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Missouri's Administration of the Governor's Emergency Education Relief Fund Grant (ED-OIG/A20GA0018)

Summary

Final audit report ED-OIG/A20GA0018 of the U.S. Department of Education Office of Inspector General, dated February 10, 2022, on Missouri's Administration of the Governor's Emergency Education Relief Fund Grant, with a transmittal letter from Selina Boyd, Regional Inspector General for Audit. The review covered the first of two GEER grants for the period March 13, 2020, through October 1, 2021. The report states that for two initiatives the awarding processes ensured support for entities most significantly impacted by the coronavirus, but that for the LEA Connectivity Initiative the Department of Elementary and Secondary Education did not correctly implement its designed process. It recommends that Missouri provide evidence that its May 2021 LEA Connectivity Initiative reallocations are accurate and complete. It states that Missouri agreed with all of the findings and recommendations.

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Issuer
U.S. Department of Education, Office of Inspector General
Document type
Report
Date
2022-02-10

Cite this document

“Missouri's Administration of the Governor's Emergency Education Relief Fund Grant (ED-OIG/A20GA0018).” U.S. Department of Education, Office of Inspector General, dated 2022-02-10. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/missouri-geer-administration/, SHA-256 afec1225cb3903ee44fd24323be30ab5d29745ab7a56f9aedc0b10b48bfe14b6.

Full text

              U.S. Department of Education
              Office of Inspector General




Missouri’s Administration of the
Governor’s Emergency Education
Relief Fund Grant
February 10, 2022
ED-OIG/A20GA0018
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




February 10, 2022


The Honorable Michael L. Parson
Governor, State of Missouri
P.O. Box 720
Jefferson City, MO 65102


Dear Governor Parson:

Enclosed is our final audit report, “Missouri’s Administration of the Governor’s Emergency Education
Relief Fund Grant,” Control Number ED-OIG/A20GA0018. 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, who will consider them before taking final Departmental
action on this audit:

        Mark Washington
        Deputy Assistant Secretary
        Office of Administration
        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 ........................................................................................................................ 5
Finding 1. Missouri Designed and Generally Implemented Awarding Processes that
Ensured that GEER Grant Funds Supported LEAs and IHEs that Were Most Significantly
Impacted by the Coronavirus.............................................................................................. 9
Finding 2. Missouri Generally Designed and Implemented Adequate Monitoring
Processes Over IHEs’ and LEAs’ Use of the GEER Grant, But the SEA’s Process Could Be
Strengthened .................................................................................................................... 17
Appendix A. Scope and Methodology............................................................................... 25
Appendix B. Acronyms and Abbreviations........................................................................ 33
Missouri Comments .......................................................................................................... 34
               Results in Brief
               What We Did
               The objectives of the audit were to determine whether the State of Missouri (Missouri)
               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 Missouri received, including the processes that it used to award and monitor GEER
               grant funds, for the period March 13, 2020, through October 1, 2021.

               To accomplish our objectives, we reviewed relevant Federal laws, regulations, and
               guidance. We assessed Missouri’s awarding processes for the three initiatives (LEA
               Transportation Supplement, LEA Connectivity, and IHE initiatives) it funded with the
               GEER grant, including Missouri’s methodology for identifying LEAs and IHEs that were
               most significantly impacted by the coronavirus. To assess Missouri’s awarding
               processes, we reviewed samples of grant applications for the three initiatives Missouri
               funded, in order to determine whether the subgrantees submitted the required
               documentation and signed the required assurances; allocations Missouri awarded to
               LEAs and IHEs, in order to assess the accuracy and completeness of the allocation
               methodology; and Missouri’s drawdown transactions from the U.S. Department of
               Education’s (Department) G5 grants management system, in order to determine
               whether Missouri complied with cash management requirements. We also assessed
               Missouri’s processes for monitoring its GEER grant subgrantees. Our assessment
               included a review of Missouri’s Department of Elementary and Secondary Education’s
               (DESE) and Department of Higher Education and Workforce Development’s (DHEWD)
               monitoring plans and processes. We also reviewed a sample of IHE expenditures to




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.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                         1
                determine whether subgrantees under Missouri’s IHE Initiative used GEER grant funds
                for allowable purposes. 2

                What We Found
                We found that for two of the initiatives Missouri funded with its GEER grant (LEA
                Transportation Supplement Initiative and IHE Initiative), Missouri’s DESE and DHEWD
                designed and implemented awarding processes that ensured the GEER grant was used
                to support LEAs and IHEs that were most significantly impacted by the coronavirus, as
                determined by the State. However, for the third initiative (LEA Connectivity Initiative),
                while DESE created a methodology designed to ensure the GEER grant funds were used
                to support LEAs that were most significantly impacted by the coronavirus, it did not
                correctly implement the process it designed. Specifically, DESE’s implementation
                included an error in its written allocation methodology for a data element used to
                identify the LEAs most significantly impacted by the coronavirus and a formula error in
                the calculation used to rank LEAs as most significantly impacted by coronavirus. DESE’s
                implementation also lacked documentation to fully support that reallocations due to
                changes in guidance for equitable services to nonpublic schools and the correction of a
                formula error were accurate and complete. 3 Because DESE did not provide
                documentation to fully support its LEA Connectivity Initiative reallocations, the audit
                team could not determine whether Missouri awarded GEER grant funds to LEAs most
                significantly impacted by the coronavirus.

                We found that for all three initiatives, Missouri ensured that the LEAs and IHEs that
                received a GEER grant allocation submitted the required applications and assurances.
                We also found that Missouri followed cash management requirements.

                We found that Missouri’s DHEWD designed and implemented a comprehensive
                reimbursement process as its monitoring strategy to ensure that subgrantees of its IHE
                Initiative used GEER grant funds in accordance with the CARES Act and other applicable
                Federal requirements. However, we found that DESE’s plan for monitoring subgrantees
                of its LEA Connectivity and LEA Transportation Supplement initiatives could be
                strengthened. Specifically, DESE should include in its monitoring plan a requirement for



2
 We did not review a sample of LEA reimbursements for allowability because DESE’s process for
reimbursement did not include the collection and review of supporting documentation related to LEAs’
expenditures under Missouri’s LEA Connectivity and LEA Transportation Supplement initiatives.
3
 Before this draft audit report was issued, DESE revised its written allocation methodology and
corrected the formula error in the calculation used to rank LEAs.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                            2
              LEAs to certify their responses to the self-assessment questionnaire DESE will use for
              monitoring, and develop protocols to review LEAs’ expenditures, as this will provide
              additional assurance that subgrantees used GEER grant funds for allowable purposes.

              After the exit conference, DESE added a requirement in its GEER Fiscal Monitoring Guide
              for LEAs to certify their responses to the self-assessment monitoring questionnaire, and
              revised the guide to include a review of high-risk LEAs’ expenditures during on-site
              monitoring reviews. However, because the number of LEAs likely to be identified as
              high-risk based on DESE’s risk assessment process is small, also reviewing a sample of
              medium-risk LEAs’ expenditures would increase the likelihood that DESE’s monitoring
              process would identify unallowable expenditures.

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

                  •   provide evidence that its May 2021 LEA Connectivity Initiative reallocations are
                      accurate and complete, and if not, make proper corrections as needed, and
                      inform the affected LEAs accordingly;

                  •   develop and implement controls to ensure that allocation methodologies are
                      implemented as designed, and funding decisions are fully supported; and
                  •   develop and implement protocols to review a sample of medium-risk LEAs’
                      expenditures for allowability.

              Missouri Comments
              We provided a draft of this report to Missouri for comment. We summarized Missouri’s
              comments at the end of each finding and provided the full text of the comments at the
              end of this report. Missouri agreed with all of our findings and recommendations and
              proposed corrective actions to address our recommendations. Missouri also provided
              documentation to support the implementation of its proposed corrective actions to
              address the recommendation that the May 2021 LEA Connectivity Initiative reallocations
              are corrected so that the allocations are accurate and complete.

              OIG Response
              Missouri’s proposed corrective actions, if effectively implemented, are responsive to our
              recommendations. We did not change our findings or recommendations as a result of
              information submitted subsequent to our audit period. However, the documentation
              that Missouri provided related to its May 2021 LEA Connectivity Initiative reallocations
              appears supportive of the State’s efforts to implement its proposed corrective actions. It
              will be important for Missouri to work with the Department to ensure that all

U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                         3
              recommendations are appropriately and sufficiently resolved and that corrective actions
              are fully implemented.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                   4
                  Introduction
                  Purpose
                  The objectives of the audit were to determine whether the State of Missouri (Missouri)
                  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 March 13, 2020, through
                  October 1, 2021.

                  Background
                  GEER Grant Authorized by the CARES Act
                  The CARES Act, 4 which was 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 5 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 the 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 counted 6 under section 1124(c) of the Elementary and Secondary Education
                  Act of 1965, as amended (ESEA). Governors that received a GEER grant were required by



4
    Public Law No. 116-136.
5
 The Department’s Frequently Asked Questions About the 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.
6
 For example, children counted for the purposes of making Title I, Part A formula grants to local
educational agencies, or the Title I, Part A formula count.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                           5
                the Department to designate a State agency as the fiscal agent 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) 7 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.

                U.S. Department of Education’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




7
 Section 18003(d)(1) of the CARES Act authorizes LEAs to use GEER grant funds for any activity
authorized by the ESEA of 1965, 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/A20GA0018                                                                                           6
                  Department by June 8, 2020. 8 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 use of the
                  GEER grant funds and programmatic, fiscal, and reporting assurances.

                  The Department’s Certification and Agreement required States, within 45 days of
                  receiving a GEER grant award, to submit an initial report to the Department detailing
                  their 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. 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.

                  Missouri’s GEER Grant Initiatives
                  The Governor of Missouri received $54.6 million in GEER grant funds. Missouri allocated
                  $30 million to its Department of Elementary and Secondary Education (DESE), which was
                  the State’s fiscal agent, and $24.6 million to its Department of Higher Education and
                  Workforce Development (DHEWD).

                  DESE conducted webinars to inform LEAs of its initiatives funded by the GEER grant, and
                  DESE and DHEWD provided grant packages to LEAs and public IHEs, respectively, that
                  included an application; instructions on the application and reimbursement processes;
                  and the programmatic, fiscal, and reporting assurances from the Department’s
                  Certification and Agreement for GEER grant funds. The packages also included
                  compliance requirements and guidance on allowable and unallowable expenditures. By
                  signing the application, LEAs and IHEs agreed to comply with all applicable GEER grant
                  requirements.



8
    The deadline was extended from its original date of June 1, 2020, to June 8, 2020.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                          7
              DESE Initiatives
              DESE allotted $15 million of its GEER grant funds for its LEA Connectivity Initiative that
              was intended to increase the number of elementary and secondary education students
              who have access to the internet and digital learning resources. Allowable expenditures
              included Wi-Fi enabled devices and costs to provide Wi-Fi enabled device functionality.
              DESE allotted the remaining $15 million in GEER grant funds for its LEA Transportation
              Supplement Initiative to assist LEAs with transportation-related expenses arising from
              the coronavirus. Allowable expenditures included school bus and fuel purchases,
              medical and cleaning supplies, and salary and benefits for bus drivers and aides.

              DHEWD Initiatives
              DHEWD allotted $23.6 million of its GEER grant funds to an IHE Initiative that was
              intended to provide institutional support to its 23 public IHEs, all of which had a
              12 percent reduction in funding for fiscal year 2021 due to shortfalls in Missouri’s
              General Revenue Fund. Allowable expenditures included salaries for staff and
              infrastructure and technological expenses incurred to provide educational services and
              institutional support in a remote environment. DHEWD plans to use its remaining
              $1 million in GEER grant funds for a pilot program, Re-Enrollment and Persistence
              Coaching, that is expected to provide coaching to students who have prior college credit
              but are not currently enrolled. We did not review DHEWD’s plans for this pilot program
              because the program was still being developed at the time of our review.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                           8
              Finding 1. Missouri Designed and Generally
                Implemented Awarding Processes that
                Ensured that GEER Grant Funds Supported
                LEAs and IHEs that Were Most Significantly
                Impacted by the Coronavirus
              We found that for two of the initiatives Missouri funded with its GEER grant (LEA
              Transportation Supplement Initiative and IHE Initiative), Missouri’s DESE and DHEWD
              designed and implemented awarding processes that ensured that the GEER grant was
              used to support LEAs and IHEs that were most significantly impacted by the coronavirus,
              as determined by the State. We also found that the factors Missouri included in the
              allocation methodologies for the two initiatives aligned with the intent of the CARES Act
              to support LEAs and IHEs most significantly impacted by coronavirus.

              For a third initiative that Missouri funded with its GEER grant (LEA Connectivity
              Initiative), although DESE created a methodology designed to ensure that the GEER
              grant funds were used to support LEAs that were most significantly impacted by the
              coronavirus, it did not correctly implement the process it designed. DESE’s
              implementation included an error in a data element in its written allocation
              methodology to identify the LEAs most significantly impacted by the coronavirus and a
              formula error in the calculation used to rank LEAs as most significantly impacted by
              coronavirus. DESE’s implementation also lacked documentation to fully support that
              reallocations due to changes in guidance for equitable services to nonpublic schools and
              correction of a formula error were accurate and complete. As such, we could not
              determine whether Missouri awarded GEER grant funds to LEAs most significantly
              impacted by the coronavirus.

              Allocation Methodology for LEA Transportation Supplement
              and IHE Initiatives
              DESE’s LEA Transportation Supplement Initiative allocation methodology used DESE’s
              annual transportation allocation formula, which considers factors such as the number of
              miles driven, the number of students transported, and annual transportation expenses
              to identify LEAs with the greatest transportation burden. The purpose of the LEA
              Transportation Initiative was to address LEAs’ additional transportation needs, such as
              the need for additional sanitation for buses, and additional routes, buses, and drivers to
              allow for social distancing of riders, due to coronavirus. DESE allocated GEER grant funds
              to 539 of its 558 LEAs for this initiative.

              DHEWD’s IHE Initiative allocation methodology used the number of students enrolled,
              the number of faculty and staff employed, and the number of Pell grant recipients

U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                      9
                enrolled at the State’s public IHEs to identify those with the greatest need, reasoning
                that these IHEs would have the largest number of students, faculty, and staff affected by
                coronavirus. Public IHEs experienced a 12-percent reduction in funding for fiscal
                year 2021 due to shortfalls in Missouri’s General Revenue Fund, and the GEER grant
                helped to alleviate that reduction. DHEWD allocated GEER grant funds to 23 public IHEs
                for this initiative.

                Allocation Methodology for DESE’s LEA Connectivity Initiative
                To fund the LEA Connectivity Initiative, DESE initially allotted $15 million in GEER grant
                funds and $4.9 million in ESSER grant funds. According to DESE’s written allocation
                methodology for the LEA Connectivity Initiative, DESE was to allocate the GEER grant
                funds to LEAs that DESE identified as most significantly impacted by the coronavirus, as
                required. The written methodology did not specify how the ESSER funds were to be
                allocated to LEAs for this initiative; however, DESE explained that after it applied all the
                LEA Connectivity Initiative’s GEER grant funds, it continued down the ranked list of LEAs,
                funding LEAs until the ESSER grant funds were exhausted. The purpose of the LEA
                Connectivity Initiative was to increase the number of students who have access to the
                internet and digital learning resources by providing Wi-Fi enabled devices and hotspots
                to students. Missouri has an estimated 200,000 students who lack access to digital
                learning resources, which poses a challenge for schools to maintain continuity of
                learning when public health factors (such as coronavirus) cause school closures.
                Affordability contributes to the lack of digital learning resources and some families
                cannot afford wi-fi enabled devices, cellular data, or monthly broadband charges.

                To allocate GEER grant funds related to its LEA Connectivity Initiative, DESE first used
                two factors that provided a basis for determining the LEAs that were most significantly
                impacted by the coronavirus: the DDI socioeconomic score for the county where the LEA
                is located and the LEA’s free and reduced lunch (FRL) rate. The DDI socioeconomic score
                originates from a study conducted by Purdue University, and provides a measure of
                socioeconomic characteristics 9 that are known to impact people’s adoption of
                technology. The FRL rate is the rate of students in the district that qualify for free and
                reduced lunch prices.

                In an allocation spreadsheet, DESE averaged the DDI socioeconomic score and FRL rate
                for each LEA to arrive at a calculated score for each of the 555 LEAs that had



9
  Examples of socioeconomic characteristics known to impact technology adoption are the percent of
the population that is age 65 and over, the percent of the population that is age 25 and older that has
less than a high school education, and the individual poverty rate for the county.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                          10
                connectivity issues. 10 The LEAs with the highest scores were considered most
                significantly impacted by the coronavirus. DESE ranked the 555 LEAs by score, highest to
                lowest, and then performed a calculation using two additional factors to determine the
                amount of GEER grant funds each LEA should be allocated: Student Funding Base
                (20 percent of the LEA's 2019 student enrollment) and Per Student Funding (FRL rate
                multiplied by $300). DESE then multiplied the Student Funding Base factor by the Per
                Student Funding factor to determine the amount of funds each LEA should be allocated
                for the Connectivity Initiative. However, because there was only $15 million of GEER
                grant funds and $4.9 million of ESSER grant funds allotted to the LEA Connectivity
                Initiative, not all of the 555 LEAs could receive funds for the LEA Connectivity Initiative
                based on the proposed allocation amounts in the spreadsheet. Therefore, DESE applied
                the GEER grant funds to LEAs by starting at the top of the ranking list of 555 LEAs
                (highest scores represent most significantly impacted) and working down the list until
                the $15 million in GEER grant funds were exhausted. As such, DESE allocated the GEER
                grant funds to 296 of the 555 LEAs. Next, using the $4.9 million in ESSER grant funds,
                DESE was able to apply ESSER grant funds to the next 111 LEAs on the ranking list. The
                remaining LEAs on the ranking list did not receive funds for the Connectivity Initiative.
                See Figure 1 for DESE’s Connectivity Initiative allocation process illustrated as described
                above.

                DESE notified the LEAs of their GEER grant allocation amount, required the LEAs to
                submit an application and a budget to receive the allocation, and informed them that
                the funds will be available on a reimbursement basis. As of September 22, 2021, not all
                of the original 296 LEAs had applied for their GEER grant allocation; however, DESE
                stated that it believed that all of them would apply for the funds before the obligation
                deadline, which was September 30, 2021.




10
  Three of Missouri’s 558 LEAs were not eligible for GEER grant funds under the LEA Connectivity
Initiative because they did not have connectivity issues: Missouri Schools for the Severely Disabled,
Pemiscot County Special School District, and Voluntary Interdistrict Choice Corporation.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                        11
              Figure 1. DESE’s Connectivity Initiative Allocation Process
                             To Rank the 555 LEAs (with connec�vity issues),
                                  Perform This Calcula�on for Each LEA

                                                                                             Average of LEA’s FRL
                                      LEA’s Free and                                            and LEA’s DDI
                                      Reduced Lunch               LEA’s County DDI           Socioeconomic Score
                                        Rate (FRL)              Socioeconomic Score           = LEA’s Calculated
                                                                                                    Score


                                                               Using the LEA’s Calculated Score, Rank the LEAs from Highest to
                                                               Lowest, Then for Each LEA Perform This Calcula�on to Determine
                                                                  the Proposed Amount of Funds Each LEA Should Receive



                                      LEA Student Enrollment                   FRL x $300                       LEA’s Proposed
                                              x 20%                       = Per Student Funding               Alloca�on Amount
                                      = Student Funding Base                      Factor                      ($9,000 minimum)



                                                                Allocate the GEER Grant Funds to LEAs Beginning at the
                                                                Top of the Ranked List Un�l the $15 Million is Exhausted




                                                            Are                                         Are
                                                        GEER Grant                                  ESSER Grant
                     Use GEER Grant                        Funds                                       Funds
                                          Yes                                                                                    No Funds Available
                      to Fund LEA’s                     Available to               No             NoAvailable to           No     to Cover the LEA’s
                        Proposed                         Cover the                                   Cover the
                                                                                                       LEA’s                     Proposed Alloca�on
                        Alloca�on                          LEA’s
                                                                                                     Proposed                         Amount
                         Amount                          Proposed
                                                         Alloca�on                                   Alloca�on
                                                         Amount?                                     Amount?

                        296 LEAs Were Allocated                                                                        Proposed Alloca�on Amount
                          GEER Grant Funds                                                          Yes                was not Funded for 148 LEAs


                                                                                               Use ESSER Grant to
                                                                                                   Fund LEA’s
                                                                                                    Proposed
                                                                                               Alloca�on Amount



                                                                                          111 LEAs Were Allocated ESSER
                                                                                                  Grant Funds




              Data Element Error in Implementation of Allocation
              Methodology
              We found that the DDI score that DESE used to determine the LEAs’ coronavirus impact
              in its calculation to rank the 555 LEAs was not the DDI score included in the written
              allocation methodology DESE published on its website in its Guidance for the Missouri
              Student Connectivity Grant, dated August 6, 2020, and reported to the Department in
              its 45-day report. According to DESE’s written allocation methodology, one of the
              factors that it planned to use to rank the LEAs was the DDI infrastructure score, which
              measures the percentage of the population that does not have internet access or
              computing devices in a specific county. However, as described in the section above,
              DESE used the DDI socioeconomic score in the allocation spreadsheet. Although both
              factors relate to what is known as the “digital divide”—the gap between those who have
              access to technology and those who do not—and could therefore be used to determine
              coronavirus impact for the purpose of this initiative, anyone who viewed Missouri’s




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                                                                       12
                website and 45-day report to learn how it allocated GEER grant funds to LEAs would not
                have had an accurate understanding of the factors that Missouri actually used.

                According to the Assistant Commissioner for the Office of Quality Schools (OQS), DESE’s
                intent was to use the DDI socioeconomic score and not the DDI infrastructure score, but
                somehow, they included the wrong language in the written allocation methodology. The
                Assistant Commissioner stated that several staff members reviewed the written
                allocation methodology but did not identify the error. Before this draft audit report was
                issued, Missouri provided additional documentation as evidence that it revised the
                allocation methodology on its website to include its use of Purdue University’s DDI
                socioeconomic score instead of the DDI infrastructure score.

                Formula Errors in the Allocation Spreadsheet
                We also found that the DDI socioeconomic scores DESE used to rank LEAs for GEER grant
                allocations were incorrect for 73 of the 555 LEAs, which resulted in 554 LEAs being
                incorrectly ranked on DESE’s August 2020 allocation calculation spreadsheet. To rank
                LEAs, DESE used a spreadsheet it obtained from a Purdue University study that
                contained a DDI socioeconomic score for each county in Missouri. In the allocation
                calculation spreadsheet that DESE created, DESE used a Microsoft Excel VLOOKUP
                formula that was intended to pull the DDI socioeconomic score from the Purdue
                University spreadsheet for the county where each LEA is located. 11 However, DESE’s
                allocation calculation spreadsheet contained an error in the VLOOKUP formula that
                caused 73 LEAs to be assigned the incorrect socioeconomic score and the 554 LEAs to be
                incorrectly ranked.

                In March 2021, DESE revised the August 2020 allocation calculation spreadsheet to
                correct the DDI socioeconomic scores for the 73 LEAs, after we informed DESE of the
                errors. The corrections resulted in the re-ranking of the 554 LEAs. Because the ranking
                of the LEAs changed with the March 2021 correction, DESE had to reallocate the GEER
                grant funds to ensure the LEAs most significantly impacted by the coronavirus (as
                determined by DESE’s corrected LEA rankings list) were allocated GEER grant funds.




11
   The Vlookup function is a built-in function in Microsoft Excel that makes Excel “look up” data in a table
and places that data into another location in the same spreadsheet or in a different spreadsheet located
in the same Microsoft Excel workbook as the source data.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                         13
                DESE performed this reallocation in May 2021, which resulted in 290 LEAs being
                allocated $14.7 million in GEER grant funds. 12

                DESE provided us with Excel spreadsheets to support its May 2021 reallocation of GEER
                grant funds; however, the spreadsheets did not contain sufficient data for us to
                determine whether the new LEA allocation amounts for the 290 LEAs were correct. For
                example, the spreadsheets did not include the formulas used to calculate the 555 LEAs’
                preliminary reallocation amount, which would dictate those LEAs that should ultimately
                be offered a GEER grant allocation versus LEAs that should be offered an ESSER grant
                allocation versus LEAs that should not be offered any allocation for the LEA Connectivity
                Initiative. Because DESE did not provide documentation to fully support the reallocation
                amounts, we are not able to determine if the LEAs that were allocated GEER grant funds
                were those that were most significantly impacted by the coronavirus as determined by
                DESE’s March 2021 corrected LEA rankings list.

                According to the CARES Act Section 18002(c)(1), GEER grant funds may be used to
                provide emergency support through grants to LEAs that the 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.

                According to 2 Code of Federal Regulations (C.F.R.) section 200.303(a) and (c), a non-
                Federal entity should 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, and the terms and conditions of the
                Federal award. Further, the non-Federal entity must also evaluate and monitor its
                compliance with statutes, regulations, and the terms and conditions of Federal awards.

                The U.S. Government Accountability Office’s “Standards for Internal Control in the
                Federal Government” Principle 10 states that management should design appropriate
                types of control activities for the entity’s internal control system. Control activities help
                management fulfill responsibilities and address identified risk responses in the internal
                control system. Principle 13 states that management should process obtained data into
                quality information that supports the internal control system. Quality information is
                appropriate, current, complete, accurate, accessible, and provided on a timely basis.


12
  The amount of GEER grant funds available for the LEA Connectivity Initiative’s reallocations had
changed in November 2020 to comply with the Department’s updated guidance on allocating GEER
grant funds for equitable services to nonpublic schools, which resulted in less money allocated to LEAs
($14.7 million instead of $15 million).


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                           14
              Management considers these characteristics as well as the information processing
              objectives in evaluating processed information and makes revisions when necessary, so
              that the information is quality information. Management processes relevant data from
              reliable sources into quality information within the entity’s information system.
              Management uses the quality information to make informed decisions and evaluate the
              entity’s performance in achieving key objectives and addressing risks.

              The issues described above occurred because DESE did not have sufficient controls in
              place to ensure that staff followed the written allocation methodology and correctly
              applied the formulas in the allocation spreadsheets. Specifically, DESE did not have
              written procedures or a formal review process to compare its planned allocation
              methodology (as reported to the Department) with the allocation methodology that it
              implemented, or processes to ensure the accuracy and completeness of its allocation
              spreadsheets. In addition, DESE did not have sufficient controls in place to ensure that it
              had adequate documentation to fully support its May 2021 LEA Connectivity awarding
              decisions.

              As previously discussed, errors in DESE’s initial LEA Connectivity allocation calculation
              spreadsheet resulted in DESE having to reallocate GEER grant funds to ensure that LEAs
              most significantly impacted by the coronavirus received a GEER grant. However,
              because the spreadsheets that were supposed to support the reallocations did not
              contain sufficient data, we are not able to determine if the LEAs that were allocated
              GEER grant funds were those that were most significantly impacted by the coronavirus.

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

                  1.1 provide evidence that its May 2021 LEA Connectivity Initiative reallocations are
                      accurate and complete, and if not, make proper corrections as needed, and
                      inform the affected LEAs accordingly; and

                  1.2 develop and implement controls to ensure that allocation methodologies are
                      implemented as designed, and funding decisions are fully supported.

              Missouri Comments
              Missouri agreed with the finding and recommendations. Missouri stated that it has
              completed the corrections to the LEA Connectivity Initiative reallocations so that they
              are accurate and complete and informed the affected LEAs accordingly. Missouri
              provided documentation to support implementation of the corrective actions related to
              Recommendation 1.1. Missouri also stated that it will develop and implement a


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                      15
              procedure to ensure allocation methodologies for all Federal grants are executed as
              designed and verified for accuracy in response to Recommendation 1.2.

              OIG Response
              Missouri’s proposed corrective actions, if effectively implemented, are responsive to our
              recommendations. We did not change our finding or recommendations as a result of
              information submitted subsequent to our audit period. However, the documentation
              that Missouri provided related to its LEA Connectivity Initiative reallocations appears
              supportive of the State’s efforts to implement its proposed corrective actions for
              Recommendation 1.1. It will be important for Missouri to work with the Department to
              ensure that both recommendations are appropriately and sufficiently resolved and that
              corrective actions are fully implemented.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                    16
              Finding 2. Missouri Generally Designed and
                Implemented Adequate Monitoring Processes
                Over IHEs’ and LEAs’ Use of the GEER Grant,
                But the SEA’s Process Could Be Strengthened
              We found that Missouri’s DHEWD designed and implemented a comprehensive
              reimbursement and monitoring process to ensure that subgrantees for its IHE Initiative
              used GEER grant funds in accordance with the CARES Act and other applicable Federal
              requirements. For a sample of expenditures related to the IHE Initiative, we reviewed
              supporting documentation and found that DHEWD’s reimbursement process provided
              effective monitoring and ensured that IHEs used GEER grant funds for allowable
              purposes. We also found that Missouri’s DESE designed and implemented a
              reimbursement process for LEAs that provided some level of assurance that LEAs used
              GEER grant funds for allowable purposes for the LEA Connectivity and LEA
              Transportation Supplement initiatives. Although the monitoring plan that DESE designed
              for those initiatives includes several activities to address LEAs’ compliance with
              applicable requirements, the plan could be strengthened. Specifically, DESE’s monitoring
              plan did not include protocols for reviewing supporting documentation for LEAs’
              expenditures or a requirement that LEAs certify the information provided to DESE as a
              part of their self-assessment monitoring process. After we discussed this area for
              improvement with Missouri during our exit conference, DESE provided a revised GEER
              Fiscal Monitoring Guide, Fiscal Year 2022, that included a review of high-risk LEAs’
              supporting documentation related to GEER grant-funded expenditures during onsite
              reviews and a requirement for LEAs to certify their responses to the self-assessment
              questionnaire. However, LEA monitoring could be strengthened to provide additional
              assurance that LEAs used GEER grant funds for allowable purposes and that the
              information provided was accurate.

              DHEWD’s GEER Grant Reimbursement and Monitoring Process
              for IHEs
              DHEWD designed and implemented a comprehensive reimbursement process that it
              used to monitor IHE’s expenditures. We found that the reimbursement process ensured
              IHEs used GEER grant funds for allowable purposes. Initially, DHEWD provided IHEs with
              a grant package that included a list of allowable expenditures, guidelines, required
              assurances, and instructions on the application and reimbursement processes. DHEWD
              included a “Federal Funding Certification for GEER Funds” form in the grant package and
              required IHEs to submit the form before submitting any reimbursement requests. By
              signing the form, the IHE is bound by all terms and conditions outlined in the grant
              package. DHEWD also required IHEs to submit a certified request form that included


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                   17
                details of how the funds were used, an invoice or other supporting documentation, and
                proof of payment for the full amount of the payment requested, with their
                reimbursement request. DHEWD officials documented their review and approval of the
                reimbursement request by emailing DESE’s Accounting and Procurement Division to
                request the transfer of funds. DHEWD officials also maintained a ledger separately from
                the Statewide Advantage for Missouri (SAM II) accounting system to track each IHE’s
                payments and allocation balances to ensure that the IHEs were not reimbursed for more
                than they were awarded. 13 We selected a judgmental sample of 17 from a population of
                48 expenditures. For the sample of expenditures, we reviewed supporting
                documentation and confirmed that DHEWD officials followed their reimbursement and
                monitoring process, documented their approvals, and that the IHEs used expenditures
                for allowable purposes. We found that for the sample tested, DHEWD’s reimbursement
                process provided effective monitoring and ensured that IHEs used GEER grant funds for
                allowable purposes.

                DESE’s GEER Grant Reimbursement and Monitoring Processes
                for LEAs
                We found that DESE developed and implemented a GEER grant reimbursement process
                that provides some level of assurance on the allowability of expenditures for which LEAs
                requested reimbursement with GEER grant funds. We also found that DESE developed
                but has not begun implementing a monitoring process that will rely on risk assessments
                so that DESE can target its efforts and which will entail a combination of self-
                assessments and desk reviews, on-site reviews, and desk audits. However, the
                monitoring plan that DESE designed for the GEER grant could be strengthened.

                DESE’s GEER Grant Reimbursement Process for its LEA
                Connectivity and LEA Transportation Supplement Initiatives
                DESE developed and implemented a process to disburse GEER grant funds to applicable
                LEAs on a reimbursement basis (for the LEA Connectivity and LEA Transportation
                Supplement Initiatives), that provided some level of assurance on the allowability of
                expenditures. Initially, DESE provided LEAs with a grant package that included a list of
                allowable expenditures, guidelines, required assurances, and instructions on the
                application and reimbursement processes. DESE also created a GEER grant webpage to



13
  The SAM II is Missouri's integrated financial, human resource, and payroll system. The SAM II system
incorporates accounts payable, accounts receivable, fixed asset accounting, grants and project
accounting, budget preparation and budget control, purchasing, human resources, and payroll
processing for all State departments and agencies.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                      18
                   provide LEAs with information to assist them in complying with GEER grant
                   requirements. To receive GEER grant reimbursements for its LEA Connectivity and LEA
                   Transportation Supplement Initiatives, DESE requires LEAs to submit an online
                   reimbursement request form that lists the amount(s) requested and the related
                   accounting code(s) that were in their approved budgets. DESE requires LEAs to retain
                   supporting documentation for expenditures included in the reimbursement request;
                   however, they were not required to submit the supporting documentation along with
                   the reimbursement request.

                   DESE also required LEAs to certify that the expenditures listed in their reimbursement
                   requests were allowable, complied with GEER grant requirements, and were included in
                   the pre-determined categories 14 listed on the LEAs’ approved budgets. DESE Regional
                   Supervisors review the LEA Connectivity Initiative reimbursement requests and DESE’s
                   Student Transportation Manager reviews the LEA Transportation Supplement Initiative
                   reimbursement requests. In addition, DESE’s CARES Act Coordinator conducts a second-
                   level review of the LEA Connectivity Initiative reimbursements. According to DESE’s
                   CARES Act Coordinator and Student Transportation Manager, the reviewers verify that
                   the required assurance is included with the reimbursement request, the accounting
                   code(s) and the amount(s) expended are in line with the LEA’s approved budget, and
                   there are sufficient funds budgeted to cover the amount of reimbursement requested.

                   DESE’s GEER Grant Monitoring Process for LEAs
                   DESE developed a monitoring process but has not yet begun monitoring the LEAs’ use of
                   GEER grant funds. 15 Although the monitoring process includes several activities meant
                   to address LEAs’ compliance with applicable requirements, we found that it could be
                   strengthened. Specifically, DESE’s monitoring process did not include a protocol to
                   review supporting documentation related to LEAs’ expenditures. Adding such a review
                   would strengthen DESE’s monitoring process and provide additional assurance that LEAs
                   used GEER grant funds for allowable purposes. In addition, LEAs are not required to
                   certify their responses to the questions included in DESE’s self-assessment monitoring
                   process. Requiring LEAs to certify their responses would provide DESE with additional
                   assurance that the information provided was accurate. DESE plans to monitor LEAs that
                   were awarded GEER grant funds for the LEA Connectivity and LEA Transportation
                   Supplement Initiatives by conducting a risk assessment to determine what level of



14
  Some of the pre-determined expenditure categories include salaries, employee benefits, purchased
services, materials, supplies, contracted services, and transportation equipment purchases.
15
     DESE provided a draft version of its GEER Fiscal Monitoring Guide, Fiscal Year 2022.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                       19
              monitoring an LEA selected for review will receive. After we discussed these areas for
              improvement with Missouri during our exit conference, DESE provided a revised GEER
              Fiscal Monitoring Guide, Fiscal Year 2022, that included a review of high-risk LEAs’
              supporting documentation related to GEER grant-funded expenditures during onsite
              reviews and a requirement for LEAs to certify their responses to the self-assessment
              questionnaire.

              Risk Assessment Process
              To determine the level of monitoring LEAs will undergo, DESE will conduct two annual
              risk assessments: one for LEAs that received GEER grant funds for the LEA Connectivity
              Initiative and one for LEAs that received GEER grant funds for the LEA Transportation
              Supplement Initiative. DESE will categorize all LEAs as high, medium, or low-risk during
              its risk assessment process. Each risk assessment uses 12 risk indicators, and for each
              indicator the LEA is scored either a “0” for no or a “5” for yes, for a maximum risk score
              of 60 points. Since the scoring system for the risk assessments essentially requires a yes
              or no response, having multiple identified issues in a single risk indicator does not
              increase the score. For example, issues included under the “Financial Concerns” risk
              indicator include financial distress, impending school closure, indications of fraud or
              abuse, Cash Management Plan assignment, and award restrictions in the fiscal year
              under review. The risk assessments also include indicators specific to the grant being
              monitored. Some of the indicators DESE plans to use to assess risk for GEER grants
              include an allocation above $90,000 for the LEA Connectivity Initiative or above
              $50,000 for the LEA Transportation Supplement Initiative, prior audit findings, and
              whether the LEA had five or more budget revisions.

              DESE will classify LEAs with issues in fewer than 5 of the 12 risk indicators (which results
              in a risk score of 20 or less) as low-risk with no monitoring required. LEAs that have
              issues identified for 5 to 8 of the 12 risk indicators (which results in a risk score between
              25 and 40) are assessed as medium-risk and will be monitored by a self-assessment and
              desk review. LEAs that have issues identified for 9 to 12 of the 12 risk indicators (which
              results in a risk score of 45 or more) are assessed as high-risk and will be monitored by
              an on-site review. Table 1 shows the type of monitoring that will be conducted based on
              the results of the monitoring risk assessments. DESE will conduct the risk assessments
              for the GEER grant in October 2021 and expects to complete the monitoring process in
              March 2022. Because DESE has not yet conducted the risk assessments, it has not
              determined how many of the 290 LEAs that received funds for its LEA Connectivity
              Initiative or how many of the 539 LEAs that received funds for its LEA Transportation
              Supplement Initiative will receive a self-assessment and desk review, on-site review, or
              no review.



U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                        20
               Table 1. Monitoring Actions Based on Risk Scores
                  Risk Assessment Levels            Risk Score                       Action

                                              Risk score of 45 or more
                         High-Risk                                               On-Site Review
                                            (issues in 9 to 12 risk areas)

                                                Risk score between
                                                     25 and 40               Self-Assessment and Desk
                       Medium-Risk
                                                                                      Review
                                             (issues in 5 to 8 risk areas)

                                                Risk Score 20 or less
                         Low-Risk                                                   No Action
                                             (issues in 1 to 4 risk areas)


               Self-Assessment and Desk Review Process
               LEAs assessed as medium-risk will be required to perform a self-assessment. The self-
               assessment consists of 31 questions that LEAs must answer with either “yes,” “no,” or
               “not applicable,” and provide comments where required. 16 The questions relate to
               allowable uses of funds, obligation of funds, coding of expenditures, cash management,
               procurement, time and effort, inventory, and nonpublic school services or equitable
               services. DESE’s monitoring team conducts a desk review of the self-assessment
               responses for compliance with Department guidance, Federal laws, and regulations. If
               the LEA responds to questions with “no” or “not applicable,” the LEA may be asked to
               provide additional information or upload supporting documentation for further review.
               Additionally, if the reviewer identifies discrepancies between the LEA’s responses, the
               reviewer may ask the LEA to provide additional information or upload supporting
               documentation. For example, if the LEA responds that it did not spend funds on payroll
               but then reports an amount for expenditures under salaries in another question then
               the reviewer may ask for additional documentation to reconcile the discrepancy
               between the two responses. DESE’s self-assessment process does not include a review
               of supporting documentation related to LEAs’ expenditures or a requirement for LEAs to
               certify their responses; however, after we discussed this area for improvement with
               Missouri at the exit conference, DESE provided documentation to support that it revised
               its process to require LEAs to certify their responses to the self-assessment.




16
  LEAs respond to the questionnaire in DESE’s Tiered Monitoring System, a web-based platform that
serves as a repository for LEAs to upload documents, respond to questions, and complete assessments.
DESE uses this system to conduct monitoring of LEAs.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                        21
               On-site Review Process
               In DESE’s monitoring plan, LEAs that will be required to have an on-site review must
               provide the DESE monitoring team with the documents listed below, before the start of
               the on-site review. The CARES Coordinator and the monitoring team review the
               documentation and fill out the same questionnaire used in the self-assessment and desk
               review process described above, using the following documents:

                   •   General Ledger for the fiscal year sorted by project code for all expenditures;

                   •   Monthly General Ledgers for the fiscal year for all expenditures;

                   •   Payroll Report for all staff paid with GEER grant funds;

                   •   List of LEA staff paid with GEER grant funds; and

                   •   Time and Effort documentation for the fiscal year under review.
               Although the monitoring plan states that DESE may ask the LEA to provide additional
               supporting documentation for further review, this is at the monitoring team’s
               discretion, so it may not include supporting documentation for expenditures or may not
               occur at all. However, after we discussed this issue with Missouri at the exit conference,
               DESE provided documentation to support that it revised its on-site review process to
               include a review of supporting documentation related to GEER grant-funded
               expenditures for the high-risk LEAs.

               After the self-assessment and desk reviews or on-site reviews are completed, DESE
               plans to issue a report to each LEA that indicates whether the LEA complied with Federal
               requirements. If the LEA was not in compliance with the requirements, the report will
               identify the deficiencies and include a corrective action plan. The LEA must correct any
               deficiencies within 30 days.

               Desk Audits
               As an additional step in its monitoring plan, DESE also plans to perform desk audits each
               fiscal year, to review all LEAs’ GEER grant-related documentation, separate from the
               tiered monitoring process described above. This review is a second look at LEAs’
               applications, budget revisions, payment requests, final expenditure reports and
               revisions, cash management plans, and audit findings for other Federal grants that
               passed through DESE, using documentation housed in Missouri’s electronic grants
               management system. 17 However, DESE does not plan to review any supporting



17
  Missouri’s electronic Planning and electronic Grants System, known as ePeGS, is a web‐based system
for managing grants including related documentation and reporting requirements.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                         22
              documentation related to expenditures during this process and would not identify
              whether LEAs’ expenditures were used for unallowable purposes.

              LEA Monitoring Could Be Improved
              Because the reimbursement requests, self-assessments and desk reviews, on-site
              reviews, and desk audits do not include protocols for when DESE would review LEAs’
              expenditures, adding such a protocol to the monitoring plan would provide DESE with
              additional assurance that LEAs used GEER grant funds for allowable purposes. In
              addition, requiring LEAs to certify their responses to the self-assessment would add
              assurance that the answers provided were accurate.

              According to 2 C.F.R. section 200.303(a) and (c), a non-Federal entity should 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.

              According to 2 C.F.R. section 200.400(d), the accounting practices of a non-Federal
              entity must be consistent with the cost principles and support the accumulation of costs
              as required by the principles and must provide for adequate documentation to support
              costs charged to the Federal award.

              The U.S. Government Accountability Office’s “Standards for Internal Control in the
              Federal Government” Principle 10 states that management should design appropriate
              types of control activities for the entity’s internal control system. Control activities help
              to reasonably ensure compliance with applicable requirements. Control activities also
              work to identify and address weaknesses in the system of internal controls.

              Although DESE has some controls in place to help ensure subgrantees use GEER grant
              funds for allowable purposes, having protocols to review all or a sample of LEAs’
              supporting documentation related to expenditures charged to the GEER grant during its
              monitoring process and requiring LEAs to certify their responses to the self-assessment
              questionnaire further reduces the risk of GEER grant funds being used for unallowable
              purposes. After we discussed these issues with Missouri at the exit conference, DESE
              revised the on-site review process to include a review of supporting documentation
              related to GEER grant-funded expenditures for the high-risk LEAs. However, because
              only a small number of LEAs are likely to be identified as high-risk and require on-site
              reviews, also reviewing a sample of medium-risk LEAs’ supporting documentation
              related to GEER grant-funded expenditures would increase the likelihood that DESE’s



U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                         23
              monitoring process would identify unallowable expenditures and provide assurances
              that funds were used as intended.

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

                  2.1 develop and implement protocols to sample and review supporting
                      documentation related to expenditures charged to the GEER grant for LEAs
                      identified as medium-risk.

              Missouri Comments
              Missouri agreed with the finding and recommendation and identified corrective actions
              it planned to take to address the recommendation. Missouri stated that it will develop
              and implement protocols to sample and review supporting documentation related to
              expenditures charged to the GEER grant for LEAs identified as medium-risk.

              OIG Response
              Missouri’s proposed corrective actions, if effectively implemented, are responsive to our
              recommendation. Missouri should work with the Department to ensure that the
              recommendation is appropriately and sufficiently resolved and that corrective actions
              are fully implemented.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                    24
               Appendix A. Scope and Methodology
               Our audit covered Missouri’s control activities related to the administration of the GEER
               grant. Specifically, our audit covered Missouri’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 Missouri’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 Missouri’s GEER grant award and
               monitoring processes from March 13, 2020, through October 1, 2021. We conducted
               fieldwork virtually due to the national pandemic from December 7, 2020, through
               October 1, 2021. We performed testing on Missouri’s grant allocations through
               March 15, 2021, applications through July 23, 2021, and expenditures through
               March 10, 2021. We held an exit conference with Missouri officials on June 16, 2021, to
               discuss the results of our audit. 18

               To achieve our audit objectives, we gained an understanding of the CARES Act, the
               Uniform Grant Guidance at 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 and the U.S. Government Accountability Office’s
               “Standards for Internal Control in the Federal Government.” We also reviewed
               requirements for managing Federal funds, including 2 C.F.R. section 200.302, Financial
               Management, and 2 C.F.R. section 200.305, Payment.

               We also performed the following procedures:

                   •   Reviewed the organization charts for the Governor’s Office, DESE, and DHEWD
                       to determine those positions or personnel responsible for awarding,
                       administering, and monitoring the GEER grant.

                   •   Interviewed Missouri officials to obtain the rationale for selecting DESE as the
                       designated State agency to administer the funds and to gain an understanding
                       of the processes used for determining how the GEER grant funds were
                       appropriated, allocated, awarded, and used.

                   •   Reviewed Missouri’s GEER grant Certification and Agreement (application), its
                       required 45-day report submitted to the Department, documentation related to


18
  Although we held the exit conference on June 16, 2021, Missouri provided additional information
after the exit conference which we reviewed and considered through October 1, 2021.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                      25
                      the use of funds, and any communications with the Department to gain an
                      understanding of how Missouri intended for the funds to be used.

                  •   Reviewed DESE’s and DHEWD’s GEER grant awards to LEAs and IHEs and tested
                      a sample of these awards to determine whether DESE and DHEWD followed
                      their award processes (In the Sampling Methodology section of this report, see
                      the LEA Connectivity Initiative Samples, the LEA Transportation Supplement
                      Initiative Samples, and the IHE Initiatives Samples).

                  •   Reviewed and recalculated the allocation spreadsheets for the LEA Connectivity,
                      LEA Transportation Supplement, and IHE initiatives to determine whether the
                      allocations were correct.

                  •   Determined whether the data DESE and DHEWD used in the LEA Connectivity,
                      LEA Transportation Supplement, and IHE allocation spreadsheets were accurate.
                      We tested samples of LEA allocation data for the first two initiatives and a
                      sample of IHE allocation data for the other initiative. (In the Sampling
                      Methodology section of this report, see the LEA Connectivity Initiative Samples,
                      the LEA Transportation Supplement Initiative Samples, and the IHE Initiative
                      Samples).
                  •   Determined whether the data DESE used in the LEA Connectivity and LEA
                      Transportation Supplement allocation spreadsheets were complete. We
                      reviewed a list of LEAs that were allocated funds for the LEA Connectivity
                      Initiative and a list of those that did not receive an allocation and compared it to
                      a list of all of Missouri’s 558 LEAs. We reconciled any differences to ensure all
                      LEAs were accounted for. We also compared the amount of funds allocated to
                      LEAs for the LEA Connectivity Initiative to the amount of funds awarded to DESE
                      for this initiative to ensure that the entire amount was allocated. We performed
                      the same procedures for the LEA Transportation Supplement Initiative.

                  •   Determined whether the data DHEWD used in the IHE Initiative allocation
                      spreadsheet were complete. We reviewed a list of IHEs that were allocated
                      funds for the IHE Initiative and a list of those that did not receive an allocation
                      and compared it to a list of all of Missouri’s 23 public IHEs. We reconciled any
                      differences to ensure all IHEs were accounted for. We also compared the
                      amount of funds allocated to the IHEs for the IHE Initiative to the amount of
                      funds awarded to DHEWD for the IHE initiative to ensure that the entire amount
                      was allocated.

                  •   Obtained and reviewed the status of Missouri’s maintenance of effort
                      agreement.



U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                       26
                   •   Reviewed and evaluated the criteria, policies, procedures, and internal controls
                       Missouri used to determine which LEAs and IHEs were “most significantly
                       impacted by the coronavirus.”

                   •   Reviewed all of Missouri’s GEER grant drawdowns to determine whether
                       Missouri complied with cash management regulations and guidance. We
                       compared the drawdown amounts for all 81 of Missouri’s drawdowns to the
                       amounts included in its expenditure reports. For each drawdown, we subtracted
                       the expenditure amounts from the same date to determine whether Missouri
                       had any periods with excess cash on hand. We also calculated the number of
                       days between Missouri’s receipt of the funds drawn down and the dates that
                       Missouri expended the funds.

                   •   Reviewed and evaluated DESE’s monitoring plan procedures for ensuring that
                       GEER grant funds were used in accordance with the CARES Act and other
                       applicable Federal requirements.

                   •   Reviewed DHEWD’s monitoring procedures and related supporting
                       documentation such as its IHE reimbursement tracking ledger and IHE requests
                       for reimbursement (including invoices, proof of payment, and evidence of the
                       review and approval of the requests) and tested a sample of expenditures to
                       ensure that GEER grant funds were used in accordance with the CARES Act and
                       other applicable Federal requirements. 19 (In the Sampling Methodology section
                       of this report, see the IHE Initiatives Samples.)

               Sampling Methodology
               To determine whether DESE and DHEWD followed their award processes for the LEA
               Connectivity, LEA Transportation Supplement, and IHE initiatives, we selected samples
               of LEAs and IHEs to review. To determine the accuracy of the data that DESE and
               DHEWD used in the LEA Connectivity, LEA Transportation Supplement, and IHE
               allocation spreadsheets, we also selected samples of LEAs and IHEs to review. To
               determine whether DHEWD followed its reimbursement process, which it also used as
               its monitoring mechanism to ensure IHEs use GEER grant funds for allowable purposes,
               we selected a sample of reimbursement payments that DHEWD made to IHEs that were
               allocated GEER grant funds for the IHE Initiative.




19
  We did not review a sample of LEA reimbursements for allowability because DESE’s process for
reimbursement did not include the collection and review of supporting documentation related to LEAs’
expenditures.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                     27
               Regarding the awarding process, not all LEAs that were allocated GEER grant funds
               applied to receive the funds. For the selected samples, we confirmed that the LEA
               received an award notification letter from Missouri, applied, signed Missouri’s required
               assurances, and offered equitable services to nonpublic schools. All LEAs that were
               awarded an allocation were required to go through these steps regardless of whether
               they applied for the GEER grant funds. However, to receive the funds, the LEAs had to
               apply for the funds.

               The sections below describe the sampling in detail.

               LEA Connectivity Initiative Samples
               To determine whether DESE followed its award process for the LEA Connectivity
               Initiative, we selected a sample of 25 (8 percent, rounded up to 25) of the 296 LEAs that
               were awarded an LEA Connectivity allocation. We judgmentally selected 12 LEAs, which
               were those LEAs with the highest allocation amounts (over $200,000) and randomly
               selected 13 LEAs. For each of the 25 LEAs, we confirmed whether DESE followed its
               award processes. In addition, for the 23 LEAs in our sample that had applied for the LEA
               Connectivity funds, we confirmed that the LEA had applied, and for the 2 LEAs in our
               sample that had not yet applied, we confirmed that there was no payment made to the
               LEA through May 5, 2021.

               To determine the accuracy of the data in the LEA Connectivity allocation spreadsheet,
               we selected a random sample of 15 (5 percent) of 296 LEAs that were allocated GEER
               grant funds for the LEA Connectivity Initiative. We compared the student enrollment
               numbers and DDI scores recorded in the allocation spreadsheet to the student
               enrollment data from the Elementary/Secondary Information System 20 and to the DDI
               score spreadsheet DESE used from Purdue University, respectively, for the 15 sampled
               LEAs.

               Table 2 shows the universe, sample sizes, and sampling methodologies related to our
               testing of the LEA Connectivity Initiative.




20
  The Elementary/Secondary Information System is a National Center for Education Statistics web
application that allows users to quickly view public and private school data.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                      28
              Table 2. LEA Universes and Samples for the LEA Connectivity Initiative Testing
               Testing Purpose     Universe     Sample Size                  Methodology

                                                                 Twelve judgmentally selected with
                                                                 allocations over $200,000 each, and
                 Award Process       296        25 (8 percent)
                                                                 13 selected using a simple random
                                                                 sample.


                Accuracy of Data
                  in Allocation      296        15 (5 percent)   Simple random sample.
                  Spreadsheet



              LEA Transportation Supplement Initiative Samples
              To determine whether DESE followed its award process for the LEA Transportation
              Supplement Initiative, we selected a sample of 40 (7 percent) of the 539 LEAs that were
              awarded an LEA Transportation Supplement allocation. We judgmentally selected
              19 LEAs, which were those LEAs with the highest allocation amounts (over $150,000);
              and randomly selected 21 LEAs. For each of the 40 LEAs, we confirmed whether DESE
              followed its award processes. In addition, for the 24 LEAs in our sample that had applied
              for the LEA Transportation Supplement funds, we confirmed that the LEA had applied,
              and for the 16 LEAs in our sample that had not yet applied, we confirmed that there was
              no payment made to the LEA through May 5, 2021.

              To determine the accuracy of the data in the LEA Transportation Supplement allocation
              spreadsheet, we selected a random sample of 27 (5 percent) of 539 LEAs that were
              allocated GEER grant funds for the LEA Transportation Supplement Initiative. We
              compared the prior year transportation payment amounts recorded in the allocation
              spreadsheet for the 27 sampled LEAs to DESE’s prior year transportation funding report.

              Table 3 shows the universe, sample sizes, and sampling methodologies related to our
              testing of the LEA Transportation Supplement Initiative.




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                       29
                   Table 3. LEA Universes and Samples for the LEA Transportation Supplement Testing
                     Testing Purpose      Universe     Sample Size                  Methodology

                                                                        Nineteen judgmentally selected with
                                                                        allocations over $150,000 each, and
                       Award Process         539       40 (7 percent)
                                                                        21 selected using a simple random
                                                                        sample.


                    Accuracy of Data in
                        Allocation           539       27 (5 percent)   Simple random sample.
                       Spreadsheet



                   IHE Initiative Samples
                   To determine whether DHEWD followed its award process for the IHE Initiative, we
                   selected a sample of 5 (22 percent) of 23 IHEs that were allocated GEER grant funds. 21
                   We judgmentally selected three IHEs with allocation amounts over $1.5 million and
                   randomly selected two IHEs. For each of the five IHEs, we confirmed that the IHE
                   received an award notification letter from Missouri, submitted an application, and
                   signed Missouri’s required assurances.

                   To determine whether DHEWD followed its reimbursement process (which it also used
                   as its monitoring mechanism to ensure IHEs use GEER grant funds for allowable
                   purposes), we selected a judgmental sample of 17 (35 percent) of 48 reimbursement
                   payments that DHEWD made to IHEs that were allocated grant funds. 22 We selected the
                   judgmental sample by first analyzing the 48 reimbursement payments to determine how
                   many IHEs had submitted reimbursement requests. We found that most of the funds
                   were disbursed to 15 of the 19 IHEs that had submitted reimbursement requests. From
                   the 15 IHEs, we selected a total of 17 payments. We selected the payment with the
                   largest dollar amount from each of 15 IHEs. 23 In addition, we selected the only
                   2 remaining disbursements over $1 million. For the 17 reimbursement payments, we
                   reviewed the reimbursement form, the supporting documentation (including invoices
                   and proof of payment), and evidence of Missouri’s review and approval.



21
     A five percent sample would have only resulted in the selection of two IHEs so we selected five IHEs.
22
  Missouri reimbursed 19 of 23 IHEs with GEER grant funds; the remaining 4 IHEs had not received
reimbursements at the time of our testing.
23
     The largest dollar amount varied for each IHE, whichranged from $206,458 to $2.16 million.


U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                              30
              To determine the accuracy of the data in the IHE Initiative allocation spreadsheet, we
              selected a random sample of 5 of the 23 IHEs that were allocated GEER grant funds for
              the IHE initiative. We compared the student enrollment and faculty and staff
              employment data recorded in the allocation spreadsheet for the five IHEs, to the
              student enrollment and faculty and staff employment data from the Integrated
              Postsecondary Education Data System (IPEDS).

              We determined the number of IHEs that were allocated funds for the IHE Initiative and
              the number of IHEs that were not and compared the total IHEs allocated and not
              allocated funds to the number of all of Missouri’s IHEs (23) to ensure all IHEs were
              accounted for. We also compared the amount of funds allocated to the IHEs for the IHE
              Initiative to the amount of funds awarded to DHEWD for the IHE initiative to ensure that
              the entire amount was allocated. Table 4 shows the universe, sample sizes, and
              sampling methodologies related to our testing of the IHE Initiative.

              Table 4. Universes and Samples for IHE Initiative Testing
              Testing Purpose        Universe       Sample Size                Methodology

                                                                     Three judgmentally selected with
                                                        5 IHEs       allocations over $1.5 million, and 2
               Award Process          23 IHEs
                                                     (22 percent)    IHEs selected using a simple
                                                                     random sample.



                                                          17         Fifteen judgmentally selected (the
                                         48
                                                   reimbursement     largest payment from each IHE),
             Monitoring Process    reimbursement
                                                      payments       and 2 judgmentally selected
                                      payments
                                                     (35 percent)    payments over $1 million.




             Accuracy of Data in
                                                        5 IHEs
                 Allocation           23 IHEs                        Simple random sample.
                                                     (22 percent)
                Spreadsheet




              Use of Computer-Processed Data
              We relied, in part, on computer-processed data contained in Missouri’s financial
              management system, specifically, IHE reimbursement payments related to the IHE
              Initiative. We used the reimbursement payment data to determine whether DHEWD
              followed its reimbursement process, which it also used as its monitoring mechanism to
              ensure IHEs use GEER grant funds for allowable purposes. To test the reliability of the

U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                                       31
              reimbursement payment data in Missouri’s financial management system, we used the
              same sample of 17 of 48 reimbursement payments that we used to test DHEWD’s
              reimbursement process. For the 17 reimbursement payments, we compared the
              expenditure amounts to supporting documentation. We also obtained a list of all of
              Missouri’s GEER grant expenditures for the IHE Initiative as of May 5, 2021, and
              compared the totals to Missouri’s GEER grant drawdown transactions to ensure that
              there were no additional funds drawn down that were not accounted for. Based on the
              work we performed, we determined that the information was sufficiently reliable for us
              to use in meeting the audit objectives.

              We also relied on computer-processed data obtained from the Department’s G5 system.
              We used the G5 grants management system to identify the amount of GEER grant funds
              Missouri drew down as of April 30, 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.

              We also used computer-processed data from two other Department systems: IPEDS and
              the Elementary/Secondary Information System. We used the IPEDS to confirm IHE
              student enrollment and staff employment data used in Missouri’s IHE Initiative
              allocation spreadsheets. We used the Elementary/Secondary Information System data
              to confirm LEA student enrollment data used in Missouri’s LEA Connectivity and LEA
              Transportation Supplement initiatives. Both systems are administered by the
              Department’s National Center for Education Statistics (NCES), the primary Federal entity
              for collecting and analyzing data related to education. NCES develops statistical
              standards, methodologies, handbooks, and webinars to ensure the data it reports is
              timely, useful, and high-quality. For example, data reported to IPEDS undergoes a
              rigorous process that includes multiple validation reviews and procedures for data
              quality. We considered this to be the best available data for the intended purpose.

              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/A20GA0018                                                                                    32
              Appendix B. Acronyms and Abbreviations
                   C.F.R.       Code of Federal Regulations

                   CARES Act    Coronavirus Aid, Relief, and Economic Security Act

                   DDI          Digital Divide Index

                   Department   U.S. Department of Education

                   DESE         Department of Elementary and Secondary
                                Education

                   DHEWD        Department of Higher Education and Workforce
                                Development

                   ESEA         Elementary and Secondary Education Act

                   ESSER        Elementary And Secondary School Emergency
                                Relief Fund

                   FRL          Free and Reduced Lunch

                   GEER grant   Governor’s Emergency Education Relief Fund

                   IHE          Institution of Higher Education

                   IPEDS        Integrated Postsecondary Education Data System

                   LEA          Local Education Agency

                   Missouri     State of Missouri

                   OQS          Office of Quality Schools

                   SAM II       Statewide Advantage for Missouri

                   SEA          State Educational Agency




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                                                 33
                               Missouri Comments




U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018                                   34
U.S. Department of Education
Office of Inspector General
ED-OIG/A20GA0018               35

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