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/
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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.
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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.
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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
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recommendations. We made clarifying edits to the report in response to technical
comments provided by the Department.
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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.
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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).
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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.
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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.
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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.
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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.
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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.
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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).
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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).
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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.
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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.
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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.
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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.
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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.
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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.
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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
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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.
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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.
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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.
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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).
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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.
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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.
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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
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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.
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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
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Illinois’ Comments
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