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Illinois' Oversight of Local Educational Agency ARP ESSER Plans and Spending (ED-OIG/A22CA0133)

Summary

Final audit report Illinois' Oversight of Local Educational Agency ARP ESSER Plans and Spending, Control Number ED-OIG/A22CA0133, issued March 27, 2024 by the U.S. Department of Education Office of Inspector General, Audit Services, in a letter to State Superintendent of Education Dr. Tony Sanders. The report states that Illinois generally had adequate processes to ensure that LEA ARP ESSER plans met applicable requirements, but that 434 (54 percent) of 801 LEAs did not submit plans within a reasonable timeframe under Department guidance. It states that Illinois' process for reviewing reimbursement requests could be strengthened because it does not review supporting documentation. It makes recommendations to the Assistant Secretary for the Office of Elementary and Secondary Education, and states that Illinois agreed with both findings and the related recommendations.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Issuer
U.S. Department of Education, Office of Inspector General
Document type
Report
Date
2024-03-27

Cite this document

“Illinois' Oversight of Local Educational Agency ARP ESSER Plans and Spending (ED-OIG/A22CA0133).” U.S. Department of Education, Office of Inspector General, dated 2024-03-27. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/illinois-arp-esser-oversight/, SHA-256 9a59ef79573f0a18cf2954073fb4137063b5af60ce0df0092b6a8232d3b84b22.

Full text

                 U.S. Department of Education
                 Office of Inspector General




Illinois’ Oversight of Local
Educational Agency ARP ESSER
Plans and Spending
March 27, 2024
ED-OIG/A22CA0133

ED OIG Oversight of Coronavirus Response Funds
NOTICE
Statements that managerial practices need improvements, as well as other conclusions
and recommendations in this report, represent the opinions of the Office of Inspector
General. The appropriate Department of Education officials will determine what
corrective actions should be taken.

In accordance with Freedom of Information Act (Title 5, United States Code,
Section 552), reports that the Office of Inspector General issues are available to
members of the press and general public to the extent information they contain is not
subject to exemptions in the Act.
                         UNITED STATES DEPARTMENT OF EDUCATION
                                        OFFICE OF INSPECTOR GENERAL

                                                                                                                     Audit Services



March 27, 2024


Dr. Tony Sanders
State Superintendent of Education
Illinois State Board of Education
100 North 1st Street
Springfield, IL 62777

Dear Superintendent Sanders:
Enclosed is our final report, “Illinois’ Oversight of Local Educational Agency ARP ESSER Plans and
Spending,” Control Number ED-OIG/A22CA0133. This report incorporates the comments you provided in
response to the draft report. The U.S. Department of Education’s policy is to expedite resolution by
timely acting on findings and recommendations. Therefore, if you have any additional comments or
information that you believe may have a bearing on the resolution of this audit, you should send them
directly to the following Department of Education official, who will consider them before taking final
Departmental action on this audit:

        Adam Schott
        Deputy Assistant Secretary for 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




                               400 MARYLAND AVENUE, S.W., WASHINGTON, DC 20202-1510

               Promoting the efficiency, effectiveness, and integrity of the Department’s programs and operations.
Table of Contents
Results in Brief .................................................................................................................... 1
Introduction ........................................................................................................................ 5
Finding 1. Illinois Generally Had Adequate Processes for Reviewing and Approving LEA
ARP ESSER Plans, But Did Not Ensure That Plans Were Submitted Within a Reasonable
Timeframe......................................................................................................................... 12
Finding 2. Illinois’ Process for Reviewing LEA ARP ESSER Reimbursement Requests Could
Be Strengthened in a Key Area ......................................................................................... 21
Appendix A. Scope and Methodology............................................................................... 29
Appendix B. Allowable Uses of ESSER Funds .................................................................... 35
Appendix C. Acronyms and Abbreviations........................................................................ 38
Illinois’ Comments ............................................................................................................ 39
                Results in Brief
                What We Did
                The objectives of the audit were to determine whether the Illinois State Board of
                Education (Illinois) had an adequate oversight process in place to ensure that (1) local
                educational agencies’ (LEA) American Rescue Plan (ARP) Elementary and Secondary
                School Emergency Relief (ESSER) plans met applicable requirements and (2) LEAs use
                ARP ESSER funds in accordance with applicable requirements and their approved LEA
                ARP ESSER plans. Our review covered Illinois’ processes for reviewing and approving LEA
                ARP ESSER plans and overseeing LEAs’ use of ARP ESSER funds from March 24, 2021,
                through March 31, 2023.

                For both objectives, we gained an understanding of Illinois’ processes through
                interviews with key Illinois officials and reviews of relevant documents and records, such
                as written procedures and guidance and technical assistance documents that Illinois
                provided to LEAs. For the first objective, we reviewed the summary results of Illinois'
                review of LEA ARP ESSER application and plan submissions to verify that Illinois
                approved the plans for 801 LEAs that had applied for and received ARP ESSER funds and
                gain an understanding of how often and why plan reviewers did not approve plans. 1 We
                also reviewed the ARP ESSER plans for 16 LEAs to determine whether they met
                applicable requirements. For 2 of the 16 LEAs, Chicago Public School District 299
                (Chicago) and Waukegan Community Unit School District 60 (Waukegan), we reviewed
                additional information (such as ARP ESSER grant applications, plan approval documents,
                and related correspondence) to verify that Illinois followed its established ARP ESSER
                plan review and approval processes and was consistent in how it reviewed and
                approved the two plans. For the second objective, we reviewed samples of ARP ESSER
                expenditures at Chicago and Waukegan to determine whether they used ARP ESSER
                funds in accordance with applicable requirements and their approved LEA ARP ESSER
                plans.

                What We Found
                Illinois generally had adequate processes to ensure that LEA ARP ESSER plans met
                applicable requirements (Finding 1). Illinois communicated clear, accurate, and timely
                guidance and technical assistance to LEAs regarding how to develop and submit their
                ARP ESSER plans and what to include in those plans. However, Illinois did not


1
 Illinois allocated $4.6 billion in ARP ESSER funds to 849 LEAs in July 2021. For this audit, we limited our
review to the 801 LEAs that had applied for and received ARP ESSER funds on or before March 31, 2023.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                           1
               communicate accurate guidance to LEAs regarding when to submit their ARP ESSER
               plans according to U.S. Department of Education (Department) guidance. 2 As a result,
               434 (54 percent) of 801 LEAs did not submit their ARP ESSER plans within a reasonable
               timeframe as provided for in Department guidance, with one LEA submitting its plan to
               Illinois more than 540 days after receiving its allocation. 3 Further, six LEAs still had not
               submitted their ARP ESSER grant application and plan to Illinois as of January 11, 2024,
               more than 2.5 years after the LEAs received their ARP ESSER allocations. Thus, some
               LEAs may not have received critical ARP ESSER funds timely or early enough to
               adequately respond to the impacts of the coronavirus pandemic by addressing students’
               academic, social, emotional, and mental health needs, which was the purpose of the
               ARP ESSER program.

               Illinois approved the ARP ESSER plans for all 801 (100 percent) LEAs that applied for and
               received ARP ESSER funds. We determined that the ARP ESSER plans for all 16 LEAs
               (100 percent) reviewed met applicable requirements 4 and that Illinois followed its
               established ARP ESSER plan review and approval processes and was consistent in how it
               reviewed and approved the plans for Chicago and Waukegan.

               Illinois’ process for reviewing LEA ARP ESSER reimbursement requests could be
               strengthened in a key area to provide additional assurance that LEAs use ARP ESSER
               funds for allowable purposes (Finding 2). While Illinois has been consistent in how it
               oversees LEAs’ use of ARP ESSER funds, it does not request a listing of expenditures or
               review any supporting documentation from LEAs as part of its review of LEA
               reimbursement requests. Without supporting documentation to verify that the
               expenditures are allowable and properly accounted for, there is an increased risk that
               Illinois will not identify or become aware of significant compliance issues involving the
               ARP ESSER program.



2
 The U.S. Department of Education stated in its interim final requirements for the ARP ESSER Fund
(effective April 22, 2021) and State plan template that State educational agencies are responsible for
establishing a deadline for LEAs to submit their ARP ESSER plans that must be reasonable and should be
within no later than 90 days after the LEAs received their ARP ESSER allocation.
3
 Chicago and Waukegan submitted their plans timely (within 90 days of receiving their ARP ESSER
allocation).
4
  The posted plan for one LEA was missing information on how the LEA planned to use ARP ESSER funds.
However, we verified that the plan that Illinois reviewed and approved for the LEA included the missing
information and concluded that the LEA had posted an incomplete version of its plan on its website.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                           2
              The ARP ESSER program was considered a higher risk program for 2022 and 2023
              according to 2 Code of Federal Regulations (C.F.R.) section 200.519(c)(2) and the Office
              of Management and Budget’s 2 C.F.R. Part 200, Appendix XI, Compliance Supplement
              (April 2022 and May 2023). The Pandemic Response Accountability Committee, located
              within the Council of the Inspectors General on Integrity and Efficiency, stated that the
              unprecedented amount of money made available for pandemic relief and quick
              distribution of most funds put the money at a higher risk for fraud. We reviewed a total
              of 26 ARP ESSER expenditures for Chicago and Waukegan (13 expenditures for each LEA)
              and did not identify issues at either LEA. Although we did not identify any issues during
              our review of LEA expenditures, it is still important for Illinois to strengthen its process
              for reviewing LEA ARP ESSER reimbursement requests given ARP ESSER’s designation as
              a higher risk program.

              What We Recommend
              We recommend that the Assistant Secretary for the Office of Elementary and Secondary
              Education require Illinois to (1) direct LEAs that have not yet applied but plan to apply
              for ARP ESSER funds to submit their ARP ESSER grant applications and plans to Illinois as
              soon as possible and (2) design and incorporate into its documented procedures for
              reviewing LEA reimbursement requests, protocols to sample LEA expenditures charged
              to ARP ESSER and review supporting documentation to ensure that applicable Federal,
              State, and local requirements are met.

              Illinois’ Comments and Our Response
              We provided a draft of this report to Illinois for comment. We summarize Illinois’
              comments at the end of each finding and provide the full text of the comments at the
              end of the report (Illinois’ Comments).

              Illinois agreed with both findings and the related recommendations. For
              Recommendation 1.1, Illinois stated that it has and will continue to encourage the
              remaining LEAs to submit their ARP ESSER applications and plans and will provide
              technical support to those LEAs until their submissions are received. For
              Recommendation 2.1, Illinois stated that by June 2024 it will strengthen its LEA
              reimbursement requests protocol by requiring LEAs to provide a listing of their ARP
              ESSER expenditures and supporting documentation and selecting a sample of those
              expenditures for review to determine whether they are allowable. Illinois described at a
              high level the scope and activities associated with that review, which in part would
              include extracting LEA expenditure report samples, conducting pre-monitoring fiscal
              reviews of LEA expenditures against the general ledger and other supporting
              documentation, and verifying allowable or unallowable expenditure items. Illinois’
              proposed actions, if implemented as described, are responsive to our


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                        3
              recommendations. We made clarifying edits to the report in response to technical
              comments provided by the Department.




U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                 4
              Introduction
              Background
              On March 13, 2020, the President declared a national emergency due to the coronavirus
              pandemic. In response, 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, including $189.5 billion for the
              Elementary and Secondary School Emergency Relief Fund (ESSER).

                  •   The Coronavirus Aid, Relief, and Economic Security Act (CARES Act), enacted on
                      March 27, 2020 (Public Law 116-136), provided about $13.2 billion for ESSER to
                      address the impact that the coronavirus had and continues to have on
                      elementary and secondary schools.

                  •   The Coronavirus Response and Relief Supplemental Appropriations Act
                      (CRRSAA), enacted on December 27, 2020 (Public Law 116-260), provided an
                      additional $54.3 billion for ESSER to help State educational agencies (SEA) and
                      local educational agencies (LEA) safely reopen schools, measure and effectively
                      address significant learning loss, and take other actions to mitigate the impact
                      of the coronavirus on the students and families who depend on elementary and
                      secondary schools.
                  •   The American Rescue Plan (ARP), enacted on March 11, 2021 (Public
                      Law 117-2), provided the remaining $122 billion for ESSER to help SEAs and LEAs
                      safely reopen and sustain the safe operation of schools and address the impact
                      of the coronavirus pandemic on students.

              ARP ESSER
              On March 24, 2021, the U.S. Department of Education (Department) awarded about
              $81 billion in ARP ESSER funds to SEAs, about two-thirds of each SEA’s total allocation.
              To receive the remaining funds, each SEA was required to submit a plan to the
              Department’s Office of Elementary and Secondary Education for approval that described
              how the SEA would use ARP ESSER funds to safely reopen schools, support sustained
              access to in-person instruction, and address the academic, social, emotional, and mental
              health needs of students. By December 2021, the Department had approved all SEA
              plans and awarded the remaining $41 billion in ARP ESSER funds to SEAs. The Illinois SEA
              plan was submitted in June 2021 and approved by the Department in August 2021.




U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                     5
                  SEA Reserve
                  Under ARP, SEAs were allowed to reserve up to 10 percent of their total ARP ESSER
                  allocation for use by the SEA. 5 Section 2001(f) of ARP required the SEA to set aside funds
                  for certain activities and interventions that respond to students’ academic, social, and
                  emotional needs and address the disproportionate impact of the coronavirus on student
                  subgroups, with Department guidance emphasizing that SEAs should focus their efforts
                  on underserved student subgroups in particular. Specifically, from its total ARP ESSER
                  allocation, the SEA was required to spend at least

                      •   5 percent for the implementation of evidence-based interventions aimed
                          specifically at addressing learning loss, such as summer learning or summer
                          enrichment, extended day, comprehensive afterschool programs, or extended
                          school year programs;

                      •   1 percent for evidence-based summer enrichment programs; and
                      •   1 percent for evidence-based comprehensive afterschool programs.
                  Additionally, an SEA could use up to one-half of 1 percent of its total ARP ESSER
                  allocation for administrative costs. The remainder of funds, up to 3 percent depending
                  on the amount otherwise reserved, may be used for emergency needs as determined by
                  the State to address issues related to the coronavirus pandemic.

                  Subgrants to LEAs
                  Section 2001(d)(1) of ARP required SEAs to allocate at least 90 percent of their total ARP
                  ESSER allocation to LEAs in the State to help meet a wide range of needs arising from
                  the coronavirus pandemic, including reopening schools safely, sustaining their safe
                  operation, and addressing students’ social, emotional, mental health, and academic
                  needs resulting from the pandemic. SEAs were required to allocate ARP ESSER funds to
                  LEAs based on their respective shares of funds received under Title I, Part A of the
                  Elementary and Secondary Education Act of 1965 (ESEA) in fiscal year (FY) 2020.
                  Additionally, SEAs were required to allocate ARP ESSER funds to LEAs in an expedited
                  and timely manner and, to the extent practicable, no later than 60 days after receiving
                  their ARP ESSER funds.

                  LEAs’ ARP ESSER Plans
                  The interim final requirements (IFR) for the ARP ESSER Fund, effective April 22, 2021,
                  require each LEA receiving ARP ESSER funds to develop and submit to the SEA a plan for



5
    ARP sections 2001(d) and (f).


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                           6
                  the LEA’s use of ARP ESSER funds. 6 The LEA must submit the plan in accordance with the
                  procedures and deadline established by the SEA 7 and make the plan publicly available
                  on the LEA’s website. At a minimum, the LEA ARP ESSER plan must describe

                      •   the extent to which and how the funds will be used to implement prevention
                          and mitigation strategies that are, to the greatest extent practicable, consistent
                          with the most recent Centers for Disease Control and Prevention (CDC) guidance
                          on reopening schools, in order to continuously and safely open and operate
                          schools for in-person learning;

                      •   how the LEA will use the funds it reserves under section 2001(e)(1) of ARP to
                          address the academic impact of lost instructional time through the
                          implementation of evidence-based interventions, such as summer learning or
                          summer enrichment, extended day, comprehensive afterschool programs, or
                          extended school year;
                      •   how the LEA will spend its remaining ARP ESSER funds consistent with section
                          2001(e)(2) of ARP; and
                      •   how the LEA will ensure that the interventions it implements, including but not
                          limited to the interventions implemented under section 2001(e)(1) of ARP to
                          address the academic impact of lost instructional time, will respond to the
                          academic, social, emotional, and mental health needs of all students, and
                          particularly those students disproportionately impacted by the coronavirus
                          pandemic, including students from low-income families, students of color,
                          English learners, children with disabilities, students experiencing homelessness,
                          children in foster care, and migratory students.
                  The IFR for ARP ESSER required an LEA to engage in meaningful consultation with
                  stakeholders when developing its plan. These stakeholders include but are not limited to
                  students, families, teachers, school and district administrators, and unions. An LEA was
                  also required to consult with the following stakeholders to the extent present in or
                  served by the LEA: tribes, civil rights organizations (including disability rights
                  organizations), and those representing the interests of children with disabilities, English
                  learners, children experiencing homelessness, children and youth in foster care,



6
    Federal Register, IFR for ARP ESSER, 86 FR 21198.
7
 Per Federal Register, IFR for ARP ESSER, 86 FR 21199, the SEA must establish a deadline for an LEA to
submit its plan that is reasonable and should be no more than 90 days after receiving its ARP ESSER
allocation.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                           7
              migratory students, children who are incarcerated, and other underserved students.
              Additionally, an LEA needed to provide the public with an opportunity to provide input
              on the plan and consider that input as it developed the plan. Lastly, the IFR for ARP
              ESSER required that LEA ARP ESSER plans be accessible, including to parents with limited
              English proficiency and individuals with a disability. The Illinois State Board of Education
              required LEAs to submit their ARP ESSER plans by August 31, 2024.

              LEAs’ Use of ARP ESSER Funds
              Section 2001(e)(1) of ARP requires an LEA to reserve at least 20 percent of its ARP ESSER
              allocation to address the academic impact of lost instructional time (learning loss)
              through the implementation of evidence-based interventions—for example by providing
              intensive or high-dosage tutoring or accelerating learning. LEAs must ensure that the
              interventions respond to students’ academic, social, and emotional needs and address
              the disproportionate impact of the coronavirus on underrepresented student
              subgroups.

              An LEA may use the other 80 percent of its ARP ESSER allocation for a broad range of
              activities, including any activities allowed under the ESEA, Individuals with Disabilities
              Education Act, the Strengthening Career and Technical Education for the 21st Century
              Act, and the Adult Education and Family Literacy Act.

              For example, an LEA may use ARP ESSER funds to

                  •   implement coronavirus prevention strategies to safely reopen schools, maximize
                      in-person instruction, and align with public health guidance, including by
                      upgrading school facilities for healthy learning environments;
                  •   address the mental health needs of students, including using funds to hire
                      counselors and other staff;
                  •   provide integrated student support services, including by using full-service
                      community schools and assisting homeless children and youth in attending and
                      participating in school activities;
                  •   connect elementary and secondary education students to high-quality home
                      internet and devices; and
                  •   stabilize and diversify the educator workforce.
              LEAs can also use ARP ESSER funds for any activity deemed allowable under
              section 18003(d) of the CARES Act and section 313(d) of CRRSAA. See Appendix B for a
              summary of allowable uses of ESSER funds under the CARES Act, CRRSAA, and ARP.




U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                           8
                  Maintenance of Equity
                  Section 2004(b) and (c) of ARP includes new equity requirements, called maintenance of
                  equity (MOEquity), that are a condition for SEAs and LEAs receiving ARP ESSER funds.
                  MOEquity provisions help ensure that schools and LEAs serving large proportions of
                  historically underserved groups of students receive an equitable share of State and local
                  funds. MOEquity requirements ensure that in FYs 2022 and 2023 an SEA does not
                  disproportionately reduce per-pupil State funds to high-need LEAs or reduce per-pupil
                  State funding to the highest-poverty LEAs below their FY 2019 level, and that an LEA
                  does not disproportionately reduce State and local per-pupil funding in high-poverty
                  schools or disproportionately reduce the number of full-time-equivalent staff per pupil
                  in high-poverty schools. 8

                  According to the Department’s Frequently Asked Questions on ARP ESSER MOEquity
                  Requirements (dated July 26, 2022), MOEquity exceptions for LEAs may be granted by
                  the SEA or Department for various reasons, included those listed under section
                  2004(c)(2) of ARP. Section 2004(c)(2) of ARP states that an LEA does not need to
                  maintain equity if the LEA meets one or more of the following:

                      1. Has a total enrollment of less than 1,000 students.
                      2. Operates a single school.
                      3. Serves all students within each grade span with a single school.
                      4. Demonstrates an exceptional or uncontrollable circumstance, such as
                         unpredictable changes in student enrollment or a precipitous decline in the
                         financial resources of the LEA as determined by the Department’s Secretary.
                  Additionally, the Department determined that timing and implementation challenges
                  due to the pandemic (specifically related to LEA budgeting) are examples of exceptional
                  or uncontrollable circumstances that justify a limited exception to the local MOEquity
                  requirements for FYs 2022 and 2023. An LEA experiencing these circumstances may
                  demonstrate that it is excepted from the requirements for a given year by certifying to
                  the SEA that it will not implement an aggregate reduction in combined State and local
                  per-pupil funding in that year. Per the final requirements for the ARP ESSER Fund,
                  effective June 8, 2022, 9 each State must publish the names of the LEAs that are



8
 Section 2004(d)(4)(A) of ARP defines a high-poverty school as a school that is in the highest quartile of
schools served by the LEA based on the percentage of economically disadvantaged students served.
9
    Federal Register, Final Requirements for ARP ESSER Fund, 87 FR 34790.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                             9
                  excepted under each exception category. Each State must determine the most
                  appropriate way to publish and list this information so that parents, families, and the
                  general public in the State will be able to access and understand the information.

                  Illinois State Board of Education
                  The Illinois State Board of Education (Illinois), which is led by an appointed State
                  Superintendent of Education, is charged with overseeing public preschool–12 education
                  in the State of Illinois. Illinois’ Title Grant Administration, Federal and State Monitoring,
                  and Funding and Disbursements offices are responsible for the administration and
                  oversight of ARP ESSER subgrants to LEAs. Illinois has 852 LEAs (849 LEAs received ARP
                  ESSER allocations) and 3,841 schools that collectively serve about 1.9 million students.
                  As of March 31, 2023 (the end of our audit period), 801 LEAs had applied for and
                  received ARP ESSER funding and Illinois had drawn down about $1.8 billion
                  (37 percent) 10 of its $5.1 billion ARP ESSER allocation. 11 As a part of the audit, we
                  selected two Illinois LEAs for review: Chicago Public School District 299 and Waukegan
                  Community Unit School District 60.

                  Chicago Public School District 299
                  Chicago Public School District 299 (Chicago), located in Chicago, Illinois, is the largest
                  LEA in the State with 636 schools that serve about 322,000 students. Chicago was
                  allocated approximately $1.8 billion in ARP ESSER funds. As of March 31, 2023, Chicago
                  had spent about $660 million (37 percent) of its $1.8 billion ARP ESSER allocation. Of the
                  $660 million, Chicago spent about $275 million (42 percent) to address learning loss and
                  $385 million (58 percent) in other areas. In its approved ARP ESSER plan, Chicago stated
                  that it planned to use its 20 percent learning loss reserve, in part, for extended day and
                  afterschool programs, summer learning programs, and high-dosage tutoring and the
                  remainder of its funds for operational investments in schools such as technology,
                  building supplies, and school-based instructional positions.

                  Waukegan Community Unit School District 60
                  Waukegan Community Unit School District 60 (Waukegan), located in Waukegan,
                  Illinois, is one of the larger LEAs in the State with 24 schools that serve about 14,000
                  students. Waukegan was allocated approximately $43.4 million in ARP ESSER funds. As



10
     In this report, we round all percentages to the nearest whole number.
11
  As of January 10, 2024, Illinois had drawn down about $3.2 billion (63 percent) of its $5.1 billion ARP
ESSER allocation.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                            10
              of March 31, 2023, Waukegan had spent about $25.5 million (59 percent) of its
              $43.4 million ARP ESSER allocation. Of the $25.5 million, Waukegan spent about
              $8.7 million (34 percent) to address learning loss and $16.8 million (66 percent) in other
              areas. In its approved ARP ESSER plan, Waukegan stated that it planned to use its
              20 percent learning loss reserve, in part, for summer learning and comprehensive
              afterschool programs (including tutoring) and the remainder of its funds for technology
              (such as Chromebooks and iPads) for students, digital instructional services, and repairs
              and improvements to school facilities to reduce environmental health hazards.




U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                     11
                Finding 1. Illinois Generally Had Adequate
                  Processes for Reviewing and Approving LEA
                  ARP ESSER Plans, But Did Not Ensure That
                  Plans Were Submitted Within a Reasonable
                  Timeframe
                Illinois generally had adequate processes to ensure that LEA ARP ESSER plans met
                applicable requirements. Illinois communicated clear, accurate, and timely guidance and
                technical assistance to LEAs regarding how to develop and submit their ARP ESSER plans
                and what to include in those plans. However, Illinois did not communicate accurate
                guidance to LEAs regarding when to submit their ARP ESSER plans according to
                Department guidance. As a result, 434 (54 percent) of 801 LEAs 12 did not submit their
                ARP ESSER plans within a reasonable timeframe as provided for in Department
                guidance, with one LEA submitting its plan to Illinois more than 540 days after receiving
                its allocation. Further, six LEAs still had not submitted their ARP ESSER grant application
                and plan to Illinois as of January 11, 2024. Thus, some LEAs may not have received
                critical ARP ESSER funds timely or early enough to adequately respond to the impacts of
                the coronavirus pandemic by addressing students’ academic, social, emotional, and
                mental health needs, which was the purpose of the ARP ESSER program.

                Illinois’ process for reviewing and approving plans was rigorous and designed to ensure
                that the plans adequately addressed applicable requirements. Illinois used a checklist to
                guide its review and approval of LEA ARP ESSER plans. The checklist adequately
                addressed all applicable plan requirements. Illinois approved ARP ESSER plans for all
                801 (100 percent) LEAs that applied for and received ARP ESSER funds. We reviewed the
                ARP ESSER plans for 16 LEAs and determined that they were posted on LEA websites and
                met applicable requirements. The posted plan for one LEA was missing information on
                how the LEA planned to use ARP ESSER funds. However, we verified that the plan Illinois
                reviewed and approved for the LEA included the missing information and concluded that
                the LEA had posted an incomplete version of its plan on its website. For 2 (13 percent) of
                the 16 LEAs (Chicago and Waukegan), we reviewed additional information (such as ARP
                ESSER grant applications, plan approval documents, and related correspondence) and
                determined that Illinois followed its established ARP ESSER plan review and approval



12
  Illinois allocated $4.6 billion to 849 LEAs in July 2021. For this audit, we limited our review to the
801 LEAs that had applied for and received ARP ESSER funds on or before March 31, 2023 (end of our
audit period).


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                           12
                   processes and was consistent in how it reviewed and approved the plans for the two
                   LEAs.

                   Technical Assistance and Guidance Provided to LEAs
                   Illinois provided technical assistance and guidance to LEAs, in part, through
                   dissemination of Frequently Asked Questions documents (prepared by the Department),
                   presentations, webinars, and emails sent through the Illinois Web Application Security
                   (IWAS) system.13 The technical assistance and guidance provided to LEAs covered
                   various topics, including ARP ESSER plan narrative requirements, application and plan
                   submission instructions, meaningful consultation under ARP ESSER, and spending plan
                   budget and signed assurances form submission requirements. Illinois provided a large
                   portion of this technical assistance and guidance to LEAs in June 2021, which was
                   1 month before LEAs were notified that they had been allocated and could apply for
                   ARP ESSER funds (July 2021). While Illinois communicated clear, accurate, and timely
                   guidance and technical assistance to LEAs regarding how to develop and submit their
                   ARP ESSER plans and what to include in those plans, it did not communicate accurate
                   guidance to LEAs regarding when to submit their ARP ESSER plans according to
                   Department guidance.

                   Illinois Did Not Establish a Reasonable Timeframe for LEA ARP
                   ESSER Plan Submission
                   Illinois established a deadline of August 31, 2024, for LEAs to submit their ARP ESSER
                   plans, which is more than 3 years after LEAs received their ARP ESSER allocations (funds
                   allocated on July 7, 2021) and not reasonable and timely per Department guidance. As a
                   result, 434 (54 percent) of the 801 LEAs covered by our review did not submit their ARP
                   ESSER plans within a reasonable timeframe, with one LEA submitting its plan to Illinois
                   more than 540 days after receiving its allocation. Further, 6 (1 percent) of the 849 LEAs
                   that received an ARP ESSER allocation still had not submitted their ARP ESSER
                   application and plan to Illinois as of January 11, 2024, more than 2.5 years after the LEAs
                   received their ARP ESSER allocations. 14 According to Department guidance provided in
                   both its IFR for ARP ESSER 15 and State plan template, SEAs were responsible for
                   establishing a deadline for LEAs to submit their ARP ESSER plans that was reasonable


13
     IWAS is a web-based system that Illinois uses to manage its grants.
14
  The 48 LEAs (849 less 801) that were allocated but had not applied for and received ARP ESSER funds
on or before March 31, 2023, were not covered by our audit.
15
     Federal Register, IFR for ARP ESSER Fund, 86 FR 21199 (effective April 22, 2021).


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                           13
                   and should be no more than 90 days after the LEAs received their ARP ESSER allocation.
                   Following Department guidance, a reasonable deadline for plan submissions would have
                   been October 5, 2021 (90 days after the LEAs received their ARP ESSER allocation).
                   Table 1 provides summary information regarding the timing of LEA ARP ESSER plan
                   submissions.

                   Table 1. Timing of LEA ARP ESSER Plan Submissions to Illinois

                 Days After Allocation that LEA ARP ESSER
                                                                   Number of LEAs       Percentage 16
                      Plan Was Submitted to Illinois

                                  0–90 days                               367            46 percent

                                91–180 days                               183            23 percent

                                181–270 days                              125            16 percent

                                271–360 days                              103            13 percent

                                361–450 days                              12              2 percent

                                451–540 days                              10              1 percent

                                541–630 days                               1              0 percent

                                    Total                                 801                 -
                   Source: OIG Analysis of IWAS system data provided by Illinois.

                   Illinois requested clarity and guidance from the Department regarding the LEA ARP
                   ESSER plan submission deadline. In its response, the Department referred Illinois to the
                   IFR for ARP ESSER which states that the SEA must establish a deadline for an LEA to
                   submit its plan that is reasonable and should be no more than 90 days after receiving its
                   ARP ESSER allocation. As the SEA, Illinois was responsible for establishing a reasonable
                   deadline for LEAs to submit their ARP ESSER plans. Illinois’ Deputy Education Officer for
                   Operational Education and Executive Director of Regulatory Services told us that the
                   August 31, 2024, deadline for plan submissions was chosen because Illinois thought it
                   was best for their LEAs given the challenges of the coronavirus pandemic.




16
     The percentages in this table do not total to 100 percent due to rounding.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                         14
                 Illinois’ Review and Approval of LEA ARP ESSER Plans
                 Illinois required LEAs to submit a grant application for ARP ESSER funds through the
                 IWAS system. As part of the ARP ESSER grant application process, Illinois required LEAs
                 to submit a use of funds plan 17 and website address to access the plan, ARP ESSER
                 budget (along with a statement that funds will be used for the purposes listed in section
                 18003(d) of the CARES Act, section 313(d) of CRRSAA, and section 2001(e) of ARP), and
                 details of their subcontracts, if applicable. LEAs were also required to submit signed
                 assurances that they will follow all applicable Federal and State requirements.

                 Principal consultants within Illinois’ Title Grant Administration office were responsible
                 for reviewing and approving LEAs’ ARP ESSER grant applications, including their use of
                 funds plans, spending plan budgets, and assurances forms in the IWAS system. LEA ARP
                 ESSER grant applications and plans had to go through two levels of review before Illinois
                 approved them and made ARP ESSER funds available to LEAs. Illinois’ process for
                 reviewing and approving plans is summarized in Figure 1 and further described in the
                 section that follows.

                 Figure 1. Summary of Illinois’ Processes for Reviewing and Approving LEA ARP ESSER
                 Plans




                 Principal Consultants’ Review of LEA ARP ESSER Plans
                 The principal consultants within Illinois’ Title Grant Administration office (plan
                 reviewers) reviewed the LEA ARP ESSER plans to ensure that they included required
                 information in key areas and otherwise met all applicable requirements and
                 summarized the results of their reviews. Once the first reviewer was satisfied that the
                 plan met all requirements, the plan was reviewed by another principal consultant as
                 part of a second-level, quality assurance review. The plan (and application package) was



17
   Illinois also required its LEAs to submit a Safe Return to In-Person Instruction plan. For this audit, we
limited our review to LEAs’ use of funds plans and related spending plan budgets.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                           15
                considered approved by Illinois after the second-level reviewer was satisfied that all
                requirements were met. LEAs were notified in the IWAS system when their plans were
                approved, at which time the LEAs could submit requests to Illinois for ARP ESSER funds
                (reimbursement funding method). We reviewed the summary results to verify that
                Illinois approved an ARP ESSER plan for the 801 LEAs that had applied for and received
                ARP ESSER funds on or before March 31, 2023, and to assess the rigor of Illinois’ plan
                review and approval process, including how often and why it did not approve plans. We
                determined that Illinois approved an ARP ESSER plan for all 801 (100 percent) LEAs.

                We concluded that Illinois’ plan review and approval process was of sufficient rigor
                based on the high number of reviews performed, the various reasons for not initially
                approving plans, and the overall scrutiny that the principal consultants applied for each
                requirement. Illinois performed more than 3,300 reviews for the 801 LEAs, an average
                of more than 4 reviews per LEA. Only 19 (2 percent) of 801 LEAs had their plans
                approved by Illinois on the first review. Eighteen (2 percent) LEAs had their plans
                reviewed 10 or more times before Illinois approved them, further demonstrating the
                rigor of Illinois’ review and approval process (see Table 2).

                Table 2. Number of Times Illinois Reviewed LEA ARP ESSER Plans Before Approval
                Number of Times Illinois Reviewed           Number of LEAs             Percentage
                     Plan Before Approval

                                  1                                 19                  2 percent

                                2 to 3                             314                  39 percent

                                4 to 6                             373                  47 percent

                                7 to 9                              77                  10 percent

                              10 to 13                              18                  2 percent

                               TOTAL                               801                 100 percent
                Source: OIG Analysis of IWAS system data provided by Illinois.

                Principal consultants used a checklist, comprised of yes or no questions for each
                applicable requirement, to guide their reviews. 18 The plan reviewer checked yes if the
                information provided met a requirement or no if the information provided did not meet


18
  The first- and second-level reviewers used different checklists to guide their reviews. The second-level
reviewer used a quality assurance checklist.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                       16
                  a requirement. If there was a no response for any requirement on the checklist, the plan
                  reviewer returned the plan to the LEA (by declining the application package) and
                  provided detailed feedback to the LEA on what needed to be corrected or added. The
                  LEA then refined its plan and resubmitted its ARP ESSER application package until the
                  plan reviewer was satisfied that all applicable requirements were met. During their
                  reviews, the plan reviewers were primarily focused on verifying that the LEA ARP ESSER
                  plans were posted on the LEA website, were in an understandable and uniform format
                  accessible to all parents, and included sufficient information in the following areas, as
                  required by the IFR for ARP ESSER: 19

                      1. The extent to which and how the funds will be used for prevention and
                         mitigation strategies that are, to the greatest extent practicable, in line with the
                         most recent Centers for Disease Control guidance, to continuously and safely
                         operate schools for in-person learning.
                      2. How the LEA will use the funds it reserves under section 2001(e)(1) of ARP to
                         address the academic impact of lost instructional time through the
                         implementation of evidence-based interventions (20 percent learning loss).
                      3. How the LEA will ensure that its implemented interventions, including but not
                         limited to the interventions under section 2001(e)(1) of ARP to address the
                         academic impact of lost instructional time, will respond to the academic, social,
                         emotional, and mental health needs of all students.
                      4. How the LEA will engage in meaningful consultation with stakeholders and seek
                         public input as it develops the LEA ARP ESSER plan.
                      5. How the LEA will spend its remaining ARP ESSER funds consistent with section
                         2001(e)(2) of ARP.
                  Reasons why Illinois did not approve LEA ARP ESSER plan submissions included, but
                  were not limited to, missing or incomplete information regarding how the LEA would
                  use funds, unallowable expenditures in budgets, budgeted items that did not have an
                  academic impact, and missing allocations for learning loss.

                  ARP ESSER Plans for Selected LEAs, including Chicago and Waukegan
                  We reviewed the ARP ESSER plans for 16 LEAs to determine whether they met
                  applicable requirements, including the requirements that plans be posted on the LEA
                  website, be in an understandable and uniform format and accessible to all parents, and



19
     Federal Register, IFR for ARP ESSER, 86 FR 21198-21199.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                          17
                adequately describe how funds will be used and how the LEA engaged in meaningful
                consultation with stakeholders. We determined that the plans for all 16 (100 percent)
                LEAs were posted on LEA websites and all but one (94 percent) of those plans included
                all required information in the plans. The posted plan for one LEA did not adequately
                describe how the LEA planned to use ARP ESSER funds, contrary to the IFR for ARP
                ESSER (86 FR 21198). 20 Although the ARP ESSER plan posted on the LEA’s website was
                missing key information on how the LEA planned to use its ARP ESSER funds, we verified
                that the plan that Illinois reviewed and approved for the LEA included that information
                and concluded that the LEA had posted an incomplete version of its plan. About a
                month after we informed Illinois of this issue, we accessed the plan posted on the LEA’s
                website. We saw that the plan included all required information on how the LEA
                planned to use its ARP ESSER funds and thus considered the issue resolved.

                For 2 of the 16 LEAs (Chicago and Waukegan), we reviewed additional information,
                which in part included the LEAs’ ARP ESSER grant applications, plan approval
                documents, and related correspondence, to verify that Illinois followed its established
                processes for reviewing and approving LEA ARP ESSER plans and was consistent in how
                it reviewed and approved the two plans. We also reviewed the checklists that Illinois
                plan reviewers used during their reviews of the LEAs’ ARP ESSER applications and plans,
                correspondence between Illinois and the LEAs (including Illinois’ reasons for not initially
                approving the plans), and the plan submission history from initial submission to final
                approval. Illinois reviewed the plans for Chicago and Waukegan five times each before
                approving them. We determined that Illinois followed its established processes and was
                consistent in how it reviewed and approved the plans for Chicago and Waukegan. We
                also determined that both LEAs submitted their plans to Illinois within 90 days of
                receiving their ARP ESSER allocations.

                Principal Consultants’ Review of LEA ARP ESSER Spending Plan
                Budgets and Assurances
                As part of their ARP ESSER application package, Illinois required LEAs to submit a
                spending plan budget and signed assurances forms in the IWAS system. Illinois required
                an authorized LEA official to electronically sign the ARP ESSER Assurances form and five




20
  The plan posted on the LEA’s website did not describe how the LEA will use ARP ESSER funds to
implement prevention and mitigation strategies to safely open and operate schools for in person
learning, address the academic impact of lost instructional time, and respond to the academic, social,
emotional, and mental health needs of all students.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                         18
                other assurances forms in IWAS. 21 By signing the assurances forms, the LEAs promised
                to comply with applicable State and Federal requirements while administering ARP
                ESSER funds. The principal consultants within Illinois’ Title Grant Administration office
                then accessed IWAS and verified that the LEA had submitted its spending plan budget
                and required assurances forms and that there were no issues. LEA ARP ESSER
                application packages were fully approved once the principal consultants had completed
                their reviews of the ARP ESSER plan, spending plan budget, and assurances forms and
                had not identified any issues.

                The spending plan budget is a form in IWAS with fields for cost accounting codes and
                descriptions, budgeted amounts, and expenditure narratives. The LEA ARP ESSER
                application included a specific section for the LEA to input the same information for the
                20 percent of ARP ESSER funds reserved for learning loss. IWAS has controls to ensure
                that LEAs correctly input their spending plan budgets and that basic requirements are
                met, which include having preloaded budget categories that align with approved ARP
                ESSER cost accounting codes and a designated section to account for the 20 percent of
                funds reserved for learning loss.

                A non-Federal entity must establish and maintain effective internal control over the
                Federal award that provides reasonable assurance that it is managing the award in
                compliance with Federal statutes, regulations, and the terms and conditions of its award
                (2 Code of Federal Regulations (C.F.R.) section 200.303(a)). These internal controls
                should be compliant with the Comptroller General of the United States’ guidance in the
                U.S. Government Accountability Office’s (GAO) Standards for Internal Control in the
                Federal Government (September 2014) or the Committee of Sponsoring Organizations
                of the Treadway Commission’s Internal Control Integrated Framework. One component
                of internal control is control activities. Section 10.01 of GAO’s Standards for Internal
                Control in the Federal Government states that management should design control
                activities to achieve objectives and respond to risks.

                While we recognize that the coronavirus pandemic presented challenges for LEAs and
                that establishing deadlines can be difficult, the Department urged SEAs and LEAs to
                deploy ARP ESSER funds quickly to address the impacts of the pandemic on school
                communities. Illinois’ deadline for LEAs to submit their ARP ESSER plans was not
                reasonable according to Department guidance and led to more than half of the LEAs



21
  The other forms covered assurances and certifications related to (1) the grant application and State
requirements; (2) debarment, suspension, ineligibility, and voluntary exclusion; (3) lobbying; (4) General
Education Provision Act, Section 442; and (5) Grant Accountability and Transparency Act.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                       19
              submitting their plans late or not at all. As a result, some LEAs may not have received
              critical ARP ESSER funds timely or early enough to adequately respond to the impacts of
              the coronavirus pandemic by addressing students’ academic, social, emotional, and
              mental health needs.

              Recommendation
              We recommend that the Assistant Secretary for the Office of Elementary and Secondary
              Education require Illinois to—

                  1.1. Direct any LEAs that have not yet applied but plan to apply for ARP ESSER funds,
                       to submit their ARP ESSER grant applications and plans to Illinois as soon as
                       possible.

              Illinois’ Comments
              Illinois agreed with the finding and recommendation. Illinois stated that it has and will
              continue to encourage the remaining LEAs to submit their ARP ESSER applications and
              plans and will provide technical support to those LEAs until their submissions are
              received.

              OIG Response
              Illinois’ proposed actions, if implemented as described, are responsive to our
              recommendation.




U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                      20
                  Finding 2. Illinois’ Process for Reviewing LEA
                    ARP ESSER Reimbursement Requests Could Be
                    Strengthened in a Key Area
                  Illinois’ process for reviewing LEA ARP ESSER reimbursement requests could be
                  strengthened in a key area to provide additional assurance that LEAs use ARP ESSER
                  funds for allowable purposes. Illinois monitored LEAs’ use of ARP ESSER funds, in part,
                  by reimbursing LEAs after verifying that their reimbursement request aligned with the
                  approved budget and did not exceed the amount awarded (reimbursement process);
                  reviewing performance reports each year to verify that the deliverables aligned with the
                  LEAs’ approved ARP ESSER plans, budgets, and reimbursements for the period
                  (performance review process); and conducting annual monitoring of selected LEAs
                  based on their overall risk, which includes a review of ARP ESSER expenditures (ARP
                  ESSER monitoring process). While Illinois has been consistent in how it oversees LEAs’
                  use of ARP ESSER funds, it does not request or review any supporting documentation
                  (such as contracts, receipts, and invoices) from LEAs as part of its review of LEA
                  reimbursement requests.

                  We reviewed a total of 26 ARP ESSER expenditures for Chicago and Waukegan
                  (13 expenditures for each LEA) to determine whether they used ARP ESSER funds in
                  accordance with applicable requirements and the approved ARP ESSER plan. We
                  determined that all (100 percent) expenditures reviewed were in accordance with
                  applicable requirements and the approved LEA ARP ESSER plan.

                  Illinois’ Oversight of LEA MOEquity Requirements
                  Illinois published on its website the names of the LEAs receiving an ARP ESSER MOEquity
                  exception and the reasons for those exceptions, in accordance with the final
                  requirements for the ARP ESSER Fund. 22 Illinois also published on its website the names
                  of the LEAs that were exempt from the MOEquity requirements. For FY 2022, all but 1 of
                  the 801 LEAs were either exempt from MOEquity requirements or received an ARP
                  ESSER MOEquity exception. The one LEA required to maintain equity in accordance with
                  program requirements provided Illinois with information to support that it did so during
                  FY 2022. For FY 2023, all 801 (100 percent) LEAs were either exempt from the MOEquity
                  requirements or received an ARP ESSER MOEquity exception. For FY 2022, Illinois
                  required all LEAs to submit an exemption survey to determine if they were eligible for
                  an exemption, exception, or special waiver from the Department. For FY 2023, Illinois


22
     Federal Register, Final Requirements for ARP ESSER Fund, 87 FR 34790.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                       21
              identified the LEAs that were exempt and did not require LEAs to submit an exemption
              survey to Illinois or the Department.

              For an LEA seeking a MOEquity exception for an exceptional or uncontrollable
              circumstance, and where there was no aggregate reduction in State and local per-pupil
              funding, Illinois required the LEA to submit a signed LEA Certification of Exception from
              Local Maintenance of Equity Requirements form to Illinois. For an LEA seeking a waiver
              from the Department for an exceptional or uncontrollable circumstance, Illinois
              instructed the LEA to include the waiver request on the exemption survey and provide
              that information to the Department (and Illinois) for consideration. Chicago and
              Waukegan requested an ARP ESSER MOEquity exception for an exceptional or
              uncontrollable circumstance with no aggregate reduction in State and local per-pupil
              funding for FYs 2022 and 2023 and authorized officials from both LEAs signed and
              submitted the required certifications to Illinois. We concluded that both LEAs provided
              the required documentation and certifications to support their exception requests.

              Technical Assistance and Guidance Provided to LEAs
              Illinois provided technical assistance and guidance to LEAs, in part, through
              dissemination of Frequently Asked Questions documents (prepared by the Department),
              its website, and webinars. The technical assistance and guidance provided to LEAs
              covered various ARP ESSER topics, including allowable uses of ARP ESSER funds, ARP
              ESSER annual reporting, and ARP ESSER MOEquity requirements. Illinois provided a large
              portion of this technical assistance and guidance to LEAs before LEAs could access their
              ARP ESSER funds. Illinois continued to provide ongoing technical assistance and
              guidance to LEAs after the LEAs received their allocations and ahead of key MOEquity
              and reporting deadlines. We determined that Illinois communicated clear, accurate, and
              timely guidance and technical assistance to LEAs regarding allowable uses of ARP ESSER
              funds, annual reporting requirements, and the applicable MOEquity requirements.

              Illinois’ Processes for Monitoring LEAs’ Use of ARP ESSER
              Funds
              Illinois monitored LEAs’ use of ARP ESSER funds through its reimbursement,
              performance review, and ARP ESSER monitoring processes. These processes are
              described in the next three sections, respectively.

              Reimbursement Process
              Illinois reimburses LEAs for their ARP ESSER expenditures in the same way it reimburses
              LEAs for their other Federal grant expenditures. Illinois requires an LEA to submit an
              Electronic Expenditure Report (EER) form through the EER component of IWAS to be
              reimbursed for its ARP ESSER expenditures. The EER form pre-populates the total ARP


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                     22
               ESSER budget amount for the LEA and cash vouchered to date (reimbursement
               payments made to date). The LEA is required to enter the amount of funds spent to date
               by related budget function and object codes on the EER form. Only LEA officials with
               proper authorization and permissions in IWAS, as granted by the LEA superintendent or
               IWAS administrator, can enter data on and submit an EER form on the LEA’s behalf.
               Once the LEA official enters the expenditure data, the current reimbursement request
               amount (amount spent to date less cash vouchered to date) is automatically calculated
               on the EER form. The EER component of IWAS tracks ARP ESSER grant payments and has
               automated checks to ensure that an LEA is not reimbursed for more than it was
               awarded. Once the EER form passes all automated checks and is accepted in IWAS,
               Illinois’ Funding and Disbursements Department initiates a transfer of the LEA’s
               expenditure data into Illinois’ Financial Reimbursement Information System. Illinois’
               Funding and Disbursements Department then creates a voucher for the LEA’s
               reimbursement payment. Each week, the Director of the Funding and Disbursements
               Department certifies all vouchers generated during that particular week and sends them
               to Illinois’ Department of Fiscal Support for payment. The Department of Fiscal Support
               then draws down ARP ESSER funds from the Department’s G5 system and processes
               payments to the LEAs. 23

               Illinois incorporated useful controls into its reimbursement process, including verifying
               that key information on the EER form (for example, approved budget amount and cash
               vouchered to date) was correct, LEA assurance documents were properly submitted and
               approved in IWAS, and an authorized LEA official submitted the reimbursement request.
               However, Illinois’ process could be strengthened by requiring LEAs to provide a listing of
               their ARP ESSER expenditures and supporting documentation for a sample of those
               expenditures (as requested by Illinois) as part of their reimbursement request. Without
               this information, it would be difficult for Illinois to reasonably assure that the
               expenditures for which the LEAs are seeking reimbursement are allowable and properly
               accounted for, and there is an increased risk that Illinois will not identify or become
               aware of significant compliance issues involving the ARP ESSER program. LEAs’ misuse or
               mismanagement of ARP ESSER funds reduces the funds available for students and
               schools that need them.




23
  We reviewed eight reimbursement requests for Chicago and Waukegan (four for each LEA) and
verified that Illinois followed its established reimbursement process when reviewing the reimbursement
requests for, and making reimbursement payments to, the two LEAs.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                      23
                The ARP ESSER program was considered a higher risk program for 2022 and 2023
                according to 2 C.F.R. section 200.519(c)(2). 24 The Pandemic Response Accountability
                Committee stated that the unprecedented amount of money made available for
                pandemic relief and the quick distribution of most funds put the money at a higher risk
                for fraud. 25 Further, ARP ESSER funds can be used for a wide range of activities spanning
                multiple coronavirus response and relief laws. This scenario, in conjunction with Illinois
                not reviewing supporting documentation on at least a sample basis, could allow for the
                unintentional or intentional misuse of ARP ESSER funds by grantees and subgrantees
                and result in fraud, waste, and abuse going undetected. Without additional controls
                over the LEA reimbursement request process, Illinois may fail to properly address these
                heightened risks, leaving ARP ESSER funds at greater risk of misuse.

                Illinois senior officials told us that to address the heightened risk associated with ARP
                ESSER funds, Illinois expanded the ESSER expenditure testing that it performs during
                annual monitoring reviews to include expenditures from all years of ESSER instead of
                only testing expenditures from the most current year. The officials also told us that since
                ESSER’s inception, Illinois has always assessed ESSER at the highest risk level and
                reviewed ESSER expenditures during LEA monitoring visits. Expanding testing to include
                expenditures from all ESSER years could help Illinois identify unintentional or intentional
                misuse of ARP ESSER funds by the roughly 10 percent of LEAs selected for monitoring
                each year, but generally would not cover the other 90 percent of LEAs that are not
                subject to monitoring each year. Reviewing a sample of ARP ESSER expenditures and
                related supporting documentation for LEAs at the time of their reimbursement requests
                would subject more LEAs to Illinois’ oversight and could help Illinois identify unallowable
                costs more often or earlier than if it had waited to review expenditures at year-end as
                part of its annual monitoring.

                Non-Federal entities must establish and maintain effective internal control over the
                Federal award that provides reasonable assurance that they are managing the award in
                compliance with Federal statutes, regulations, and the terms and conditions of the



24
  Federal agencies, with the concurrence of the Office of Management and Budget, may identify Federal
programs that are higher risk and identify them as such in the Compliance Supplement. The ARP ESSER
program was identified as a higher risk program in the Office of Management and Budget’s 2 C.F.R.
Part 200, Appendix XI, Compliance Supplement, dated April 2022 and May 2023.
25
  The CARES Act established the Pandemic Response Accountability Committee within the Council of
Inspectors General on Integrity and Efficiency, the oversight and coordination body for the Inspector
General community.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                        24
                  award (2 C.F.R. section 200.303(a)). State grantees (pass-through entities) are required
                  to establish monitoring priorities based on the risks posed by each subgrantee and
                  monitor the fiscal activity of subgrantees as necessary to ensure that the subaward is
                  used for authorized purposes and complies with Federal statutes, regulations, and the
                  terms and conditions of the subaward; and that subaward performance goals are
                  achieved (2 C.F.R. section 200.332(b) and (d)). In addition, section 10.01 of GAO’s
                  Standards for Internal Control in the Federal Government, states that management
                  should design control activities to achieve objectives and respond to risks.

                  Performance Review Process
                  Each year, a team within Illinois’ Title Grant Administration office reviews performance
                  information for all LEAs. Within 30 days after the end of each annual reporting period,
                  Illinois requires LEAs to submit a Grant Periodic Performance Report (performance
                  report) that describes the deliverables achieved with grant funds and the results and
                  impacts of those deliverables during the reporting period. 26 According to the Director of
                  Title Grant Administration, the Title Grant Administration team reviews the LEA
                  performance reports to verify that the deliverables aligned with the LEAs’ approved ARP
                  ESSER plans, budgets, and reimbursements for the period. If the team identifies issues
                  with a performance report, the report is returned to the LEA for follow-up. We verified
                  that Chicago and Waukegan provided Illinois with all required performance reports
                  applicable to our audit period. Each LEA submitted two performance reports to Illinois:
                  one for the reporting period ended December 31, 2021, and one for the reporting
                  period ended June 30, 2022. We reviewed the performance reports for Chicago and
                  Waukegan and correspondence between the LEAs and Illinois and determined that
                  Illinois followed its established processes when reviewing and approving the
                  performance reports for both LEAs. 27

                  ARP ESSER Monitoring Process
                  Illinois incorporated procedures for reviewing ARP ESSER expenditures into its existing
                  monitoring process for all Federal and State programs. It added procedures to select
                  and test ARP ESSER expenditures for allowability and compliance with applicable
                  requirements. Illinois’ Federal and State Monitoring Department, composed of



26
     Prior to FY 2023, Illinois required LEAs to submit the performance report every 6 months.
27
  Illinois approved both Waukegan performance reports on the first submission. Chicago had to submit
both of its performance reports multiple times before Illinois approved them. Illinois told Chicago what
information needed to be corrected and Chicago made the necessary corrections.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                         25
                15 employees, is responsible for monitoring Federal and State grant programs, including
                ARP ESSER. Illinois executed 2 contracts with a third-party company to perform the
                monitoring for the 10 largest LEAs (in terms of total funding) in the State. The third-
                party contractor is responsible for monitoring Chicago (the largest LEA in Illinois) each
                year and the next nine largest LEAs over a 3-year period (three monitoring reviews per
                year for 3 years). All other monitoring reviews are performed by Illinois’ Federal and
                State Monitoring Department. Collectively, Illinois and its third-party contractor
                completed 79 monitoring reviews in FY 2022 and expect to complete 88 monitoring
                reviews in FY 2023 (78 reviews were completed as of November 2023).

                Illinois conducted a formal risk assessment and used a risk assessment tool 28 to help
                determine how many and which LEAs to select for ARP ESSER monitoring. Monitoring
                reviews were either conducted on-site at the LEA’s office or remotely. The monitoring
                processes, tools, and checklists used by reviewers were the same regardless of how the
                review was performed (on-site or remote) or who performed the review (Illinois or
                third-party contractor). For each LEA selected for review, Illinois or its third-party
                contractor conducted interviews with LEA personnel responsible for administering and
                managing ARP ESSER funds and tested a sample of ARP ESSER expenditures for
                allowability and compliance with applicable requirements. The monitoring teams
                ensured that they tested at least 10 percent of all ARP ESSER expenditures (in
                accordance with established Illinois procedures) and reviewed supporting
                documentation, as needed. They held an exit conference with each LEA and then
                prepared and provided the LEA with a final report that identified the deficiencies noted
                during the monitoring review and the required corrective actions that the LEA must take
                in response to those deficiencies.

                According to Illinois’ Director of Federal and State Monitoring, Illinois’ monitoring teams
                identified 124 and 170 ESSER-related findings in FY 2022 and FY 2023, respectively.
                Across multiple LEAs, Illinois identified seven questioned costs totaling over $90,000 in
                FY 2022 and eight questioned costs totaling over $301,000 in FY 2023. The questioned
                costs, in part, included costs for a mobile video gaming theater, entertainment, and
                meetings that Illinois determined were not allowable under ARP ESSER. Illinois followed
                up with the LEAs and verified that they took appropriate corrective actions. We
                concluded that Illinois’ ARP ESSER monitoring was designed and implemented in a way




28
  The risk assessment tool incorporated the following risk indicators: Internal Control Questionnaire risk
score, amount of funding received, date of last review, number of single audit findings and questioned
costs, LEA financial status, and referral risk score based on feedback from other Illinois’ program staff.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                        26
               that enabled it to identify and select high-risk LEAs for review and detect instances of
               noncompliance during monitoring reviews.

               Review of ARP ESSER Expenditures at Chicago and Waukegan
               We reviewed samples of ARP ESSER expenditures at Chicago and Waukegan to
               determine whether they used ARP ESSER funds in accordance with applicable
               requirements and the approved ARP ESSER plan. 29 We determined that all (100 percent)
               expenditures reviewed were in accordance with applicable requirements and the
               approved LEA ARP ESSER plan.

               Chicago
               We reviewed 13 ARP ESSER expenditures totaling $11,985,312. These generally included
               expenditures for payroll, digital curricula, repairs and maintenance, and technology such
               as laptops and laptop charging stations. We determined that all 13 (100 percent)
               expenditures were in accordance with applicable requirements (allowable) and
               Chicago’s approved ARP ESSER plan.

               Waukegan
               We reviewed 13 ARP ESSER expenditures totaling $5,036,914. These generally included
               expenditures for payroll, employee retention, service contracts for speech pathologists,
               digital curricula, professional development, and repairs and maintenance. We
               determined that all 13 (100 percent) expenditures were in accordance with applicable
               requirements (allowable) and Waukegan’s approved ARP ESSER plan.

               Recommendation
               We recommend that in order to address the heightened risk associated with ARP ESSER
               funds, the Assistant Secretary for the Office of Elementary and Secondary Education
               require Illinois to—

                   2.1. Design and incorporate into its documented procedures for reviewing LEA
                        reimbursement requests protocols to sample LEA expenditures charged to ARP
                        ESSER and review supporting documentation to ensure that applicable Federal,
                        State, and local requirements are met.




 The results of our testing apply only to the samples selected and cannot be projected. See Scope and
29

Methodology (Sampling Methodology section) for information on how we selected our samples.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                          27
              Illinois’ Comments
              Illinois agreed with the finding and recommendation. Illinois stated that it will
              strengthen its LEA reimbursement request protocol by requiring LEAs to provide a listing
              of their ARP ESSER expenditures and supporting documentation and selecting a sample
              of those expenditures for review to determine whether they are allowable. Illinois
              described at a high level the scope and activities associated with that review, which in
              part would include extracting LEA expenditure report samples, conducting pre-
              monitoring fiscal reviews of LEA expenditures against the general ledger and other
              supporting documentation, and verifying allowable or unallowable expenditure items.
              Illinois stated that it will strengthen its LEA reimbursement request protocol and
              incorporate the related activities by June 2024.

              OIG Response
              Illinois’ proposed actions, if implemented as described, are responsive to our
              recommendation.




U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                   28
              Appendix A. Scope and Methodology
              Our audit covered Illinois’ processes for reviewing and approving LEA ARP ESSER plans
              and overseeing LEAs’ use of ARP ESSER funds from March 24, 2021, through March 31,
              2023. To achieve our objectives, we gained an understanding of the following laws,
              regulations, and guidance relevant to ARP ESSER:

                  •   CARES Act (Public Law 116-136, March 27, 2020), section 18003 (“Elementary
                      and Secondary School Emergency Relief Fund”).
                  •   CRRSAA (Public Law 116-260, December 27, 2020), section 313 (“Elementary
                      and Secondary School Emergency Relief Fund”).
                  •   ARP (Public Law 117-2, March 11, 2021), sections 2001 (“Elementary and
                      Secondary School Emergency Relief Fund”) and 2004 (“Maintenance of Effort
                      and Maintenance of Equity”).
                  •   2 C.F.R. Part 200, Uniform Administrative Requirements, Cost Principles, and
                      Audit Requirements for Federal Awards.
                  •   Office of Management and Budget’s 2 C.F.R. Part 200, Appendix XI, Compliance
                      Supplement, April 2022 and May 2023.
                  •   GAO’s Standards for Internal Control in the Federal Government
                      (September 2014).
                  •   IFR for ARP ESSER (April 22, 2021), 86 FR 21195–21207; and Final Requirements
                      for ARP ESSER Fund (June 8, 2022), 87 FR 34790–34794.
                  •   Department guidance, including the Department’s Secretary of Education Letter
                      (March 24, 2021) announcing SEA grant allocations; ARP ESSER Grant Award
                      Assurances; Frequently Asked Questions documents for ARP ESSER Program
                      Maintenance of Equity Requirements (August 6, 2021, and updated on January
                      23, 2023) and ESSER and Governor’s Emergency Education Relief Programs
                      (May 2021, and updated on December 7, 2022); CRRSAA ESSER II Fact Sheet
                      (January 5, 2021); ARP ESSER Fact Sheet (March 2021); slides for the webinar,
                      “Using COVID-Relief Funds for Facility Upgrades, Renovations, and Construction
                      (September 2, 2021); and ED COVID-19 Handbook, Roadmap to Reopening
                      Safely and Meeting All Students’ Needs, Volume 2 (2021).
              We gained an understanding of Illinois’ oversight and monitoring activities through
              interviews with SEA and LEA officials. We interviewed employees and officials from
              Illinois, Chicago, and Waukegan who had knowledge of or were responsible for
              establishing, administering, or monitoring the ARP ESSER program. At Illinois, we



U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                     29
                interviewed officials who were responsible for providing guidance and technical
                assistance to LEAs, reviewing and approving LEA ARP ESSER plans and budgets, and
                monitoring LEAs’ use of ARP ESSER funds. To assess the reliability of the testimonial
                evidence, we compared information obtained from interviews with records related to
                Illinois’ oversight and monitoring activities when provided by the interviewees. We
                concluded that the testimonial evidence we obtained was sufficiently reliable within the
                context of our audit objectives.

                We also gained an understanding of Illinois’ oversight and monitoring activities through
                reviews of relevant documents and records. We reviewed documents identifying Illinois’
                offices and staff who had a role in establishing, administering, or monitoring the ARP
                ESSER program. We reviewed and evaluated the guidance and technical assistance (such
                as weekly messages and notifications, webinars, and other presentations) that Illinois
                provided to LEAs regarding ARP ESSER plans and spending. We also reviewed narratives
                to further our understanding of how Illinois monitored LEAs’ use of ARP ESSER funds,
                including through its MOEquity determinations and reimbursement, performance
                review, and ARP ESSER monitoring processes. Additionally, we reviewed and evaluated
                the tools that Illinois used to monitor LEA ARP ESSER plans and LEAs’ use of ARP ESSER
                funds, including reviewer checklists, standardized forms and templates, and risk
                assessment framework. The purposes of these document reviews were to gain an
                understanding of how Illinois administered and monitored ARP ESSER funds and assess
                the adequacy of those activities within the context of the audit objective. We also
                gained an understanding of Chicago’s and Waukegan’s processes for reviewing and
                approving ARP ESSER expenditures, which was generally done to help us complete our
                review of expenditures at the two LEAs in a timely and efficient manner and identify the
                cause of any deficiencies that might have been identified during our review (no
                deficiencies were identified for Chicago and Waukegan).

                Review of Illinois’ Oversight of LEA ARP ESSER Plans. We reviewed the summary results
                from Illinois’ review of LEA ARP ESSER application and plan submissions to verify that
                Illinois approved the plans for all 801 LEAs that had applied for and received ARP ESSER
                funds on or before March 31, 2023, and assess the rigor 30 of Illinois’ LEA ARP ESSER plan




30
  For purposes of assessing the rigor of Illinois’ plan review and approval processes, we considered the
number of reviews that Illinois performed, the reasons why Illinois did not initially approve plans, and
the overall scrutiny that the plan reviewers applied for each requirement.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                       30
               review and approval processes. We also reviewed the ARP ESSER plans for 16 LEAs 31 to
               determine whether they met applicable requirements, including the requirements that
               plans be posted on the LEA website, be in an understandable and uniform format and
               accessible to all parents, and adequately describe how funds will be used and how the
               LEA engaged in meaningful consultation with stakeholders. For 2 of the 16 LEAs (Chicago
               and Waukegan), we reviewed additional documentation (such as ARP ESSER grant
               applications, plan approval documents, and related correspondence) to verify that
               Illinois followed its established ARP ESSER plan review and approval process and was
               consistent in how it reviewed and approved the two plans.

               Review of Illinois’ Oversight of LEAs’ Use of ARP ESSER Funds. We reviewed samples of
               ARP ESSER expenditures at Chicago and Waukegan to determine whether they used ARP
               ESSER funds in accordance with applicable requirements. Specifically, we reviewed each
               sampled expenditure to determine whether it was (a) connected to the pandemic,
               (b) authorized under applicable regulations, and (c) reasonable and necessary in
               accordance with 2 C.F.R. Part 200, Uniform Administrative Requirements, Cost
               Principles, and Audit Requirements for Federal Awards. We also reviewed each
               expenditure to determine whether it aligned with the LEAs’ approved ARP ESSER plans.
               Lastly, we reviewed the LEAs' procurement activities for each expenditure to verify that
               the LEAs followed their established processes in this area. See the Sampling
               Methodology section for additional information.

               Sampling Methodology
               To determine whether Illinois had an adequate oversight process to ensure that LEAs
               used ARP ESSER funds in accordance with applicable requirements and their approved
               ARP ESSER plans, we selected 2 LEAs from the universe of 801 LEAs that had applied for
               and received ARP ESSER funds on or before March 31, 2023, and tested a total of
               26 expenditures for the 2 LEAs (13 expenditures for each LEA). To select the 2 LEAs for
               review, we first limited the universe of LEAs eligible for selection to the 10 LEAs with the
               largest ARP ESSER allocations. We then judgmentally selected for review the LEA with
               the largest ARP ESSER funding allocation (Chicago). For the second LEA, we limited the
               universe of LEAs eligible for selection to those LEAs that had spent at least 30 percent of
               their ARP ESSER allocation as of December 31, 2022. From the limited universe of four
               LEAs, we judgmentally selected an LEA (Waukegan) that had expenditures of different
               types, including expenditures for technology, capital improvements, and learning loss.



31
  We selected the 16 LEAs for review because they were the 16 largest LEAs in terms of awarded ARP
ESSER funds.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                        31
              For Chicago, we selected (using both judgmental and random sampling) a nonstatistical
              sample of 13 ARP ESSER expenditures from a total population of 1,465,509 ARP ESSER
              expenditures as of March 31, 2023. The 13 expenditures represented $11,985,312
              (2 percent) of the $660,251,221 in total ARP ESSER expenditures. To select our sample,
              we first removed from the universe any expenditures that were less than $5,000. Next,
              we divided the expenditures into two strata: one for learning loss (totaling
              $152,730,974) and one for all other expenditures (totaling $105,659,234). We then
              selected samples as follows:

                  •   From the learning loss population, we judgmentally selected three
                      expenditures, totaling $10,904,470. We selected these expenditures because
                      they were high dollar, had unclear descriptions, or both.
                  •   From the other expenditures population, we selected 10 expenditures, totaling
                      $1,080,842. First, we judgmentally selected three expenditures, totaling
                      $1,036,196. We selected these expenditures because they were high dollar, had
                      unclear descriptions, or both. Next, from the remaining population we randomly
                      selected seven expenditures, totaling $44,646.
              For Waukegan, we selected (using both judgmental and random sampling) a
              nonstatistical sample of 13 ARP ESSER expenditures (2 percent) from a total population
              of 820 ARP ESSER expenditures as of March 31, 2023. The 13 expenditures represented
              $5,036,914 (20 percent) of the $25,486,819 in total ARP ESSER expenditures. To select
              our sample, we first divided the expenditures into two strata: one for learning loss
              (totaling $8,730,281) and one for all other expenditures (totaling $16,756,538). Next, we
              removed from each stratum any expenditures that were less than $5,000. After
              removing these items, the learning loss population and other expenditures population
              totaled $8,690,146 and $16,396,006, respectively. We then selected samples as follows:

                  •   From the learning loss population, we randomly selected three expenditures,
                      totaling $115,353.

                  •   From the other expenditures population, we selected 10 expenditures, totaling
                      $4,921,560. First, we judgmentally selected three expenditures, totaling
                      $2,754,961. We selected these expenditures because they were high dollar, had
                      unclear descriptions, or both. Next, from the remaining population we randomly
                      selected seven expenditures, totaling $2,166,599.
              The results of our testing apply only to the samples selected and cannot be projected.




U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                       32
              Use of Computer-Processed Data
              We relied, in part, on computer-processed data (spreadsheets) from Chicago’s and
              Waukegan’s accounting systems. We obtained the universe of ARP ESSER expenditures
              as of March 31, 2023, for Chicago and Waukegan. We used the universes to select
              samples of expenditures for detailed testing to determine whether the two LEAs used
              their ARP ESSER funds in accordance with applicable requirements and their approved
              ARP ESSER plans. To assess the completeness of the data for both LEAs, we compared
              the total expenditures in the LEA spreadsheets to the total expenditures that the LEAs
              reported in their EER forms as of March 31, 2023. To assess the reliability of expenditure
              data for both LEAs, we reviewed supporting documentation, such as invoices and payroll
              records, for our sample of 26 expenditures (13 expenditures for each LEA). We did not
              identify any issues and concluded that the data from Chicago’s and Waukegan’s
              accounting systems were reliable for their intended use.

              Internal Controls
              We obtained an understanding of all five areas of internal control (control environment,
              risk assessment, control activities, information and communication, and monitoring) as
              they relate to Illinois’ processes for ensuring that LEA ARP ESSER plans meet applicable
              requirements and LEAs use ARP ESSER funds in accordance with applicable
              requirements and their approved LEA ARP ESSER plans. At the SEA level, we limited our
              internal control work to the two areas we deemed significant to the audit objective: risk
              assessment and control activities.

                  •   Risk assessment—risk identification, analysis of risk, responses to risk, including
                      consideration of the potential for fraud.
                  •   Control activities—design of appropriate types of control activities, design of
                      control activities at various levels, documentation of responsibilities through
                      policies, and periodic review of control activities.
              At the LEA level, we limited our internal control work to gaining an understanding of the
              LEAs’ processes (controls) within the context of the individual expenditures selected for
              testing which would help us determine the underlying cause for any identified
              deficiencies.

              As discussed in the findings, we concluded that Illinois’ process (control activities) for
              ensuring that LEA ARP ESSER plans met applicable requirements was generally adequate
              but did not ensure that plans were submitted within a reasonable timeframe (Finding 1)
              and its process for reviewing and approving LEA ARP ESSER reimbursement requests
              could be strengthened in a key area (Finding 2).



U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                        33
              Compliance with Standards
              We conducted this performance audit in accordance with generally accepted
              government auditing standards. Those standards require that we plan and perform the
              audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our
              findings and conclusions based on our audit objective. We believe that the evidence
              obtained provides a reasonable basis for our findings and conclusions based on our
              audit objectives.

              We remotely conducted our audit from April 2023 through January 2024. We discussed
              the results of our audit with Illinois officials on January 9, 2024.




U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                  34
                  Appendix B. Allowable Uses of ESSER Funds
                  Activities that an LEA may support with ESSER funds available include the following. 32

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


32
     Per section 18003(d) of the CARES Act, section 313(d) of CRRSAA, and section 2001(e) of ARP.


U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                            35
                  learning to all students, providing guidance for carrying out requirements under the
                  IDEA and ensuring other education services can continue to be provided consistent
                  with all Federal, State, and local requirements.
              13. Purchasing educational technology (including hardware, software, and connectivity)
                  for students who are served by the LEA that aids in regular and substantive
                  educational interaction between students and their classroom instructors, including
                  low-income students and students with disabilities, which may include assistive
                  technology or adaptive equipment.
              14. Providing mental health services and supports, including through the
                  implementation of evidence-based full-service community schools.
              15. Planning and implementing activities related to summer learning and enrichment
                  and supplemental after-school programs, including providing classroom instruction
                  or online learning during the summer months and addressing the needs of low-
                  income students, students with disabilities, English learners, migrant students,
                  students experiencing homelessness, and children and youth in foster care.
              16. Addressing the academic impact of lost instructional time among an LEA’s students,
                  including low-income students, students with disabilities, English learners, racial and
                  ethnic minorities, students experiencing homelessness, and children and youth in
                  foster care, including by
                      a. administering and using high-quality assessments that are valid and reliable
                         to accurately assess students’ academic progress and assist educators in
                         meeting students’ academic needs, including through differentiating
                         instruction;
                      b. implementing evidence-based activities to meet the comprehensive needs
                         of students;
                      c. providing information and assistance to parents and families on how they
                         can effectively support students, including in a distance learning
                         environment; and
                      d. tracking student attendance and improving student engagement in distance
                         education.
              17. School facility repairs and improvements to enable operation of schools to reduce
                  risk of virus transmission and exposure to environmental health hazards, and to
                  support student health needs.
              18. Inspection, testing, maintenance, repair, replacement, and upgrade projects to
                  improve the indoor air quality in school facilities, including mechanical and non-
                  mechanical heating, ventilation, and air conditioning systems, filtering, purification

U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                       36
                  and other air cleaning, fans, control systems, and window and door repair and
                  replacement.
              19. Developing strategies and implementing public health protocols including, to the
                  greatest extent practicable, policies in line with guidance from the CDC for the
                  reopening and operation of school facilities to effectively maintain the health and
                  safety of students, educators, and other staff.
              20. Other activities that are necessary to maintain the operation of and continuity of
                  services in the LEA and continuing to employ existing staff of the LEA.




U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                                        37
              Appendix C. Acronyms and Abbreviations
               ARP                  American Rescue Plan
               CARES Act            Coronavirus Aid, Relief, and Economic Security Act
               CDC                  Centers for Disease Control and Prevention
               C.F.R.               Code of Federal Regulations
               Chicago              Chicago Public School District 299
               CRRSAA               Coronavirus Response and Relief Supplemental
                                    Appropriations Act
               Department           U.S. Department of Education
               EER                  Electronic Expenditure Report
               ESEA                 Elementary and Secondary Education Act
               ESSER                Elementary and Secondary School Emergency Relief
               FY                   fiscal year
               GAO                  Government Accountability Office
               IFR                  interim final requirements
               Illinois             Illinois State Board of Education
               IWAS                 Illinois Web Application System
               LEA                  local educational agency
               MOEquity             Maintenance of Equity
               Performance report   Grant Periodic Performance Report
               SEA                  State educational agency
               U.S.C.               United States Code
               Waukegan             Waukegan Community Unit School District 60




U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                                                                         38
              Illinois’ Comments




U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133                   39
U.S. Department of Education
Office of Inspector General
ED-OIG/A22CA0133               40


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