Lower Kuskokwim School District's Use of Elementary and Secondary School Emergency Relief Funds (ED-OIG/F24NY0181)
Summary
A U.S. Department of Education Office of Inspector General flash report, ED-OIG/F24NY0181, dated September 26, 2024, on Lower Kuskokwim School District's use of Elementary and Secondary School Emergency Relief (ESSER) funds, with a transmittal letter to Commissioner Deena M. Bishop of the Alaska Department of Education and Early Development signed /s/ Myra Hamilton. The report states that the district was allocated approximately $47.1 million in ESSER funds and had spent about $43 million (91 percent) as of March 11, 2024. The OIG determined that all the ESSER expenditures it reviewed were allowable and that the district complied with key Federal procurement requirements for each expenditure reviewed. Because it identified no exceptions, the report includes no recommendations.
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- Issuer
- U.S. Department of Education, Office of Inspector General
- Document type
- Report
- Date
- 2024-09-26
Cite this document
“Lower Kuskokwim School District's Use of Elementary and Secondary School Emergency Relief Funds (ED-OIG/F24NY0181).”
U.S. Department of Education, Office of Inspector General, dated 2024-09-26. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/lower-kuskokwim-school-district-esser/
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U.S. Department of Education
Office of Inspector General
Lower Kuskokwim School
District’s Use of Elementary and
Secondary School Emergency
Relief Funds
September 26, 2024
ED-OIG/F24NY0181
FLASH REPORT
NOTICE
In accordance with Freedom of Information Act (Title 5, United States Code,
Section 552), reports that the Office of Inspector General issues are available to
members of the press and general public to the extent information they contain is not
subject to exemptions in the Act.
UNITED STATES DEPARTMENT OF EDUCATION
OFFICE OF INSPECTOR GENERAL
Audit Services
September 26, 2024
Deena M. Bishop. Ed.D.
Commissioner
Alaska Department of Education and Early Development
PO Box 110500
Juneau, Alaska 99811
Dear Commissioner Bishop:
Enclosed is our final report, “Lower Kuskokwim School District’s Use of Elementary and Secondary
School Emergency Relief Funds,” Control Number ED-OIG/F24NY0181. This report incorporates the
comments you provided in response to the draft report. The U.S. Department of Education’s policy is to
expedite audit resolution by timely acting on findings and recommendations. Therefore, if you have any
additional comments or information that you believe may have a bearing on the resolution of this
review, you should send them directly to the following Department of Education official, who will
consider them before taking final Departmental action on this review:
Adam Schott
Delegated the Authority to Perform the Functions and Duties of the Assistant Secretary Office of
Elementary and Secondary Education
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202
We appreciate your cooperation during this review. If you have any questions, please contact me at
(214) 790-5430 or Myra.Hamilton@ed.gov.
Sincerely,
/s/
Myra Hamilton
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.
U.S. Department of Education, Office of Inspector General
Results in Brief
Lower Kuskokwim School District’s Use of Elementary and
Secondary School Emergency Relief Grant Funds
Why the OIG Performed What Did the OIG Find?
This Work We determined that all the ESSER expenditures we reviewed for Lower Kuskokwim were
Congress passed three coronavirus allowable and in accordance with applicable requirements. Allowable activities generally
relief acts within a 1-year period that include those authorized by the Elementary and Secondary Education Act, Individuals with
provided more than $275 billion for Disabilities Education Act, Adult Education and Family Literacy Act, Carl D. Perkins Career
an Education Stabilization Fund to and Technical Education Act of 2006, and subtitle B of title VII of the McKinney-Vento
prevent, prepare for, and respond to Homeless Assistance Act. It also includes activities listed in section A-3 of the U.S.
the coronavirus, which the President Department of Education’s Frequently Asked Questions document for the ESSER and
declared as a national emergency in Governor’s Emergency Education Relief Programs.
March 2020. This included
We also found that Lower Kuskokwim complied with key Federal procurement
$189.5 billion for Elementary and
requirements, including those covering the procurement methods to be followed and
Secondary School Emergency Relief
contract cost, price, and provisions, when procuring the goods or services associated with
(ESSER), funds intended to provide
each ESSER expenditure we reviewed.
vital support to States, local
educational agencies, and schools to What Are the Next Steps?
address the impact of the Because we identified no exceptions, our report does not include recommendations.
coronavirus. Support, in part, However, our results are limited to the ESSER expenditures we reviewed, and it is critical
includes activities designed to help that any remaining ESSER funds continue to be used appropriately.
students and educators safely return
Alaska and Lower Kuskokwim had no comments on our draft report.
to and sustain in-person instruction,
and that address the educational
inequities exacerbated by the
coronavirus pandemic and students’
social, emotional, mental health, and
academic needs.
Ensuring that ESSER funds are used
for allowable purposes is critical to
help address the needs of students
and educators. The Lower
Kuskokwim School District (Lower
Kuskokwim) was allocated
approximately $47.1 million in ESSER
funds to support 29 schools serving
about 4,000 students.
We performed this review to
determine whether Lower
Kuskokwim expended ESSER grant
funds for allowable purposes in
accordance with applicable
requirements.
Flash Report ED-OIG/F24NY0181
Purpose
The objective of our flash review was to determine whether the Lower Kuskokwim
School District (Lower Kuskokwim) expended Elementary and Secondary School
Emergency Relief (ESSER) 1 grant funds for allowable purposes in accordance with
applicable requirements. This flash review report presents the results of our review.
Lower Kuskokwim School District
The Lower Kuskokwim School District in Alaska is a local educational agency (LEA) in
rural remote setting with 29 schools serving about 4,000 students. Lower Kuskokwim
was allocated approximately $47.1 million in ESSER funds, and as of March 11, 2024, it
had spent about $43 million (91 percent) of its $47.1 million ESSER allocation to address
the impacts of the coronavirus pandemic. For our review period, Lower Kuskokwim
received $29 million in ESSER funds, $24.7 million of which were American Rescue Plan
(ARP) ESSER funds. In its approved ARP ESSER Plan, Lower Kuskokwim noted that it
planned to use its ARP ESSER funds, in part, for additional instructional aides, robust
summer school, intensive and extended day opportunities for students, professional
development for instructional staff, and a data analysis specialist. Additionally, its funds
were to be used, in part, for increases in custodial hours for cleaning and sanitization;
ventilation improvements; air purifiers; materials to ensure universal masking, hand
hygiene, and social distancing; cameras for contact tracing and monitoring social
distancing; and buses and staff to allow for socially distanced transportation to and from
in-person learning.
Results of Our Review
For the selected transactions covered by our review, Lower Kuskokwim expended ESSER
grant funds for allowable purposes and in accordance with applicable requirements. We
1
ESSER is one of multiple emergency relief funds comprising the Education Stabilization Fund, which
was first authorized and funded under the Coronavirus Aid, Relief, and Economic Security Act
(March 27, 2020), and for which Congress later provided additional funding under the Coronavirus
Response and Relief Supplemental Appropriations Act (December 27, 2020) and the American Rescue
Plan (March 11, 2021). Under ESSER, the U.S. Department of Education awarded grants to State
educational agencies for the purpose of providing local educational agencies with emergency relief
funds to address the impacts that the coronavirus pandemic had on elementary and secondary schools
and their students.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0181 1
selected and reviewed 16 non-personnel and 4 personnel ARP ESSER 2 expenditures (less
than 1 percent) from a total population of 8,548 ARP ESSER expenditures for the period
July 1, 2022, through June 30, 2023 (review period). We used a judgmental, risk-based
process to select the 20 expenditures that represented $8,529,895 (52 percent) of the
$16,439,545 in total ARP ESSER expenditures during our review period.
We reviewed each expenditure to determine whether it was (1) connected to the
coronavirus pandemic (intended to prevent, prepare for or respond to the coronavirus
pandemic, including its impact on the social, emotional, mental health, and academic
needs of students); (2) an authorized use of ESSER funds under applicable law and
regulations; and (3) reasonable and necessary and otherwise permissible under the
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards (Uniform Guidance, 2 Code of Federal Regulations (C.F.R.) part 200). We
also performed additional work, as needed, to determine whether Lower Kuskokwim
complied with key Federal procurement requirements, specifically those covered under
2 C.F.R. sections 200.320 (methods of procurement to be followed), 200.324 (contract
cost and price), and 200.327 (contract provisions), when procuring the goods or services
associated with each expenditure. We interviewed Lower Kuskokwim officials to gain a
basic understanding of how they used ESSER funds, and their processes for approving
and monitoring ESSER expenditures.
An LEA can use ESSER funds for any activity deemed allowable under section 18003(d) of
the Coronavirus Aid, Relief, and Economic Security Act (P.L. 116-136); section 313(d) of
the Coronavirus Response and Relief Supplemental Appropriations Act (P.L. 116-260);
and section 2001(e) of the American Rescue Plan Act (P.L. 117-2). These activities
generally include any activity authorized by the Elementary and Secondary Education
Act, Individuals with Disabilities Education Act, Adult Education and Family Literacy Act,
Carl D. Perkins Career and Technical Education Act of 2006, and subtitle B of title VII of
the McKinney-Vento Homeless Assistance Act; as well as those listed in section A-3 of
the U.S. Department of Education’s Frequently Asked Questions document for the
ESSER and Governor’s Emergency Education Relief Programs (May 2021, and updated
on December 7, 2022).
We determined that all 20 (100%) expenditures that we reviewed for Lower Kuskokwim
were used for allowable purposes and in accordance with applicable requirements.
These expenditures were generally for indirect costs, iPads, educational software,
construction costs, equipment, internet service, travel reimbursement, training, and
2
We limited the scope of our review to ARP ESSER expenditures because they represented the highest
dollar amount of ESSER expenditures when compared to other ESSER funds during our review period.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0181 2
payroll. They were connected to the coronavirus pandemic, authorized uses of ESSER
funds under applicable law and regulations, and reasonable and necessary and
otherwise permissible under Uniform Guidance. In addition, we found that Lower
Kuskokwim complied with key Federal procurement requirements covered under
2 C.F.R. sections 200.320, 200.324, and 200.327 when procuring the goods or services
associated with each expenditure.
Because all the expenditures we reviewed were for allowable purposes and in
accordance with applicable requirements, we make no recommendations in this report.
However, our results are limited to the ESSER expenditures we reviewed, and it is critical
that any remaining ESSER funds continue to be used appropriately.
Alaska Department of Education and Early Development’s
Comments
The Alaska Department of Education and Early Development had no comments on the
draft report since no issues were identified. Lower Kuskokwim also had no comments on
this report.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0181 3
Appendix A. Scope and Methodology
Our review covered Lower Kuskokwim’s ARP ESSER expenditures from July 1, 2022,
through June 30, 2023 (review period). We limited the scope of our review to ARP ESSER
funds because Lower Kuskokwim’s ARP ESSER funds represented the highest dollar
amount ($24.7 million) of all ESSER funds ($29 million) that were allocated to and
expended by them during our review period. We also limited our internal control work
to gaining a basic understanding of the process that Lower Kuskokwim used to account
for ESSER funds including the accounting system and accounting codes used by Lower
Kuskokwim. We conducted our review remotely from April 2024 through July 2024. We
discussed the results of our review with Lower Kuskokwim and Alaska Department of
Education and Early Development officials on July 9, 2024.
Sampling Methodology
To determine whether Lower Kuskokwim expended ARP ESSER grant funds during our
review period for allowable purposes in accordance with applicable requirements, we
selected and reviewed 20 expenditures (less than 1 percent) from a total population of
8,548 expenditures using a judgmental, risk-based, selection process. We stratified the
population between personnel and non-personnel expenditures and selected 16 non-
personnel expenditures and 4 personnel expenditures. The 16 non-personnel
expenditures (1 percent) were selected from a total of 1,233 non-personnel ARP ESSER
expenditures and represented $8,390,546 (66 percent) of the $12,809,181 in total non-
personnel ARP ESSER expenditures from our review period. The 4 personnel
expenditures (less than 1 percent) were selected from the total population of
7,315 personnel expenditures and represented $139,349 (4 percent) of the
$3,630,363 in total personnel ARP ESSER expenditures from our review period.
We selected the 20 expenditures using one or a combination of the following criteria:
For non-personnel expenditures, we selected the highest dollar transactions for each of
the 17 unique account descriptions above $1,808, and for personnel expenditures, we
selected the highest dollar transactions for each of the 9 unique account descriptions
above $23,007. We selected the 16 highest dollar non-personnel expenditures per
account description and the 4 highest dollar personnel expenditures per account
description. Since the expenditures were selected using a judgmental, risk-based,
selection process, the results of our testing cannot be projected to the universe of ARP
ESSER expenditures.
Use of Computer-Processed Data
We relied, in part, on computer-processed data (LEA expenditure data) from Lower
Kuskokwim’s accounting system. Lower Kuskokwim provided us with a PDF of a report
generated from its accounting system that contained its ARP ESSER expenditure data
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0181 4
from July 1, 2022, through June 30, 2023. We converted the PDF document to a
spreadsheet for quicker review and analysis. To assess the completeness of the
expenditure data in the spreadsheet, we compared total expenditures in the
spreadsheet to total expenditures in the four quarterly ARP ESSER expenditure reports
that Lower Kuskokwim submitted to the Alaska Department of Education and Early
Development for our review period. To assess the reliability of the expenditure data in
the spreadsheet, we reviewed supporting documentation, such as invoices and proof of
payment, for the 20 expenditures covered by our review. We did not identify any issues
and concluded that the expenditure data in the spreadsheet were reliable for their
intended use.
Compliance with Standards
We conducted our work in accordance with OIG quality control standards and the
Council of the Inspectors General on Integrity and Efficiency “Quality Standards for
Federal Offices of Inspector General,” which require that we conduct our work with
integrity, objectivity, and independence. We believe that the information obtained
provides a reasonable basis for our conclusions.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0181 5
Appendix B: Acronyms and Abbreviations
ARP American Rescue Plan
C.F.R. Code of Federal Regulations
ESSER Elementary and Secondary School Emergency Relief
LEA local educational agency
Lower Kuskokwim Lower Kuskokwim School District
Uniform Guidance Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0181 6
Alaska Department of Education and Early
Development’s Comments
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0181 7
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