Note: Please answer this question based on the SEA's future
                  plans to use digital wallets (if applicable).
                  ☐ Yes.
                  ☐ No. (proceed to Question No. 22)
              20. Please list the name of the digital wallet vendor(s) and for which U.S. Department of
                  Education grants the SEA plans to use digital wallet-related services and
                  technologies during calendar year 2025. Note: Please answer this question based on
                  the SEA's future plans to use digital wallets (if applicable).
              21. What goods or services will the digital wallet vendor provide to the SEA in 2025?
                  (Check all that apply.) Note: Please answer this question based on the SEA's future
                  plans to use digital wallets (if applicable).
                  ☐ Automated direct deposit reimbursement or payment.
                  ☐ Tracking of funds.
                  ☐ Reports on fund distribution.
                  ☐ Built in controls for fund use.
                  ☐ Ordering of goods or materials.
                  ☐ Receipts and invoices submitted through platform.
                  ☐ Preapproved marketplace.
                  ☐ Other. (Please explain.)

              Section III. Other State Agencies’ Use of Digital Wallet-Related Technologies and
              Services
              22. Is the SEA aware of any other state agencies that used digital wallets to facilitate the
                  administration of U.S. Department of Education grant funds between October 1,
                  2022, and December 31, 2024?
                  ☐ Yes.
                  ☐ No. (proceed to Question No. 25)
                  ☐ Other. (Please explain.)
              23. Which other state agencies used digital wallets to facilitate the administration of
                  U.S. Department of Education grant funds? (Provide the name of the state agency)
              24. For which U.S. Department of Education grants did the other state agencies use
                  digital wallets?




U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                       15
              Section IV. LEAs’ Use of Digital Wallet-Related Technologies and Services
              25. Do any LEAs in your State use digital wallets to facilitate the administration of U.S.
                  Department of Education grant funds? (Check one.)
                  ☐ Yes.
                  ☐ No. (proceed to Question No. 29)
                  ☐ Other. (Please explain.)
              26. How many LEAs (or approximately how many LEAs, if the exact number is not
                  known) use digital wallets to facilitate the administration of U.S. Department of
                  Education grant funds? (Please provide the number or approximate number of LEAs
                  using digital wallets.)
              27. For which U.S. Department of Education grants do the LEAs use digital wallets to
                  facilitate the administration of U.S. Department of Education grant funds?
              28. What goods or services do the digital wallet vendors typically provide for the LEAs?
                  (Check all that apply.)
                  ☐ Automated direct deposit reimbursement or payment.
                  ☐ Tracking of funds.
                  ☐ Reports on fund distribution.
                  ☐ Built in controls for fund use.
                  ☐ Ordering of goods or materials.
                  ☐ Receipts and invoices submitted through platform.
                  ☐ Preapproved marketplace.
                  ☐ Other. (Please explain.)

              Section V. Additional Information (optional)
              29. Please provide any additional comments or clarifying information regarding the
                  survey or your survey responses, if desired or as needed. (If a comment is related to
                  a specific question, please include the question number in your response.)




U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                       16
              Appendix C. Acronyms and Abbreviations
               Department       U.S. Department of Education

               digital wallet   digital wallet-related technologies and services

               EANS             Emergency Assistance to Non-Public Schools

               ESSER            Elementary and Secondary School Emergency Relief Fund

               GEER             Governor's Emergency Education Relief Fund

               LEA              local educational agency

               OESE             Office of Elementary and Secondary Education

               SEA              State educational agency

               Title I          Title I, Part A of the Elementary and Secondary Education Act
                                of 1965




U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219                                                                                17
              OESE Comments




U.S. Department of Education
Office of Inspector General
ED-OIG/F25CA0219               18


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