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Michigan's Administration of the Governor's Emergency Education Relief Fund Grant (ED-OIG/A20GA0039)

Summary

A final audit report, ED-OIG/A20GA0039, dated September 14, 2022, from the U.S. Department of Education Office of Inspector General on Michigan's administration of the Governor's Emergency Education Relief Fund (GEER) grant, with a transmittal letter to Governor Whitmer signed /s/ Selina Boyd. The review covers March 13, 2020, through May 10, 2022, and Michigan's GEER grant of $89.4 million. It finds that Michigan could not support its awards to four entities under five programs, totaling $5.4 million, and that the Michigan Department of Education did not have a written plan to monitor its GEER grant subgrantees. It also states that processes for the K-12 GEER and Future for Frontliners programs ensured that $84 million was used to support local educational agencies most significantly impacted by the coronavirus and institutions of higher education.

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Issuer
U.S. Department of Education, Office of Inspector General
Document type
Report
Date
2022-09-14

Cite this document

“Michigan's Administration of the Governor's Emergency Education Relief Fund Grant (ED-OIG/A20GA0039).” U.S. Department of Education, Office of Inspector General, dated 2022-09-14. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/michigan-geer-administration/, SHA-256 fccfcd1b4f3fcb17b7ba1cd0091f6e1c64e009fa6f26f5f743f4689f5175a214.

Full text

Michigan’s Administration of the
Governor’s Emergency Education
Relief Fund Grant
September 14, 2022
ED-OIG/A20GA0039

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




September 14, 2022


The Honorable Gretchen Whitmer
Governor, State of Michigan
P.O. Box 30013
Lansing, Michigan 48909


Dear Governor Whitmer:

Enclosed is our final audit report, “Michigan’s Administration of the Governor’s Emergency Education
Relief Fund,” Control Number ED-OIG/A20GA0039. This report incorporates the comments you provided
in response to the draft report. 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[s], who will consider them before taking final Departmental action on
this audit:

        Mark Washington
        Deputy Assistant Secretary
        U.S. Department of Education
        400 Maryland Ave. SW
        Washington, D.C. 20202

The U.S. Department of Education’s policy is to expedite audit resolution by timely acting on findings
and recommendations. Therefore, if you have additional comments, we would appreciate receiving
them within 30 days.

Sincerely,

/s/

Selina Boyd
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 ........................................................................................................................ 7
Finding 1. Michigan Did Not Maintain Sufficient Documentation to Support GEER Fund
Grant Awards Made to Four Education-Related Entities ................................................. 12
Finding 2. Michigan Did Not Design and Implement Sufficient GEER Fund Monitoring
Processes For Some Of Its Subgrantees............................................................................ 24
Appendix A. Scope and Methodology............................................................................... 33
Appendix B. Acronyms and Abbreviations........................................................................ 43
Michigan’s Comments ...................................................................................................... 44
                Results in Brief
                What We Did
                The objectives of the audit were to determine whether the State of Michigan (Michigan)
                designed and implemented awarding processes that ensured that the Governor’s
                Emergency Education Relief Fund (GEER grant) was used to support local educational
                agencies (LEAs) and institutions of higher education (IHEs) that were most significantly
                impacted by the coronavirus or LEAs, IHEs, or other education-related entities within
                the State that were deemed essential for carrying out emergency educational services;
                and monitoring processes to ensure that subgrantees used GEER grant funds in
                accordance with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) and
                other applicable Federal requirements. 1 Our review covered the first of two GEER grants
                that Michigan received, including the processes that it used to award and monitor GEER
                grant funds, for the period March 13, 2020, through May 10, 2022.

                To accomplish our objectives, we reviewed relevant Federal laws, regulations, and
                guidance. We assessed Michigan’s awarding processes for the seven programs 2 it
                funded with the GEER grant, including Michigan’s methodology and criteria for
                identifying the LEAs and intermediate school districts (ISDs) 3 most significantly impacted
                by the coronavirus and IHEs and other education-related entities deemed essential for
                carrying out emergency educational services. To assess Michigan’s awarding processes,
                we interviewed Michigan officials who awarded the GEER grant funds; reviewed
                samples of grant applications from eligible entities that Michigan funded to determine
                whether Michigan followed its established award processes; reviewed Michigan’s
                allocations to LEAs and ISDs to assess the accuracy and completeness of the allocation



1
 The CARES Act authorizes Governors to provide grants to LEAs and IHEs within their jurisdiction that
have been most significantly impacted by coronavirus, and to use funds to provide support to other
LEAs, IHEs, and education-related entities that the Governor deems essential for carrying out emergency
educational services, providing childcare and early childhood education, providing social and emotional
support, and protecting education-related jobs.
2
 The seven programs are K–12 GEER, Future for Frontliners, Evolution Labs, Building Healthy
Communities: Step Up for School Wellness, Statewide public television, teacher professional learning,
and Early On.
3
 Michigan has regular school districts and intermediate school districts (which serve multiple regions).
They are both considered LEAs by the State; however, for purposes of this document we only refer to
the regular school districts as LEAs.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                           1
               methodology; and reviewed Michigan’s drawdowns from the U.S Department of
               Education’s G5 grants management system to determine whether Michigan complied
               with cash management requirements.

               We also assessed Michigan’s processes for monitoring the entities to which it awarded
               GEER grant funds, including its GEER grant reimbursement processes. Our assessment
               included a review of a sample of 30 Future for Frontliners (FFF) program students 4 to
               determine whether Michigan officials followed their reimbursement processes and the
               amounts requested for reimbursement were calculated correctly and were supported.
               Our assessment also included a 100 percent review of the GEER grant expenditures
               reimbursed to three education-related entities that were awarded grant funds to
               determine whether the entities used GEER grant funds for allowable purposes. 5

               What We Found

               Grant Awards
               For five of the seven programs that Michigan funded with its GEER grant (Evolution
               Labs, Building Healthy Communities: Step Up for School Wellness, Statewide public
               television, teacher professional learning, and Early On), Michigan could not support that
               it awarded the funds to eligible entities that were deemed essential for carrying out
               emergency educational services, providing childcare and early childhood education,
               providing social and emotional support, or protecting education-related jobs. As a
               result, Michigan lacks assurance that its awards to four entities under these programs—
               totaling $5.4 million of the State’s $89.4 million GEER grant—aligned with the purpose
               of the GEER grant fund. However, for the other two (K–12 GEER and FFF) programs,
               Michigan Department of Education (MDE) and Michigan’s State Budget Office designed
               and implemented awarding processes that ensured that $84 million of its $89.4 million
               GEER grant was used to support LEAs that were most significantly impacted by the
               coronavirus, as determined by the State, and IHEs within the State that it deemed
               essential for carrying out emergency educational services. We also found that the
               factors Michigan included in the allocation methodologies for the two programs aligned




4
 The sample of 30 FFF students included 25 students in the FFF Path 1 program and 5 students in the
Path 2 program.
5
 The three education-related entities administered four programs. We did not review a sample of
expenditures for allowability for the other two (K–12 GEER and Early On programs) of the seven GEER
grant programs because MDE did not require grant recipients to submit supporting documentation with
their reimbursement requests.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                        2
               with the intent of the CARES Act to support LEAs most significantly impacted by
               coronavirus and IHEs deemed essential for carrying out emergency educational services.

               In awarding GEER grant funds to entities for all seven of its programs, we found that
               Michigan adhered to Federal requirements for pass-through entities to clearly identify
               subawards to subrecipients and to provide those subrecipients with certain required
               information at the time of the subawards. 6 We also found that Michigan ensured that
               the LEAs, ISDs, and education-related entities that received a GEER grant allocation
               submitted the required applications and assurances. We found that Michigan followed
               cash management requirements. (Finding 1 of this report)

               Monitoring Processes
               MDE did not have a written plan to monitor its GEER grant subgrantees. It had planned
               to contract with an audit firm to conduct monitoring of its GEER grant subgrantees;
               however, as of March 30, 2022, the contract had not been finalized. MDE did, however,
               conduct some monitoring activities and implement reimbursement processes for its
               subgrantees. For two (K–12 GEER and Early On programs) of the seven programs MDE
               funded with its GEER grant, the monitoring activities and reimbursement processes that
               MDE designed and implemented to ensure that the subgrantees used the GEER grant
               funds in accordance with the CARES Act and other applicable Federal requirements did
               not provide reasonable assurance that the entities used the funds for allowable
               purposes. Specifically, MDE did not require the subgrantees to submit documentation to
               support expenditures, and one of the monitoring activities was not applicable to
               subgrantees that would not receive an annual single audit. 7

               We also found that for one (FFF scholarship program) of Michigan’s seven programs,
               although Michigan’s Departments of Treasury and Labor and Economic Opportunity
               designed and implemented a reimbursement process for IHEs that provided assurance
               that reimbursements were for students who met eligibility and enrollment
               requirements, additional monitoring is needed for the FFF Path 1 program to ensure
               that IHEs’ requested reimbursement amounts are accurately calculated. For the FFF




6
 For the FFF scholarship program, MDE had an interagency agreement with Michigan’s Departments of
Treasury and Labor and Economic Opportunity, who administered the program.
7
 An annual single audit is an audit conducted in accordance with the Single Audit Act Amendments of
1996; the OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards (2 Code of Federal Regulations Part 200); the OMB Compliance Supplement; and
Government Auditing Standards.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                        3
              Path 2 scholarship program, we found the monitoring activities and reimbursement
              process to be sufficient.

              For the remaining four (Evolution Labs, Building Healthy Communities: Step Up for
              School Wellness, television broadcast service for teachers and students, and teacher
              professional learning programs) of Michigan’s seven programs, MDE designed and
              implemented a reimbursement process that provided reasonable assurance that the
              GEER grant funds were used in accordance with the CARES Act and other Federal
              requirements. Specifically, MDE developed a comprehensive reimbursement process to
              ensure the funds were being used for allowable purposes. (Finding 2 of this report)

              What We Recommend
              We recommend that the Assistant Secretary for the Office of Elementary and Secondary
              Education require the Governor of Michigan to—

                  •   provide documentation, or a full and detailed explanation, of the process
                      Michigan used to determine that the four education-related entities that
                      received GEER grant funds were essential for carrying out emergency
                      educational services, providing childcare and early childhood education,
                      providing social and emotional support, or protecting education-related jobs;
                  •   develop and implement a process to ensure that Michigan documents the
                      criteria and decisions made for awarding future GEER grant funds in accordance
                      with applicable requirements; and

                  •   timely design and implement a monitoring plan that will ensure that K–12 GEER
                      and Early On program subgrantees’ uses of GEER grant funds comply with the
                      CARES Act and other applicable Federal requirements. The monitoring plan
                      should include protocols to review, on at least a sample basis, and using a risk-
                      based approach, supporting documentation for subgrantee expenditures
                      charged to the GEER grant to provide assurance that funds were used for
                      allowable purposes.

                  •   Develop and implement a process to review, on at least a sample basis, and
                      using a risk-based approach, supporting documentation and award calculations
                      for the FFF Path 1 scholarship awards.
              We recommend that the Assistant Secretary for the Office of Elementary and Secondary
              Education—

              Take appropriate action if the documentation and other information provided by
              Michigan in response to the above recommendations does not support that the State
              followed applicable requirements.



U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                      4
              Michigan Comments and Our Response
              We provided a draft of this report to Michigan for comment. We summarize Michigan’s
              comments at the end of each finding and provide the full text of the comments at the
              end of the report.

              Michigan stated that it agreed, at least in part, with all of our findings and
              recommendations. Michigan identified corrective actions that it has taken or plans to
              take. In response to Finding 1, Michigan stated that it had a highly collaborative
              selection process, which aimed to identify programs that could be deployed quickly,
              have a Statewide impact, and support a full array of essential emergency educational
              services. Michigan stated that the documentation of the final funding recommendations
              provided to the Governor also referenced how each recommendation connected to
              applicable policy priorities and listed the entities not selected with descriptions of why
              they were not selected. Michigan also acknowledged that some aspects of the process
              were not as well-documented as they could have been.

              To address Recommendation 1.1, Michigan developed additional documentation that it
              included in its response outlining the process Michigan used to select the other
              education-related entities awarded GEER grant funds. In addition, Michigan stated that
              it intends to use this additional documentation to enhance its existing documentation
              supporting the decisions made for the GEER grant funds as a model to ensure that the
              criteria used, and decisions made, are adequately documented for future GEER grant
              funds should they become available. Michigan further stated that this enhanced
              documentation is intended to serve as the corrective action to address
              Recommendation 1.2.

              In response to Finding 2, Michigan stated that it was already developing monitoring
              protocols to sample and review supporting documentation for subgrantee expenditures.
              Michigan further stated that it has executed a contract with a consultant to complete
              the risk assessment and monitoring process for the K–12 GEER and Early On programs
              subgrantees’ use of GEER grant funds to ensure compliance with the CARES Act and
              other applicable Federal requirements. Michigan included a sample of a summary of key
              monitoring information for the K–12 GEER program with its response and stated that
              the same model will be used to assess and monitor the other six GEER-funded
              programs. Michigan also stated that it was already developing monitoring protocols to
              sample and review supporting documentation and award calculations for the FFF Path 1
              program.

              OIG Response
              Michigan’s proposed corrective actions, if properly implemented, are partially
              responsive to the two recommendations relating to Finding 1. Specifically, Michigan’s


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                      5
              response and the additional documentation included in its response describes the
              process used for selecting the other education-related entities awarded GEER grant
              funds. However, although the additional documentation states that the final funding
              recommendations provided to the Governor listed the entities not selected with
              descriptions of why they were not selected, Michigan did not provide us with any
              documentation that included this information. To fully address Recommendation 1.1,
              Michigan should also ensure that it documents the reasons for not funding other
              entities that are considered for future GEER funding.

              Regarding Michigan’s proposed corrective action to address Recommendation 1.2, while
              the enhanced documentation could be used as a model for adequate documentation for
              future GEER grant funds, it will be important for Michigan to address the issues
              identified under Recommendation 1.1 above and also establish a process to ensure that
              documentation is developed.

              Michigan’s proposed corrective actions, if properly implemented, are responsive to the
              two recommendations relating to Finding 2. The monitoring plans described in
              Michigan’s response appear supportive of the State’s efforts to implement its proposed
              corrective actions. It will be important for Michigan to work with the Department to
              ensure that all recommendations are appropriately and sufficiently resolved and that
              corrective actions are fully implemented.

              We did not make any changes to the findings and recommendations in response to
              Michigan's comments.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                    6
                  Introduction
                  Purpose
                  The objectives of the audit were to determine whether the State of Michigan (Michigan)
                  designed and implemented awarding processes that ensured that the Governor’s
                  Emergency Education Relief Fund (GEER grant) was used to support local educational
                  agencies (LEA) and institutions of higher education (IHE) that were most significantly
                  impacted by the coronavirus or LEAs, IHEs, or other education-related entities within
                  the State that were deemed essential for carrying out emergency educational services;
                  and monitoring processes to ensure that subgrantees used GEER grant funds in
                  accordance with the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) and
                  other applicable Federal requirements. Our review covered the first of two GEER grants
                  that Michigan received, including the processes that it used to award and monitor GEER
                  grant funds, for the period March 13, 2020, through May 10, 2022.

                  Background

                  GEER Grant Authorized by the CARES Act
                  The CARES Act, 8 signed into law on March 27, 2020, provides a total of $30.75 billion for
                  the Education Stabilization Fund, of which approximately $3 billion was provided to
                  Governors to make awards to LEAs, IHEs, and other education-related entities 9 within
                  each State through the GEER grant. Congress intended the GEER grant to be an
                  emergency appropriation to address coronavirus-related disruptions and support a
                  State’s ability to continue to provide educational services to students and to support the
                  ongoing functionality of LEAs and IHEs. In accordance with section 18002(b) of the
                  CARES Act, the Secretary of the U.S. Department of Education (Department) awarded
                  GEER grant funds to Governors using the following factors: 60 percent of the State’s
                  allocation was based on the State’s relative population of individuals aged 5 through 24,
                  and 40 percent of the State’s allocation was based on the relative number of children




8
    Public Law No. 116-136.
9
 The Department’s “Frequently Asked Questions About the Governor’s Emergency Education Relief
Fund (GEER Fund)” document defines an education-related entity as a governmental, nonprofit or for-
profit entity within the State that provides services that support preschool, elementary, secondary, or
higher education.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                          7
                counted 10 under section 1124(c) of the Elementary and Secondary Education Act of
                1965, as amended. Governors that received a GEER grant were required by the
                Department to designate a fiscal agent, which could be the Office of the Governor or
                another State agency, to administer the GEER grant. The fiscal agent is responsible for
                overseeing and monitoring all GEER grant activities in the State.

                The Department was required to obligate funds by September 30, 2021, and States and
                their subgrantees are required to obligate funds by September 30, 2022. Unused funds
                must be returned to the Department.

                Allowable Uses of GEER Grant Funds
                Section 18002(c) of the CARES Act authorized GEER grant funds to be used to provide

                    •   emergency support through grants to LEAs that the State educational agency
                        (SEA) deems have been most significantly impacted by coronavirus to support
                        the ability of such LEAs to continue to provide educational services to their
                        students and to support the ongoing functionality of the LEA;
                    •   emergency support through grants to IHEs serving students within the State
                        that the Governor determines have been most significantly impacted by
                        coronavirus to support the ability of such institutions to continue to provide
                        educational services and support the ongoing functionality of the institution;
                        and
                    •   support to any other IHE, LEA, or education-related entity within the State that
                        the Governor deems essential for carrying out emergency educational services
                        to students for authorized activities described in section 18003(d)(1) 11 of the
                        CARES Act or the Higher Education Act of 1965, as amended, the provision of
                        childcare and early childhood education, social and emotional support, and the
                        protection of education-related jobs.




10
  For example, children counted for the purposes of making Title I, Part A formula grants to LEAs, or the
Title I, Part A formula count.
11
  Section 18003(d)(1) of the CARES Act authorizes LEAs to use GEER grant funds for any activity
authorized by the Elementary and Secondary Education Act of 1965, as amended, including the Native
Hawaiian Education Act and the Alaska Native Educational Equity, Support, and Assistance Act, the
Individuals with Disabilities Education Act, the Adult Education and Family Literacy Act, the Carl D.
Perkins Career and Technical Education Act of 2006, or subtitle B of title VII of the McKinney-Vento
Homeless Assistance Act.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                           8
                  The Department’s Administration of the GEER Grant
                  The Department notified Governors of their GEER grant allocations in April 2020 and
                  provided guidance on how to apply for the funds. To receive the State’s GEER grant
                  allocation, the Governors submitted a signed Certification and Agreement to the
                  Department by June 8, 2020. 12 The Certification and Agreement served as the
                  application to receive funds under the GEER grant, as provided in section 18002(a) of
                  the CARES Act. The Certification and Agreement included information on the State’s
                  planned uses of the GEER grant funds and programmatic, fiscal, and reporting
                  assurances. This included an assurance that within 45 days of receiving GEER grant
                  funds, the State would submit an initial report to the Department detailing its process
                  for awarding the funds to LEAs, IHEs, or other education-related entities, including the
                  criteria for determining entities that are most significantly impacted by coronavirus or
                  deemed essential for carrying out emergency educational services, and the State’s
                  methodology for formulating those criteria. The Certification and Agreement also
                  included a requirement that States submit quarterly reports to the Secretary on their
                  uses of funds.

                  To answer questions about information that may not be easily understood from reading
                  section 18002 and other parts of the CARES Act, the Department issued a Frequently
                  Asked Questions document. 13 The Department also encouraged SEAs to consult with the
                  Governor when making determinations of which LEAs were most significantly impacted
                  by coronavirus. In addition to the guidance document provided, the Department
                  provided technical assistance to State agencies through conference calls to discuss their
                  allocation methodologies and plans for using the funds, and to answer any questions
                  they might have.

                  Michigan’s GEER Grant Programs
                  The Governor of Michigan received $89.4 million in GEER grant funds. The Governor
                  identified the former Assistant Director of Michigan’s State Department of Education
                  (MDE), Office of Financial Management (Financial Management) as the State program
                  representative and MDE Financial Management as the fiscal agent for the GEER grant.
                  The Governor’s Office allocated $60 million to MDE, $24 million to Michigan’s
                  Departments of Treasury (Treasury) and Labor and Economic Opportunity (LEO), and




12
     The deadline was extended from its original date of June 1, 2020.
13
  “Frequently Asked Questions About the Governor’s Emergency Education Relief Fund (GEER Fund),”
https://oese.ed.gov/files/2020/10/FAQs-GEER-Fund.pdf (last visited May 11, 2022).


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                             9
                   $5.4 million to four other education-related entities 14 (Detroit Public Television,
                   Michigan Virtual University, the Michigan Elementary and Middle School Principals
                   Association, and MDE’s Office of Great Start).

                   MDE’s Program
                   MDE allotted $60 million in GEER grant funds for the K–12 GEER Program. The purpose
                   of the program was to provide grant funds to school districts 15 that had a significant
                   number of students in high need groups. 16 MDE provided grant packages to the school
                   districts that included an application, instructions on the application, and guidance on
                   allowable expenditures. Some of the allowable expenditures included connectivity;
                   student mental health; addressing learning loss; out-of-school-time learning; remote
                   learning materials and training; teacher training and curriculum; and health, safety, and
                   wellness. By electronically signing the application, the school districts agreed to comply
                   with all applicable GEER grant requirements.

                   Treasury’s and LEO’s Program
                   Treasury and LEO allotted $24 million in GEER grant funds for the Future for Frontliners
                   (FFF) scholarship program. The purpose of the program was to provide scholarships for
                   frontline workers 17 to attend a community college or an institution that provides adult
                   education. The FFF program included two paths. The Path 1 scholarship program was for
                   frontline workers to pursue an associate degree or industry-recognized certificate that is
                   eligible under the Federal Pell Grant (Pell) program. 18 The Path 2 scholarship program
                   was for frontline workers to obtain a high school diploma or its recognized equivalent by
                   enrolling at a State-approved adult education provider.




14
  Michigan Virtual University was allocated grant funds for two separate programs. For one of those
programs, Michigan Virtual University was in partnership with Michigan State University and the
University of Michigan.
15
     School districts included LEAs and intermediate school districts (which serve multiple regions).
16
  Michigan defined high needs groups as students who were identified as economically disadvantaged,
children with disabilities, or English language learners.

 According to Michigan’s FFF Frequently Asked Questions document, frontline workers were workers
17

who worked in an essential industry, such as healthcare, public safety, and grocery workers, during the
COVID-19 pandemic.
18
  Pell grants, authorized by Title IV of the Higher Education Act of 1965, as amended, are need-based
aid grants awarded to eligible undergraduate students.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                           10
                Detroit Public Television’s Program
                Detroit Public Television allotted $1.5 million in GEER grant funds for its Statewide
                public television program service. The purpose of the program was to support
                educational programming on public television to reach children where other virtual
                programming is challenging and to provide support for teachers on how to use the
                programming in conjunction with broader virtual or remote education plans.

                Michigan Virtual University’s, Michigan State University’s, and University of
                Michigan’s Program
                Michigan Virtual University, in partnership with Michigan State University and the
                University of Michigan allotted $1.4 million in GEER grant funds for the teacher
                professional learning program. The purpose of the program was to train teachers on
                how to implement the teacher professional learning standards developed by the
                Governor’s Education Advisory Council. 19

                Michigan Virtual University’s Program
                Michigan Virtual University allotted $1 million in GEER grant funds for the Evolution Labs
                program. The purpose of the program was to provide social-emotional learning support
                services for Michigan students, parents, and educators.

                Office of Great Start’s Program
                MDE’s Office of Great Start allotted $1 million in GEER grant funds for the Early On
                program. The funding was intended to allow MDE’s existing early intervention program
                for children aged 3 and under to reach more infants and toddlers through remote early
                intervention.

                Michigan Elementary and Middle School Principals Association’s Program
                The Michigan Elementary and Middle School Principal’s Association allotted $500,000 in
                GEER grant funds for the Building Healthy Communities: Step Up for Wellness program.
                The purpose of the program was to provide Statewide mental health supports 20 to
                students, teachers, and administrators.



19
  According to Michigan’s website, the Governor’s Education Advisory Council identifies issues
impacting the effectiveness of Michigan’s public education system and best practices in public education
and provides recommendations of corresponding changes, improvement, or advice relevant to public
education. The Council recommends guiding principles for new professional learning.
20
  According to Michigan Elementary and Middle School Principals Association’s grant application,
mental health supports included training and resources on social and emotional learning, staff well-
being, physical education, and nutrition education.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                        11
              Finding 1. Michigan Did Not Maintain Sufficient
                Documentation to Support GEER Fund Grant
                Awards Made to Four Education-Related
                Entities
              For five of the seven programs that Michigan funded with its GEER grant, Michigan
              could not fully support its processes for awarding funds to eligible entities that were
              deemed essential for carrying out emergency educational services, providing childcare
              and early childhood education, providing social and emotional support, or protecting
              education-related jobs. The five programs were Evolution Labs, Building Healthy
              Communities: Step Up for School Wellness, television broadcast service for teachers and
              students, teacher professional learning, and Early On.

              For these programs, Michigan described at a high level in its initial and updated reports
              to the Department the essential policy goals (such as connectivity, student mental
              health, and remote learning materials and training) that it wanted to address through
              subgrants to LEAs, IHEs, and education-related entities. However, Michigan did not
              maintain sufficient documentation related to its decisions to award funds to any of the
              education-related entities selected and not to award funds to other entities that
              submitted requests for GEER grant funds. Without such documentation, there is less
              assurance that Michigan’s awarding of $5.4 million (6 percent) of its $89.4 million GEER
              grant to the four entities that administered the five programs was the result of
              processes that sought to identify entities essential for carrying out emergency
              educational services, providing childcare and early childhood education, providing social
              and emotional support, or protecting education-related jobs. In addition, the lack of
              documentation for awarding decisions provides for less transparency into the awarding
              processes, which could potentially increase the risk of fraud, abuse, or noncompliance
              with CARES Act requirements and other Federal regulations.

              For the other two programs (K–12 GEER and FFF) that Michigan funded with its
              remaining $84 million in GEER grant funds, MDE and Michigan’s State Budget Office
              (SBO) designed and implemented awarding processes that ensured that the GEER grant
              funds were used to support LEAs that were most significantly impacted by the
              coronavirus, as determined by the State, and IHEs within the State that it deemed
              essential for carrying out emergency educational services. We also found that the
              factors Michigan included in the allocation methodologies for the two programs aligned
              with the intent of the CARES Act to support LEAs most significantly impacted by
              coronavirus and IHEs deemed essential for carrying out emergency educational services.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                    12
                Michigan’s Award Process for Five of its GEER Grant Programs
                Was Not Fully Supported
                Michigan allocated $5.4 million of its $89.4 million GEER grant to four education-related
                entities to fund five programs; however, Michigan could not fully support the process it
                used to select the four entities. The $5.4 million was allocated as follows:

                    •   $1 million to Michigan Virtual University for the Evolution Labs program (State
                        mental health program), 21

                    •   $500,000 to the Michigan Elementary and Middle School Principals Association
                        for the Building Healthy Communities: Step Up for School Wellness program, 22
                    •   $1.5 million to Detroit Public Television for a Statewide broadcast service to
                        support teachers and students,
                    •   $1.4 million to Michigan Virtual University for a partnership between three
                        State IHEs (Michigan Virtual University, Michigan State University, and the
                        University of Michigan) for teacher professional learning, and
                    •   $1 million to MDE’s Office of Great Start for the Early On program, an existing
                        early intervention program for children aged 3 and under.

                Michigan’s 45-Day Reports
                The Terms and Conditions of the GEER fund included in Michigan’s Grant Award
                Notification stated that within 45 days of receiving GEER grant funds, the State must
                submit to the Department an initial report detailing its process for awarding those funds
                to LEAs, IHEs, or other education-related entities, including the criteria for determining
                those entities that are most significantly impacted by coronavirus or deemed essential
                for carrying out emergency educational services, and the methodology used to
                formulate those criteria. The former Assistant Director of MDE Financial Management,
                who was designated as Michigan’s GEER grant program administrator, submitted
                Michigan’s required 45-Day Report to the Department in August 2020, and an update to
                the 45-Day Report in October 2020. Under the other education-related entities section
                of both reports, there were brief descriptions of the programs that Michigan funded and
                the allocation amounts for each program. In both reports, Michigan described at a high


21
  According to the grant application, Evolution Labs provides free access to social emotional learning
support services for Michigan students, parents, and educators.
22
  According to the grant application, the Building Healthy Communities: Step Up for School Wellness
program provides students, teachers, and administrators with the necessary tools to improve nutrition,
increase physical activity, and address mental health and well-being.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                          13
                level the criteria and processes that it used to determine the policy goals 23 of its GEER
                grant.

                In the updated 45-Day Report, Michigan also described at a high level the process it
                used to award funds to the other education-related entities selected to receive grant
                funds. Specifically, the report stated that Michigan worked with the education-related
                entities to develop programs that addressed its GEER grant policy goals, and that the
                entities submitted grant applications that included descriptions of the programs to be
                funded and detailed budgets. Neither report included a description of the processes
                Michigan used for selecting the education-related entities that would be responsible for
                administering the five programs listed in the 45-Day reports.

                Grant Award Selection Process
                In our interviews with SBO officials who described Michigan’s award selection process,
                they explained that while external requests for GEER grant funds were not solicited,
                14 external entities submitted requests for the grant funds to the SBO. SBO officials
                further explained that the SBO and the Executive Office of the Governor performed an
                informal evaluation of the external requests based on whether the request:

                    •   appeared to have a Statewide impact,
                    •   met any of the policy goals,
                    •   would provide for a quick deployment of funds, or
                    •   included items that could/should be purchased by individual LEAs with other
                        GEER or Elementary and Secondary School Emergency Relief Fund 24 money they
                        were receiving.
                SBO officials explained that the SBO and the Executive Office of the Governor used the
                evaluation criteria described above to develop an internal decision document to make
                funding recommendations to the Governor. The document included the names of the



23
  Michigan’s 45-Day Report included a list of the following GEER grant policy goals: connectivity;
student mental health; addressing learning loss; out-of-school-time learning; remote learning materials
and training; teacher training and curriculum; and health, safety, and wellness needs.
24
  The Elementary and Secondary School Emergency Relief Fund, established under the Coronavirus Aid,
Relief, and Economic Security Act, awarded grants to SEAs for the purpose of providing LEAs that receive
funds under Part A of Title I of the Elementary and Secondary Education Act of 1965, including charter
schools that are LEAs, with emergency relief funds to address the impact the COVID-19 pandemic has
had, and continues to have, on elementary and secondary schools across the Nation.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                             14
                four education-related entities that Michigan ultimately funded (as well as the K–12
                GEER and Future for Frontliners programs), the policy category that the selected entities
                or programs would meet (such as scholarships, teacher training, student mental health,
                remote learning materials, and early intervention supports), a description of how the
                entities planned to use the funds, and a recommended funding amount. The document
                also presented the Governor with questions on whether she agreed with the allocated
                amounts and use of funds. According to SBO officials, the Governor selected all four
                entities and the related programs that were included in the document for funding with
                the proposed allocation amounts presented in the document.

                We found that two of the four funded entities (MDE’s Office of Great Start and Michigan
                Virtual University) submitted external requests to SBO, which was in line with the
                process described. However, for the other two funded entities, one submitted its
                request directly to the Governor’s office (Michigan Elementary and Middle School
                Principals Association) while the other did not submit a request at all (Detroit Public
                Television). An SBO official explained that because Detroit Public Television previously
                requested State education funding to expand its programming and was included in the
                Governor’s recommended Fiscal Year 2021 budget, Michigan provided the entity with
                GEER grant funds so that it could begin its expanded Statewide programming in the
                summer of 2020. We also found that the internal decision document that SBO and the
                Governor’s office used to select entities did not include the selection criteria described
                above or the names of all the entities that were evaluated and did not document the
                evaluation of the 14 external requests.

                After the Governor made the decision to award funds to the four entities, MDE clearly
                identified the subawards to the four entities and provided them with required
                information such as the award amount, the fund obligation period, and the Federal
                grant requirements. Also, for three of these entities (Michigan Virtual University,
                Michigan Elementary and Middle School Principals Association, and Detroit Public
                Television), MDE required that they complete grant applications containing budget
                narratives and assurances before they could receive any award notification letters or
                funds. We confirmed that the three entities complied with those requirements. For the
                fourth entity (MDE’s Office of Great Start) administering the Early On program, MDE
                required the subgrantees of that program (which were all 56 ISDs 25 in the State) to
                complete the required applications after it completed its allocation process. We tested
                the allocation process, which was based on the 2015–2017 county birth counts of


25
  Michigan has regular school districts and intermediate school districts (which serve multiple regions).
They are both considered LEAs by the State; however, for purposes of this document we only refer to
the regular school districts as LEAs.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                       15
              children under age 3 residing in the geographical location of each ISD, and confirmed
              that the allocation spreadsheet was accurate, it agreed with the county birth counts
              included in a separate spreadsheet that MDE provided to us, and the data were reliable
              for our purposes. In addition, for a sample of 6 of the 56 ISDs, we confirmed that MDE
              had their signed grant application with a budget containing allowable uses of funds and
              their award notification letter that included all of the required subaward information.

              According to sections 18002(c)(1) through (c)(3) of the CARES Act, the GEER Fund may
              be used to provide emergency support grants to LEAs and IHEs deemed most
              significantly impacted by coronavirus and any other IHEs, LEAs, or education-related
              entities in the State that the Governor deems essential for carrying out emergency
              education services to authorized students.

              Additionally, the Department’s Frequently Asked Questions about the GEER Fund
              provides guidance to States. Specifically, Question A-3 states that Governors may use
              GEER grant funds through a subgrant or contract to other LEAs, IHEs, and education-
              related entities deemed “essential for carrying out emergency educational services,
              providing childcare and early childhood education, providing social and emotional
              support, and protecting education-related jobs.”

              In addition, according to 2 Code of Federal Regulations (C.F.R.) section 200.303(a) and
              (c) (effective through November 11, 2020), a non-Federal entity must establish and
              maintain effective internal control over its Federal award that provides reasonable
              assurance that it is managing its award in compliance with Federal statutes, regulations,
              and the terms and conditions of its award. These internal controls should be compliant
              with the Comptroller General of the United States’ guidance in “Standards for Internal
              Control in the Federal Government” or the Committee of Sponsoring Organizations of
              the Treadway Commission’s “Internal Control Integrated Framework.” The entity must
              also evaluate and monitor its compliance with statutes, regulations, and the terms and
              conditions of Federal awards.

              Also, the U. S. Government Accountability Office Standards for Internal Control in the
              Federal Government section 10.03 states that, “Management clearly documents
              internal control and all transactions and other significant events in a manner that allows
              the documentation to be readily available for examination. The documentation may
              appear in management directives, administrative policies, or operating manuals, in
              either paper or electronic form. Documentation and records are properly managed and
              maintained.”

              Michigan could not provide documentation to fully support its GEER grant award
              process because it did not have controls in place to ensure that the process was
              adequately documented. Specifically, Michigan’s Governor’s Office, which was


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                      16
                ultimately responsible for Michigan’s GEER grant, did not require the GEER grant
                administrator (the former MDE Financial Management Assistant Director) to document
                the deliberative processes that were used to determine the education-related entities
                that would be responsible for carrying out essential activities in support of the State’s
                established policy goals.

                Without such documentation, there is less assurance that Michigan’s awarding of
                $5.4 million of its $89.4 million GEER grant to four education-related entities was the
                result of processes that sought to identify entities essential for carrying out emergency
                educational services, providing childcare and early childhood education, providing social
                and emotional support, or protecting education-related jobs. In addition, the lack of
                documentation for awarding decisions provides for less transparency into the awarding
                processes, which could potentially increase the risk of fraud, abuse, or noncompliance
                with CARES Act requirements and other Federal regulations.

                Award Processes for Subgrantees of the K–12 GEER and Future
                for Frontliners Scholarship Programs Were Designed and
                Implemented in Accordance with the CARES Act, Federal
                Regulations, and Grant Conditions
                For the K–12 GEER and FFF scholarship programs that Michigan funded with its GEER
                grant, Michigan designed and implemented awarding processes that ensured that the
                GEER grant funds were used to support LEAs that it determined as most significantly
                impacted by the coronavirus and IHEs within the State that it deemed essential for
                carrying out emergency educational services. We also found that the factors Michigan
                included in the allocation methodologies for the two programs aligned with the intent
                of the CARES Act.

                K–12 GEER Program
                MDE allocated $60 million in GEER grant funds (for the K–12 GEER program) to 557 LEAs
                and 56 ISDs 26 that it determined as most significantly impacted by coronavirus. LEAs and
                ISDs could only use GEER grant funds for the following expenditure categories:
                connectivity; student mental health; addressing learning loss; out-of-school-time
                learning; remote learning materials and training; teacher training and curriculum; and



26
  MDE determined that 557 LEAs and 56 ISDs were eligible for the GEER grant funds. Of these, 547 LEAs
and 53 ISDs applied for and received the GEER grant funds after MDE allocated the funds. The other
10 LEAs and 3 ISDs did not receive GEER grant funds because they either closed or refused the funds
after MDE notified them of their allocation. Michigan did not drawdown or reallocate the $84,519 that it
had already allocated to the 10 LEAs and 3 ISDs.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                       17
               health, safety, and wellness needs. In allocating the funds to LEAs and ISDs, the SBO and
               MDE determined LEAs as most significantly impacted by coronavirus based on the
               number of students at the LEA who were identified as economically disadvantaged,
               children with disabilities, and English language learners. According to Michigan’s GEER
               Fund Distribution Framework (Framework), 27 these student groups were targeted
               because providing them with an adequate education typically has a higher cost than
               providing a similar education to traditional students. Also, these student groups may be
               more adversely impacted by the coronavirus’s disruption to the normal school calendar.
               An LEA was eligible to receive GEER grant funds if over 50 percent of its student
               population was considered economically disadvantaged. LEAs that met this eligibility
               criteria were allocated $86.62 in GEER grant funds for each student identified as
               economically disadvantaged, a child with a disability, or an English language learner.

               Regarding ISDs, according to SBO’s Financial Specialist, SBO determined that all ISDs
               were eligible for GEER grant funding because ISDs generally serve a special education
               population with greater needs. MDE allocated $86.62 in GEER grant funds to ISDs for
               each child with a disability, based on the student’s special education full-time
               equivalency status. 28

               Michigan posted to its website the criteria it used to allocate the $60 million in GEER
               grant funds to LEAs and ISDs. We also found that MDE and SBO applied the allocation
               formulas correctly, the calculations were accurate, and the data used were reliable.

               Regarding the application process, MDE followed its normal Federal grant application
               policies and procedures for LEAs and ISDs. In order for LEAs and ISDs to obtain their
               allocated GEER grant funds, MDE required them to submit an online application that
               included a detailed budget and signed assurances. MDE Financial Management
               reviewed the applications to determine whether the budgeted amount agreed to the
               allocated amount and the budgeted expenditures were for allowable uses. MDE
               Financial Management provided GEER grant award notification letters to the LEAs and
               ISDs.




27
  Michigan’s Framework document outlined how its GEER grant funds would be allocated and included
the same information that was in Michigan’s 45-Day Report.
28
  Special education full-time equivalency status is a measure of how much time a student receives
specialized instruction through a special education program.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                         18
                We selected a nonstatistical sample of 50 (9 percent) of the 557 LEAs and 6 (11 percent)
                of the 56 ISDs that were allocated GEER grant funds 29 and confirmed that each entity
                that received funding submitted an application, signed the required assurances, and
                submitted budgets that included uses of funds under allowable expenditure categories.
                We also confirmed that MDE provided each sampled LEA and ISD with a grant award
                notification letter that included all the required subaward information.

                FFF Program
                Michigan allocated $24 million in GEER grant funds to Treasury and LEO to administer
                the FFF scholarship program. Treasury and LEO used the GEER grant funds to reimburse
                IHEs for tuition and fees for students who met FFF scholarship program and enrollment
                eligibility requirements. The FFF scholarship program included two paths. The Path 1
                program was for frontline workers in essential industries, such as grocery stores, to
                pursue an associate degree or industry-recognized certificate that is eligible under the
                Federal Pell Grant (Pell) program. 30 The FFF Path 1 scholarship covered the costs for in-
                district tuition and fees less any Pell grant funds and any tuition-restricted scholarships
                or awards that the student received. The FFF Path 2 program was for frontline workers
                to obtain a high school diploma or its recognized equivalent by enrolling at a State-
                approved adult education provider. The FFF Path 2 scholarship covered high school
                equivalency testing fees and the cost to enroll in classes at the adult education provider.

                The FFF program had overall eligibility criteria that applied to both paths. The applicant
                must:

                    •   be a Michigan resident;
                    •   have worked in-person in an essential industry 31 at least part-time during the
                        initial shutdown period (April 1,2020, to July 30, 2020); and

                    •   have completed the FFF application by December 31, 2020.




29
  We judgmentally selected 10 LEAs and 2 ISDs that had the largest K–12 GEER program allocations.
From the remaining LEAs and ISDs, we selected 40 LEAs and 4 ISDs using a simple random sample.
30
  Pell grants, authorized by Title IV of the Higher Education Act of 1965, as amended, are need-based
aid grants awarded to eligible undergraduate students.
31
  Michigan’s FFF Frequently Asked Questions document includes a list of essential industries, such as
grocery stores and restaurants, waste management services, and manufacturing of personal protective
equipment.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                          19
                  FFF Path 1
                  In addition to meeting the overall criteria described above, in order to be eligible for the
                  FFF Path 1 scholarship program, applicants must not have previously earned an
                  associate or baccalaureate degree and must not be in default on a Federal student loan
                  or have received a Title IV 32 overpayment. FFF Path 1 applicants applied for the FFF
                  program using an online application in Michigan’s Student Scholarships and Grants
                  system. System checks determined whether the applicants met some of the eligibility
                  requirements, while Michigan’s Unemployment Insurance Agency, which had a data
                  agreement with Treasury and LEO, determined whether the applicants met employment
                  eligibility requirements. Eligible FFF Path 1 applicants were required to be admitted to
                  an accredited Michigan public community college and attend at least half-time
                  (6 credits) and complete the Free Application for Federal Student Aid.

                  We selected a nonstatistical sample of 5 (17 percent) of the 29 community colleges that
                  received at least $10,000 in FFF Path 1 GEER grant funds as of August 5, 2021. 33 We then
                  selected a nonstatistical sample of 25 (1.3 percent) of the 1,874 students who received
                  GEER grant funds from the 5 community colleges 34 and confirmed that the students
                  applied for the FFF program by December 31, 2020, were approved for FFF Path 1, met
                  the eligibility requirements, and were taking the required number of program credits.

                  FFF Path 2
                  In addition to meeting the overall criteria described above, in order to be eligible for the
                  FFF Path 2 scholarship program, applicants must not have had a high school diploma or
                  its recognized equivalent at the time of application, must have been at least 18 years old
                  by December 31, 2020, and must not have been enrolled in high school at the time of
                  application. FFF Path 2 applicants applied for the FFF program using an online
                  application on LEO’s 35 website. LEO determined the initial eligibility of the applicant
                  while Michigan’s Unemployment Insurance Agency verified the applicant’s employment
                  eligibility.

                  LEO executed grant agreements with each adult education provider that enrolled one or
                  more FFF Path 2 eligible students. As part of the grant agreement, the adult education



32
     Title IV of the Higher Education Act, as amended.
33
  We judgmentally selected 3 community colleges that received the highest amount of GEER grant
funds and 2 colleges using a simple random sample.
34
     We selected the sample of 25 students using a simple random sampling design.
35
     LEO’s division of Workforce Development administered the FFF Path 2 scholarship program.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                           20
                  providers were required to report participant data monthly, 36 encouraged (but not
                  required) to submit invoices to LEO for payment monthly, and required to agree to a
                  GEER grant reimbursement limit that was based on the number of enrolled FFF Path 2
                  students. 37 LEO also required the adult education providers to monitor students’
                  performance.

                  We selected a nonstatistical sample of 5 (1.3 percent) of the 389 students who received
                  GEER grant funds under the FFF Path 2 program 38 and confirmed that the students
                  applied for the program by December 31, 2020, were approved, and met the eligibility
                  requirements. We also confirmed that the adult education provider had a grant
                  agreement and complied with the grant agreement requirements.

                  Michigan posted to its FFF website the scholarship eligibility criteria that it used for both
                  program paths.

                  Recommendations
                  We recommend that the Assistant Secretary for the Office of Elementary and Secondary
                  Education require the Governor of Michigan to—

                      1.1 Provide documentation, or a full and detailed explanation, of the process
                          Michigan used to determine that the four education-related entities that
                          received GEER grant funds were essential for carrying out emergency
                          educational services, providing childcare and early childhood education,
                          providing social and emotional support, or protecting education-related jobs.
                      1.2 Develop and implement a process to ensure that it documents the criteria and
                          decisions made for awarding future GEER grant funds in accordance with
                          applicable requirements.




36
  LEO required the adult education providers to report attendance data and achievement data, such as
the number of students earning their high school diploma.
37
  The GEER grant reimbursement limit for an adult education provider could range from $10,000 to
$750,000 depending on how many FFF Path 2 students were enrolled.
38
     We selected the sample of 5 students using a simple random sampling design.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                            21
              We recommend that the Assistant Secretary for the Office of Elementary and Secondary
              Education—

                  1.3 Take appropriate action if the documentation and other information provided
                      by Michigan in response to the above recommendations does not support that
                      the State followed applicable requirements.

              Michigan Comments
              Michigan agreed in part with the finding and related recommendations. Michigan stated
              that it had a highly collaborative selection process, which aimed to identify programs
              that could be deployed quickly, have a Statewide impact, and support a full array of
              essential emergency educational services. Michigan stated that the documentation of
              the final funding recommendations provided to the Governor, and referenced in the
              report, also referenced how each recommendation connected to applicable policy
              priorities and listed the entities not selected with descriptions of why they were not
              selected. Michigan also acknowledged that some aspects of the process were not as
              well documented as they could have been. For example, the 45-Day Report submitted
              could have provided greater detail regarding the evaluation and selection process.

              To address Recommendation 1.1, Michigan developed additional documentation that it
              included in its response that outlined the process it used to select the other education-
              related entities awarded GEER grant funds. In addition, Michigan stated that it intends
              to use this additional documentation to enhance its existing documentation supporting
              the decisions made for the GEER grant funds as a model to ensure that the criteria used,
              and decisions made, are adequately documented for future GEER grant funds should
              they become available. Michigan further stated that this enhanced documentation is
              intended to serve as the corrective action to address Recommendation 1.2.

              OIG Response
              Michigan’s proposed corrective actions, if properly implemented, are partially
              responsive to the two recommendations. Specifically, Michigan’s response and the
              additional documentation included in its response describes the process it used for
              selecting the other education-related entities awarded GEER grant funds. However,
              although the additional documentation states that the final funding recommendations
              provided to the Governor listed the entities not selected with descriptions of why they
              were not selected, Michigan did not provide us with any documentation that included
              this information. To fully address Recommendation 1.1, Michigan should also ensure
              that it documents the reasons for not funding other entities that are considered for
              future GEER grant funds.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                    22
              Regarding Michigan’s proposed corrective action to address Recommendation 1.2, while
              the enhanced documentation could be used as a model for adequate documentation for
              future GEER grant funds, it will be important for Michigan to address the issues
              identified under Recommendation 1.1 above and also establish a process to ensure that
              documentation is developed.

              We did not change our findings or recommendations as a result of Michigan’s response.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                 23
               Finding 2. Michigan Did Not Design and
                 Implement Sufficient GEER Fund Monitoring
                 Processes For Some Of Its Subgrantees
               MDE did not have a written plan to monitor its GEER grant subgrantees. It had planned
               to contract with an audit firm to conduct monitoring of its GEER grant subgrantees;
               however, as of March 30, 2022, the contract was still incomplete. MDE did, however,
               conduct some monitoring activities and implement reimbursement processes for its
               subgrantees. For two (K–12 GEER and Early On programs) of Michigan’s seven programs,
               the monitoring activities and reimbursement process that MDE designed and
               implemented for its subgrantees did not provide reasonable assurance that the entities
               used GEER grant funds for allowable purposes. Specifically, MDE did not require the
               subgrantees to submit documentation to support expenditures, and one of the
               monitoring activities was not applicable to subgrantees that would not receive an
               annual single audit. 39 We also found that for one (FFF scholarship program) of
               Michigan’s seven programs, additional monitoring is needed for the FFF Path 1 program
               to ensure that IHEs’ requested reimbursement amounts are accurately calculated. We
               found that the monitoring activities and reimbursement process for the FFF Path 2
               scholarship program were sufficient.

               For the remaining four (Evolution Labs, Building Healthy Communities: Step Up for
               School Wellness, television broadcast service for teachers and students, and teacher
               professional learning programs) of Michigan’s seven programs, MDE designed and
               implemented a comprehensive reimbursement process that ensured the entities used
               the GEER grant funds in accordance with the CARES Act and other applicable Federal
               requirements. We reviewed supporting documentation for the four programs and found
               that the comprehensive reimbursement process provided effective monitoring and
               ensured that the entities used GEER grant funds for allowable purposes.

               Michigan Did Not Sufficiently Monitor Three of its GEER Grant
               Programs
               The monitoring that Michigan provided for three (K–12 GEER, Early On, and FFF Path 1
               scholarship programs) of the programs it funded with GEER grant funds was insufficient.
               Specifically, MDE did not have a written plan to monitor its GEER grant subgrantees and,


39
  An annual single audit is an audit conducted in accordance with the Single Audit Act Amendments of
1996; the OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards (2 Code of Federal Regulations Part 200); the OMB Compliance Supplement; and
Government Auditing Standards.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                    24
               at the time of our audit, had not yet completed a planned monitoring contract with an
               audit firm. Michigan performed some monitoring of its subgrantees, as discussed below,
               but we found that improvements are needed to ensure that GEER grant funds are used
               in accordance with the CARES Act and other applicable Federal requirements.

               Monitoring Process for the K–12 GEER and Early On Programs
               For the K–12 GEER and Early On programs, although MDE designed and implemented
               monitoring activities and a reimbursement process for its subgrantees, these efforts did
               not provide reasonable assurance that the entities used the GEER grant funds for
               allowable purposes.

               One of the monitoring activities MDE implemented for the LEAs and ISDs that
               participated in the programs was a review of the LEAs’ and ISDs’ Final Expenditure
               Reports (FER). MDE required the LEAs and ISDs to submit their FERs within 60 days of
               expending all of their allocated funds or the grant ending date, whichever came first.
               The FER included the amount of GEER grant funds the LEA or ISD expended for each
               expense category listed in the report (salaries, benefits, purchased services, supplies
               and materials, capital outlay, and other expenses). MDE reviewed the FERs to ensure
               that the expenditure totals for each expense category matched the totals from the LEAs’
               and ISDs’ approved budgets. LEAs or ISDs did not have to submit invoices or supporting
               documentation with the FERs. We selected a sample of 50 LEAs that received and
               expended K–12 GEER grant funds. 40 As of September 27, 2021, 5 of the 50 LEAs had
               submitted a FER. We reviewed all five FERs and confirmed that the final expenditure
               totals matched the LEAs’ approved budget totals. However, because no documentation
               was submitted with the FERs to support that the expenditures were incurred, the State
               had less assurance that the funds were used for allowable purposes.

               Another activity MDE used to monitor the LEAs and ISDs was MDE’s existing single audit
               desk review process. As part of the desk review process, MDE reviewed the LEAs’ and
               ISDs’ annual single audit reports 41 to determine whether there were any Federal
               program findings and related corrective actions. MDE used a spreadsheet to document
               the desk review. According to an MDE official, if the audit reports identified GEER grant
               findings, as was the case for six LEAs at the time of our review, the results of the desk
               review were uploaded into MDE’s Grant Electronic Monitoring System / Michigan




40
  This is the same sample we used for our K–12 GEER program award process testing discussed in
Finding 1.

 MDE reviewed single audit reports to ensure that the reports complied with Federal regulations.
41




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                     25
                  Administrative Review System (GEMS/MARS) 42 and sent to the program office
                  responsible for ensuring that GEER grant corrective actions are taken. However, this
                  activity is not sufficient by itself because not all LEAs and ISDs are required to have an
                  annual single audit performed. 43

                  The reimbursement process MDE implemented to disburse GEER grant funds to LEAs
                  and ISDs required LEAs and ISDs to request reimbursement through MDE’s Cash
                  Management System (CMS). 44 The CMS, which Michigan uses for all Federal education
                  grants, tracks grant payments and remaining balances to ensure that the LEAs and ISDs
                  are not reimbursed for more than they were awarded. The only information the LEAs
                  and ISDs are required to enter into the system is the amount of funds they are
                  requesting for reimbursement. They did not have to provide details of how the GEER
                  grant funds were used or submit documentation supporting that the expenditures were
                  actually incurred. LEAs and ISDs certified 45 that each reimbursement request was true,
                  complete, and accurate, and that the expenditures and requested payments were for
                  the purposes and objectives set forth in the terms and conditions of the Federal award.

                  Monitoring Process for the FFF Scholarship Program
                  Michigan did not have a monitoring plan in place for the FFF scholarship program. MDE
                  officials stated that Treasury, LEO, and others would perform monitoring of subgrantees
                  for programs other than the K–12 GEER program. However, MDE’s Financial
                  Management Assistant Director also stated that MDE intended to have the monitoring
                  contract discussed above include monitoring for all the GEER grant programs. A
                  monitoring plan was never developed.

                  For the FFF Path 1 scholarship program, although Treasury and LEO designed and
                  implemented a reimbursement process for IHEs that provided assurance that
                  reimbursements were for students who met eligibility and enrollment requirements,


42
  According to Michigan’s GEMS/MARS website, the system supports the monitoring of the
implementation of Federal and State programs at the local level to ensure funds and other resources are
spent or used appropriately in accordance with State and Federal law and Department of Education
policy.
43
  A non-Federal entity, such as a LEA or ISD, that expended less than $750,000 in Federal awards during
the fiscal year is exempt from Federal audit requirements.
44
  The CMS is a web-based system that MDE’s subgrantees are required to use to request drawdowns of
grant funds.
45
     Subgrantees make the certification by clicking a box when submitting their reimbursement request.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                               26
                  additional monitoring activity is needed for the FFF Path 1 program to ensure that IHEs’
                  requested reimbursement amounts are accurately calculated. For the FFF Path 2
                  scholarship program, we found the monitoring activities and reimbursement process
                  sufficient.

                  For the FFF Path 1 program, Treasury provided a handbook to the participating IHEs that
                  included the award packaging order for scholarship funds 46 and instructions for
                  submitting reimbursement requests. On a quarterly basis, Treasury required IHEs
                  participating in the Path 1 program to complete an online reimbursement request form
                  that included the total number of credit hours the participating students had taken for
                  the quarter, along with the total amount of reimbursable tuition and fees applicable for
                  those students for the quarter. The reimbursement request form states that by
                  submitting the reimbursement request, IHEs confirm that all credit hours for which they
                  were requesting reimbursement were related to associate degrees or occupational
                  certificate programs that are eligible under the Federal Pell Grant (Pell) program. 47 The
                  IHEs also confirmed that the students were eligible FFF Path 1 scholarship participants.
                  IHEs were not required to submit a copy of the students’ quarterly tuition bill or other
                  documentation showing that the calculation used to determine the reimbursable
                  amount was in accordance with the required packaging order established by Treasury
                  with the reimbursement request form. Treasury did not perform a review of the GEER
                  grant reimbursement requests to ensure that the IHEs were not reimbursed for more
                  than each student’s calculated award amount. We judgmentally selected a sample of
                  5 (17 percent) of the 29 IHEs that received at least $10,000 in FFF Path 1 GEER grant
                  funds, as of August 5, 2021. We then selected a nonstatistical sample of 25 (1 percent)
                  of the 1,874 students who received GEER grant funds from the 5 sampled IHEs 48 and
                  confirmed that Treasury officials followed their reimbursement process, the amounts
                  requested for reimbursement were calculated correctly, and students’ accounts were
                  credited for the correct GEER grant amount.




46
  The packaging order is the order in which a student’s financial aid is applied to their quarterly bill. The
FFF program required IHEs to apply any of the following financial aid: Pell grant, Michigan Indian Tuition
Waiver, Survivors Tuition grant, Children of Veterans Tuition grant, and the Michigan Competitive
Scholarship, to the student’s quarterly bill before the FFF scholarship amount could be determined.
47
  Pell grants, authorized by Title IV of the Higher Education Act of 1965, as amended, are need-based
aid grants awarded to eligible undergraduate students.
48
     We selected 5 students from each IHE using a simple random sampling design.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                          27
                  For the FFF Path 2 program, LEO designed and implemented a comprehensive
                  reimbursement process that it used to monitor adult education providers’ expenditures.
                  We found that the reimbursement process ensured that adult education providers used
                  GEER grant funds for allowable purposes. LEO provided adult education providers with a
                  FFF Path 2 handbook that included the reporting requirements and instructions for
                  submitting reimbursement requests. On a monthly basis, LEO required adult education
                  providers to enter FFF Path 2 student data into Michigan’s Adult Education Reporting
                  System (MAERS). 49 The data included the name of the classes the student was taking,
                  assessment scores, 50 attendance records, and any achievements. 51 LEO reviewed the
                  student data prior to approving a provider’s reimbursement request. Also, in order to
                  receive reimbursement, LEO required the adult education providers to submit
                  reimbursement requests along with invoices and supporting documentation via email.
                  LEO encouraged them to submit the reimbursement requests monthly, but they were
                  not required to submit them monthly. We selected a sample of 5 (1 percent) of the
                  389 students who received GEER grant funds for the FFF Path 2 program and found that
                  the adult education providers submitted reimbursement requests for the selected
                  students that included invoices and supporting documentation and matched the
                  participation data that the providers submitted.

                  Several criteria relate to States’ monitoring of GEER grant subgrantees. Specifically,
                  Question A-11 of the Department’s Frequently Asked Questions about the GEER Fund,
                  states that each Governor must designate a State Agency as the fiscal agent to
                  administer the GEER Fund. The fiscal agent is responsible for overseeing and monitoring
                  all GEER Fund activities in the State.

                  Also, according to 2 C.F.R. section 200.303(a) and (c), 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 applicable
                  Federal statutes, regulations, terms, and conditions. Further, the non-Federal entity
                  must also evaluate and monitor its compliance with statute, regulations, and the terms
                  and conditions of Federal awards.




49
     MAERS is a web-based system used for reporting data on adult education students in Michigan.
50
  Assessments include tests such as high school equivalency tests and pre-tests taken at the time of
enrollment.
51
  Achievement data includes a student’s accomplishments such as attainment of a high school diploma
or equivalent, enrollment into a postsecondary institution, and achieving English language proficiency.


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Office of Inspector General
ED-OIG/A20GA0039                                                                                       28
              Additionally, according to 2 C.F.R. section 200.328 (a), the non-Federal entity is
              responsible for oversight of the operations of the Federal award supported activities.
              The non-Federal entity must monitor its activities under Federal awards to assure
              compliance with applicable Federal requirements and that performance expectations
              are being achieved. Monitoring by the non-Federal entity must cover each program,
              function, or activity.

              Further, according to 2 C.F.R. section 200.331, State Grantees (pass-through entities)
              must 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, complies with Federal statutes, regulations, and the
              terms and conditions of the subaward; and that subaward performance goals are
              achieved.

              The Department’s GEER grant Certification and Agreement requires that the State and
              other entities comply with all applicable regulations and guidance, including the
              OMB Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
              Federal Awards (2 C.F.R. Part 200). This requirement contained references to Federal
              monitoring regulations. Therefore, Michigan should have been aware of its
              responsibilities regarding Federal monitoring requirements because the State attested
              to its awareness by signing Part D of the GEER grant Certification and Agreement.

              Reasons for Monitoring Weaknesses Identified and the
              Resulting Impacts
              There were several reasons for the weaknesses that we identified in Michigan’s
              monitoring processes for the K–12 GEER, Early On, and FFF Path 1 scholarship programs.
              When asked about MDE’s monitoring plan for these GEER-funded programs, MDE
              Financial Management’s former Director stated that MDE decided not to perform
              monitoring of the K–12 GEER program subgrantees until all allocated GEER grant funds
              were drawn down and all LEAs and ISDs that received GEER grant funds had submitted
              an FER. The former Director further stated that MDE planned to perform light
              monitoring to decrease the burden on the LEAs and ISDs. For the Early On and FFF
              Path 1 scholarship programs, MDE’s Financial Management Assistant Director stated
              that MDE intended to include the monitoring in the same contract it was negotiating
              with an audit firm for the K–12 GEER monitoring; however, as of March 30, 2022, the
              contract was still incomplete.

              Because Michigan’s monitoring of the K–12 GEER, Early On, and FFF scholarship
              programs was not adequate to ensure allowable use of funds, Michigan has only limited
              assurance that the subgrantees used GEER grant funds in accordance with the CARES
              Act and other applicable Federal requirements. Regarding the K–12 GEER and Early On



U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                       29
              programs, because the FER submissions, single audit desk reviews, and reimbursement
              requests do not involve reviews by MDE of LEAs’ or ISDs’ expenditures, including such a
              protocol when it develops its monitoring plan would provide MDE with additional
              assurance that LEAs and ISDs used GEER grant funds for allowable purposes. Also, the
              decision not to monitor the subgrantees of those programs until all allocated GEER grant
              funds were drawn down will result in MDE not being able to timely identify and correct
              instances of noncompliance while the funds are being expended, increasing the risk of
              GEER grant funds being used for unallowable purposes. Regarding the FFF scholarship
              program, specifically the Path 1 program, although Treasury’s reimbursement process
              for IHEs provided assurance that reimbursements were for students who met eligibility
              and enrollment requirements, without a review of supporting documentation or the
              calculations made to determine the reimbursement amount, Treasury does not have
              reasonable assurance that the IHE reimbursement requests were correct, and that the
              amounts were calculated in accordance with the required packaging order established
              by Treasury.

              MDE’s GEER Grant Reimbursement Process for Four Programs
              For four of the programs that MDE funded with its GEER grant (Evolution Labs, Building
              Healthy Communities: Step Up for School Wellness, television broadcast service for
              teachers and students, and teacher professional learning), MDE designed and
              implemented a comprehensive reimbursement process that it used to monitor
              expenditures that ensured the entities used the GEER grant funds in accordance with
              the CARES Act and other applicable Federal requirements. Specifically, MDE required
              the three entities administering the four programs to submit monthly reimbursement
              requests (through GEM/MARS), as well as invoices and documentation supporting the
              requests. An MDE official reviewed the invoices and supporting documentation to
              ensure that the expenditures were for allowable purposes. The official also maintained a
              spreadsheet to track the entities’ payments and remaining balances to ensure that the
              entities were not reimbursed for more than they were awarded. MDE then sent the
              approved reimbursement requests to MDE Financial Management’s Grants, Contracts,
              and School Support Unit Supervisor for final approval and payment.

              We reviewed all the reimbursement requests and supporting documentation submitted
              by the four entities and confirmed that the entities used grant funds for allowable
              purposes. We also confirmed that MDE followed its reimbursement process and
              documented its approvals.

              Recommendations
              We recommend that the Assistant Secretary for the Office of Elementary and Secondary
              Education require the Governor of Michigan to—



U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                   30
                  2.1 Timely design and implement a monitoring plan that will ensure that K–12 GEER
                      and Early On program subgrantees’ use of GEER grant funds complies with the
                      CARES Act and other applicable Federal requirements. The monitoring plan
                      should include protocols to review, on at least a sample basis, and using a risk-
                      based approach, supporting documentation for subgrantee expenditures
                      charged to the GEER grant to provide assurance that funds were used for
                      allowable purposes.
                  2.2 Develop and implement a process to review, on at least a sample basis, and
                      using a risk-based approach, supporting documentation and award calculations
                      for the FFF Path 1 scholarship awards.

              Michigan Comments
              Michigan stated that it agreed with the finding and recommendations. Michigan stated
              that it was already developing monitoring protocols that included sampling and
              reviewing supporting documentation for subgrantee expenditures. Michigan stated that
              its monitoring plan includes a risk assessment for each program and protocols to use a
              risk-based approach to review subgrantee expenditures for allowability. Michigan
              further stated that it has executed a contract with a consultant to complete the risk
              assessment and monitoring process for K–12 GEER and Early On programs subgrantees’
              use of GEER grant funds to ensure compliance with the CARES Act and other applicable
              Federal requirements.

              Michigan included a summary of key monitoring information for the K–12 GEER
              program with their response. The summary includes a program overview, an overview
              of the risk assessment and monitoring processes, the program risk assessment results,
              and the program monitoring plan. Michigan stated that the same model will be used to
              assess and monitor the other six GEER-funded programs. Michigan projected that all risk
              assessment and monitoring activities will be completed by the end of September 2022.

              Michigan also stated that it was already developing monitoring protocols to sample and
              review supporting documentation and award calculations for the FFF Path 1 program.
              Michigan projected that the FFF Path 1 program monitoring protocols will be
              implemented by October 2022.

              OIG Response
              Michigan’s proposed corrective actions, if properly implemented, are responsive to our
              recommendations. We did not change our findings or recommendations as a result of
              Michigan’s response. However, the monitoring plans described in Michigan’s response
              appear supportive of the State’s efforts to implement its proposed corrective actions. It
              will be important for Michigan to work with the Department to ensure that all



U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                     31
              recommendations are appropriately and sufficiently resolved and that corrective actions
              are fully implemented.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                  32
              Appendix A. Scope and Methodology
              Our audit covered Michigan’s control activities related to the administration of the GEER
              grant. Specifically, our audit covered Michigan’s policies, procedures, and other controls
              to ensure that GEER grant funds were used to support LEAs and IHEs that were most
              significantly impacted by the coronavirus or LEAs, IHEs, or other education-related
              entities that were deemed essential for carrying out emergency educational services.
              Our audit also covered Michigan’s policies, procedures, and other controls to ensure
              that subgrantees used GEER grant funds in accordance with the CARES Act and other
              applicable Federal requirements. Our review covered Michigan’s GEER grant award and
              monitoring processes from March 13, 2020, through May 10, 2022. We conducted
              fieldwork virtually due to the national pandemic from July 12, 2021, through
              May 10, 2022. We performed testing on Michigan’s grant applications through
              December 2020, and expenditures through August 2021. We held an exit conference
              with Michigan officials on May 10, 2022, to discuss the results of our audit.

              To achieve our audit objectives, we gained an understanding of the CARES Act, the
              Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
              Federal Awards (2 C.F.R. Part 200), and Department guidance relevant to our audit
              objectives, including the Department’s 2020 GEER Frequently Asked Questions. We
              reviewed 2 C.F.R. section 200.303, Internal control, and the U.S. Government
              Accountability Office’s Standards for Internal Control in the Federal Government. We
              also reviewed 2 C.F.R. section 200.302, Financial management; section 200.305, Federal
              payment; section 200.328, Monitoring and reporting program performance; section
              200.331, Requirements for passthrough entities; and section 200.403, Factors affecting
              allowability of costs.

              We also performed the following procedures:

                  •   Reviewed the organization charts for MDE, MDE Financial Management, LEO,
                      and the SBO to determine staff with responsibilities related to the GEER grant.

                  •   Reviewed Michigan’s Certification and Agreement (application) to gain an
                      understanding of how Michigan intended to use the GEER grant funds.
                  •   Reviewed Michigan’s 45-Day Report and an update to the 45-Day Report to gain
                      an understanding of the process Michigan used to award GEER grant funds to
                      LEAs, IHEs, and other education-related entities.
                  •   Interviewed Michigan officials and reviewed documentation to gain an
                      understanding of Michigan’s criteria for determining LEAs and IHEs that were
                      most significantly impacted by the coronavirus or LEAs, IHEs, or other




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Office of Inspector General
ED-OIG/A20GA0039                                                                                     33
                       education-related entities that were deemed essential for carrying out
                       emergency educational services.
                   •   Interviewed MDE Financial Management and SBO officials and reviewed
                       documentation to gain an understanding of the processes for allocating,
                       awarding, administering, and monitoring its K–12 GEER program funds.
                   •   Interviewed MDE Financial Management, Treasury, LEO, and SBO officials and
                       reviewed documentation to gain an understanding of the processes for
                       allocating, awarding, administering, and monitoring its FFF program funds.
                   •   Interviewed MDE Financial Management, SBO, and MDE’s Office of Great Start
                       officials and reviewed documentation to gain an understanding of the processes
                       for allocating, awarding, administering, and monitoring GEER program funds
                       awarded to Michigan Virtual University, Detroit Public Television, the Michigan
                       Elementary and Middle School Principals Association, and MDE’s Office of Great
                       Start.
                   •   Reviewed and evaluated the criteria, policies, procedures, and internal controls
                       MDE used to determine which LEAs and ISDs were most significantly impacted
                       by the coronavirus.
                   •   Reviewed Michigan’s GEER grant drawdowns to determine whether Michigan
                       complied with cash management regulations and guidance. We compared
                       Michigan’s “Total Expenditure Reports” with the amounts drawn down from G5.
                       We also reviewed the number of days between Michigan’s drawdowns and
                       expenditures of funds to determine whether Michigan maintained excess cash.
                   •   Tested expenditures from the four programs administered by Michigan Virtual
                       University, the Michigan Elementary and Middle School Principals Association,
                       and Detroit Public Television to ensure that GEER grant funds were used in
                       accordance with the CARES Act and other applicable Federal requirements. 52 [In
                       the Sampling Methodology section of this report, see the Other Education-
                       Related Entities (excluding Early On) Sample.]
                   •   Tested a sample of the GEER grant fund reimbursements for the FFF Path 1
                       program to ensure the reimbursements were calculated correctly and that the
                       student accounts were credited for the correct GEER grant amount. (In the
                       Sampling Methodology section of this report, see the FFF Path 1 Sample.)




52
  We did not review a sample of expenditures for the K–12 GEER and Early On programs because MDE
did not require subgrantees to submit supporting documentation with their reimbursement requests.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                     34
                  •   Tested a sample of the GEER grant fund reimbursements for the FFF Path 2
                      program to ensure reimbursement requests were submitted with invoices and
                      supporting documentation and agreed with the participation data submitted. (In
                      the Sampling Methodology section of this report, see the FFF Path 2 Sample.)
                  •   Reviewed and recalculated the formulas in the allocation spreadsheets for the
                      K–12 GEER and Early On programs to determine whether the allocations were
                      correct.

                  •   Determined whether the data SBO and MDE’s Office of Great Start used in the
                      K–12 GEER and Early On programs allocation spreadsheets were accurate.

              Sampling Methodology
              To determine whether MDE and its Office of Great Start followed their award processes
              for the Early On and K–12 GEER programs, we selected samples of LEAs and ISDs to
              review. To test the reliability of the allocation spreadsheets for the two programs, we
              performed a 100 percent review of the ISDs’ allocations for the Early On program, a
              100 percent review of the LEAs’ allocations for the K–12 GEER program, and we selected
              a sample of ISD allocations to review for the K–12 GEER program. To determine whether
              Treasury and LEO followed their award and reimbursement processes for the FFF Path 1
              and Path 2 scholarship programs, we selected samples of IHEs and students to review.
              To test the reliability of the data provided related to the FFF Path 1 testing, we
              performed a 100 percent review of the participating students, and for the FFF Path 2
              testing, we selected a sample of participating students to review. To determine whether
              MDE followed its award and reimbursement processes for the Evolution Labs, Building
              Healthy Communities: Step Up for School Wellness, television broadcast service for
              teachers and students, and teacher professional learning programs, we reviewed the
              grant applications, grant award notification letters, invoices, and supporting
              documentation for all three entities administering those programs (Michigan Virtual
              University, the Michigan Elementary and Middle School Principals Association, and
              Detroit Public Television).

              The results of our testing apply only to the samples selected and cannot be projected.
              The sections below describe the sampling in detail.

              Early On Program Samples
              To determine whether MDE’s Office of Great Start followed its award processes for the
              Early On program, we selected for review a sample of 6 (11 percent) of the 56 ISDs that
              were allocated Early On funds. We judgmentally selected the two ISDs that were
              allocated the largest amount (over $90,000) of Early On. We then selected 4 ISDs from
              the remaining 54 ISDs using a nonstatistical random sampling design. For the sample of
              six ISDs, we confirmed that the ISD submitted an application with a budget that included


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                       35
               uses of funds under allowable expenditure categories, received an award notification
               from Michigan, and signed Michigan’s required assurances.

               Table 1 shows the universe, sample sizes, and sampling methodologies related to our
               testing of the Early On program.

               Table 1. ISD Universe and Samples for the Early On Program Testing
                  Testing Purpose          Universe            Sample Size          Methodology

                                                                                 Judgmentally selected
                                                                    6              2 ISDs with largest
                    Award Process             56                                     allocations and
                                                               (11 percent)          4 using simple
                                                                                   random sampling

                                                                    56
                   Data Reliability           56                                  100 percent review
                                                               (100 percent)



               K–12 GEER Program Samples
               To determine whether MDE followed its award processes for the K–12 GEER program,
               we selected for review samples of the 557 LEAs and 56 ISDs that were allocated K–12
               GEER program funds. 53 From the universe of 613 LEAs and ISDs that were allocated
               funds, we judgmentally selected for review 10 that were allocated the most K–12 GEER
               program funding (more than $536,076). We then selected a sample of 40 from the
               remaining 603 LEAs and ISDs using a nonstatistical random sampling design. The sample
               resulted in all 50 (8 percent) being LEAs.

               To ensure we performed testing of the ISDs that were allocated K–12 GEER program
               funds, we selected separate samples of ISDs. We used the same randomly selected
               4 ISDs that we used for our Early On testing (see above) and then judgmentally selected
               the 2 ISDs that were allocated the largest amount (more than $80,000) of K–12 GEER
               program funds.

               For the sample of 50 LEAs and 6 ISDs that were allocated K–12 GEER program funds, we
               confirmed that each entity submitted an application with a budget that included uses of




53
  We found that of the 613 LEAs and ISDs that were allocated GEER grant funds, 10 LEAs and 3 ISDs did
not receive GEER grant funds because they either closed or refused the funds after MDE notified them
of their allocation. As a result, 547 LEAs and 53 ISDs actually received GEER grant funds.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                      36
              funds under allowable expenditure categories, signed the required assurances, and
              received an award notification from Michigan.

              Table 2 shows the universes, sample sizes, and sampling methodologies related to our
              testing of the K–12 GEER program.

              Table 2. LEA and ISD Universes and Samples for K–12 GEER Program Testing
                 Testing Purpose           Universe          Sample Size           Methodology

                                                                                 Judgmentally selected
                                                               50 LEAs            10 LEAs with largest
                Award Process LEAs      613 LEAs and ISDs                       allocations and 40 from
                                                              (8 percent)         remaining 603 using
                                                                               simple random sampling

                                                                                Judgmentally selected
                                                                                   2 ISDs with largest
                                                                6 ISDs          allocations and 4 using
                Award Process ISDs           56 ISDs                           simple random sampling
                                                             (11 percent)          (the 4 is the same
                                                                                    sample of ISDs in
                                                                                Table 1, row 1 above).

                                                                 832
                Data Reliability LEAs         832                                100 percent review
                                                             (100 percent)

                                                                  10
                Data Reliability ISDs          56                               Simple random sample
                                                             (18 percent)



              FFF Scholarship Program Samples
              To determine whether Treasury and LEO followed their award processes for the FFF
              Path 1 and FFF Path 2 scholarship program, we conducted testing on a sample of
              25 Path 1 students and 5 Path 2 students.

              FFF Path 1 Sample
              To determine whether Treasury and LEO followed their award processes for the FFF
              Path 1 scholarship program, we first selected a sample of 5 (16 percent) of the 31 IHEs
              participating in the FFF Path 1 scholarship program. That sample consisted of 3 IHEs that
              we judgmentally selected based on them receiving the largest amount of GEER grant
              funds (more than $1.4 million) as of August 5, 2021, and 2 IHEs that we selected using
              nonstatistical random sampling after removing the 3 IHEs that had already been
              selected and 2 IHEs that received less than $10,000 in GEER grant funds as of August 5,
              2021. From the 5 selected IHEs, there were 1,874 total unique students who received



U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                      37
              GEER grant funds. We selected a nonstatistical random sample of 25 (1 percent)
              students (we selected 5 students from each IHE).

              For the sample of 25 students, we confirmed that the students applied for the FFF
              program by December 31, 2020, were approved for FFF Path 1, met the eligibility
              requirements, and were taking the required number of program credits.

              To test Treasury’s reimbursement process, we used the same sample of 25 students and
              confirmed that the amounts requested for reimbursement were calculated correctly
              and that the student accounts were credited for the correct GEER grant amount.

              Table 3 shows the universes, sample sizes, and sampling methodologies related to our
              testing of the FFF Path 1 scholarship program.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                  38
              Table 3. IHE and Student Universes and Samples for the FFF Path 1 Scholarship
              Program Testing
                  Testing Purpose           Universe          Sample Size          Methodology

                                                                                     Judgmentally
                                                                                 selected 3 IHEs with
                                                                                  largest amount of
                                                                  5 IHEs          GEER grant funds
                Award/Reimbursement
                                             29 IHEs                               and used simple
                 Process-Step 1 (IHEs)                         (17 percent)      random sampling to
                                                                                select 2 that received
                                                                                  at least $10,000 in
                                                                                  GEER grant funds

                                                                                Used simple random
                Award/Reimbursement                            25 students      sampling to select 5
                   Process-Step 2         1,874 students                        students from each
                     (Students)                                 (1 percent)       of the 5 selected
                                                                                        IHEs

                                                              1,874 students
                   Data Reliability       1,874 students                         100 percent review
                                                               (100 percent)



              FFF Path 2 Scholarship Program Samples
              To determine whether LEO followed its award processes for FFF Path 2 scholarship
              program, we selected a nonstatistical random sample of 5 (1 percent) of the
              389 students who received GEER grant funds for the FFF Path 2 program.

              For the sample of 5 students, we confirmed that the students applied for the program
              by December 31, 2020, were approved for Path 2, and met the eligibility requirements.
              We also confirmed that the students’ adult education provider had a grant agreement
              and complied with the grant agreement requirements.

              To determine whether LEO followed its reimbursement processes for the FFF Path 2
              scholarship program, we used the same random sample of 5 students and confirmed
              that the adult education providers submitted reimbursement requests that included
              invoices and supporting documentation. We also compared students’ data, such as
              name, enrollment date, and dates of diploma attainment, included with the
              reimbursement request to the participation data submitted to LEO by the provider.

              Table 4 shows the universe, sample sizes, and sampling methodologies related to our
              testing of the FFF Path 2 scholarship program.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                    39
              Table 4. Student Universe and Samples for FFF Path 2 Scholarship Program Testing
                  Testing Purpose           Universe           Sample Size          Methodology

                Award/Reimbursement                                  5              Simple random
                                               389
                      Process                                    (1 percent)           sample

                                                                                     Simple random
                                                                     5             sample (the is the
                   Data Reliability            389                                  same sample of
                                                                 (1 percent)       students from the
                                                                                       row above)



              Other Education-Related Entities (excluding Early On) Sample
              To determine whether MDE followed its award processes for the Evolution Labs,
              Building Healthy Communities: Step Up for School Wellness, television broadcast service
              for teachers and students, and teacher professional learning programs, we performed a
              100 percent review of the award process for all three entities that administered the
              programs (Michigan Virtual University, Michigan Elementary and Middle School
              Principals Association, and Detroit Public Television).

              For the three other education-related entities, we confirmed that each entity submitted
              an application with a budget that included allowable uses of funds, signed a grant award
              approval form, and received an award notification from MDE.

              To determine whether grant funds were used for allowable purposes and whether MDE
              followed its reimbursement process, we reviewed invoices and supporting
              documentation for all expenditures reimbursed as of July 20, 2021. We reviewed the
              invoices to determine whether the expenditures agreed with the allocated budget
              categories included in the entities’ grant application. We reviewed the supporting
              documentation to ensure that invoiced amounts were supported, and expenditures
              were for allowable uses.

              Use of Computer-Processed Data
              We relied, in part, on computer-processed data contained in Michigan’s grant and
              financial management systems.

              Total Expenditure Report
              We used the Total Expenditure Report from Michigan's financial management system to
              determine whether Michigan adhered to cash management regulations. To test the
              reliability of the Total Expenditure Report, we compared it to the GEER grant
              drawdowns from the Department's G5 system and reviewed supporting documentation,


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                        40
                including the program-specific expenditure reports from the cash management system,
                for a sample of expenditures. We found this data to be complete, accurate, and reliable
                for our purposes.

                FFF Path 1 Student Universe
                To test the reliability of the FFF Path 1 student universe, we accessed Treasury’s
                Michigan Student Scholarships and Grants data management system and compared
                eligible Path 1 students included in the student universe in the system to the student
                universe Treasury officials provided to us. We then compared the two data sets to
                ensure the completeness and accuracy of the universe. We confirmed that the student
                identification numbers, IHE name, and scholarship amounts in the data management
                system matched the data in the student universe that Treasury officials provided to us.
                We found this data to be complete, accurate, and reliable for our purposes.

                FFF Path 2 Student Universe
                To test the reliability of the FFF Path 2 student universe, we determined the universe of
                students by identifying the FFF Path 2 students who had a GEER payment included in
                LEO’s invoice tracking spreadsheet. We then accessed LEO’s MAERS reporting system 54
                and determined the number of students who were accepted to the FFF Path 2 program
                and enrolled with an adult education provider. We compared the two data sets to
                ensure that the universe of FFF Path 2 students included on LEO’s invoice tracking
                spreadsheet matched the data in MAERS. We then verified that the student information
                (such as name, birth date, and adult education provider) and invoiced amount from the
                tracking spreadsheet matched the invoices submitted by the adult education provider
                for a random sample of five students. We found this data to be complete, accurate, and
                reliable for our purposes.

                Allocation Spreadsheets
                Michigan allocated K–12 GEER program funds to 557 eligible LEAs and to all 56 ISDs in
                the State. 55 To test the reliability of the K–12 GEER program allocation spreadsheet, we
                verified that the allocation calculations for all 557 LEAs and 56 ISDs were accurate. Also,



54
  LEO’s MAERS reporting system contained application and enrollment data but did not contain invoices
or payment data. Invoices and payments were tracked manually by LEO on an invoice tracking
spreadsheet.
55
  Michigan determined that 557 of the 832 LEAs in the State were eligible to receive K–12 GEER grant
funds. An LEA was eligible to receive the grant funds if over 50 percent of its student population was
considered economically disadvantaged. All ISDs were eligible for K–12 GEER grant funds.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                         41
              for all 832 LEAs and a randomly selected sample of 10 of the 56 ISDs, we verified that
              the counts of total students, economically disadvantaged students, students with
              disabilities, English language learners, and FTEs in the allocation spreadsheet to data
              from the National Center for Education/Elementary and Secondary Information System,
              Civil Rights Data Collection system, Michigan’s school data website, and the State of
              Michigan 2019-2020 State Aid Financial Status Report. We found this data to be
              complete, accurate, and reliable for our purposes.

              To test the reliability of the Early On program allocation spreadsheet, we verified that
              the allocation calculations and allocated amounts were accurate and agreed with the
              allocation methodology and birth count information provided. We found this data to be
              complete, accurate, and reliable for our purposes.

              Based on the work we performed, we determined that the data were sufficiently
              reliable for us to use in meeting the audit objectives.

              Department’s G5 System
              We also relied on computer-processed data obtained from the Department's G5 system.
              We used the G5 grants management system to perform cash management testing and
              identify the amount of GEER grant funds Michigan drew down and returned as of
              November 12, 2021. The G5 grants management system is the official system of record
              for the Department's grants data. As a result, we considered it to be the best available
              data for its intended purpose.

              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 objective.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                                    42
              Appendix B. Acronyms and Abbreviations
               CARES Act       Coronavirus Aid, Relief, and Economic Security Act

               C.F.R.          Code of Federal Regulations

               Department      U.S. Department of Education

               FFF             Future for Frontliners

               GEER grant      Governor’s Education Emergency Relief Fund

               GEMS/MARS       Grant Electronic Monitoring System / Michigan Administrative
                               Review System

               IHE             Institution of Higher Education

               ISD             Intermediate school district

               LEA             Local Education Agency

               LEO             Department of Labor and Economic Opportunity

               MAERS           Michigan Adult Education Reporting System

               MDE             Michigan Department of Education

               MDE Financial   Michigan Department of Education Office of Financial
               Management      Management

               Michigan        State of Michigan

               OMB             Office of Management and Budget

               Pell            Federal Pell Grant

               SBO             Michigan State Budget Office

               Treasury        Michigan Department of Treasury




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                                                          43
                           Michigan’s Comments




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039                                 44
U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039               45
U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039               46
U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039               47
U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039               48
U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039               49
U.S. Department of Education
Office of Inspector General
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U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0039               51


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