Review of State Plans for Use of Governor's Emergency Education Relief Funds (ED-OIG/F20DC0028)
Summary
Final Flash Report ED-OIG/F20DC0028, dated December 20, 2021, from the U.S. Department of Education Office of Inspector General to Ian Rosenblum, Acting Assistant Secretary, Office of Elementary and Secondary Education. It reviews the initial 45-day reports and annual reports on the Governor's Emergency Education Relief (GEER) Fund submitted by each of the 50 States, the District of Columbia and Puerto Rico. It reports that 45 States (87 percent) planned to allocate GEER funds to local educational agencies, 39 States (75 percent) to institutions of higher education and 36 States (69 percent) to other education-related entities. It also reports that 38 States (73 percent) specifically identified information technology as a priority for use of funds.
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- Issuer
- U.S. Department of Education, Office of Inspector General
- Document type
- Report
- Date
- 2021-12-20
Cite this document
“Review of State Plans for Use of Governor's Emergency Education Relief Funds (ED-OIG/F20DC0028).”
U.S. Department of Education, Office of Inspector General, dated 2021-12-20. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/review-state-plans-geer-funds/
, SHA-256 54be5a24d01790868af8d24045928a1439d4bb491a12f6fa33ad3ee8c7ac77f3.Full text
U.S. Department of Education
Office of Inspector General
Review of State Plans for Use of
Governor’s Emergency Education
Relief Funds
December 20, 2021
ED-OIG/F20DC0028
FLASH REPORT
NOTICE
In accordance with Freedom of Information Act (Title 5, United States Code,
Section 552), reports that the Office of Inspector General issues are available to
members of the press and general public to the extent information they contain is not
subject to exemptions in the Act.
UNITED STATES DEPARTMENT OF EDUCATION
OFFICE OF INSPECTOR GENERAL
Audit Services
December 20, 2021
TO: Ian Rosenblum
Acting Assistant Secretary
Office of Elementary and Secondary Education
FROM: Bryon S. Gordon /s/
Assistant Inspector General for Audit
SUBJECT: Final Flash Report, “Review of State Plans for Use of Governor’s Emergency Education
Relief Funds,” Control Number ED-OIG/F20DC0028
Attached is the subject final flash report that consolidates the results of our review of State plans for use
of Governor’s Emergency Education Relief Funds. We have provided an electronic copy to your audit
liaison officer. We received your comments responding to our draft report.
We appreciate your cooperation during this review. If you have any questions, please contact Michele
Weaver-Dugan at (202) 245-6941 or Michele.Weaver-Dugan@ed.gov.
Attachment
400 MARYLAND AVENUE, S.W., WASHINGTON, DC 20202-1510
Promoting the efficiency, effectiveness, and integrity of the Department’s programs and operations.
Purpose
The purpose of this report is to share with the U.S. Department of Education
(Department) observations made by the Office of Inspector General (OIG) regarding
States’ Governor’s Emergency Education Relief (GEER) Fund initial 45-day reports and
annual reports.
What We Did
The objectives of our review were to review States’ initial 45-day GEER Fund reports to
determine how States plan to allocate funds to entities within the three authorized
categories: local educational agencies (LEA), institutions of higher education (IHE), and
education-related entities, and the criteria upon which these decisions were based; and
review GEER Fund annual reports to identify changes to and progress made from the
initial plans in the 45-day reports.
To accomplish our objective, we reviewed plans submitted by each of the 50 States, as
well as the District of Columbia and Puerto Rico, to determine how they planned to
allocate funds to entities within the three authorized categories and the criteria upon
which these decisions were based. We also reviewed the annual reports submitted by
each State 1 to determine if there were any notable changes from what was reported in
their initial plans and to compile reported expenditure data.
Introduction
Background
The Coronavirus Aid, Relief, and Economic Security (CARES) Act 2 was signed into law on
March 27, 2020. It authorized more than $2 trillion to battle Coronavirus Disease 2019
(coronavirus) and its economic effects. The CARES Act provided approximately
$31 billion for an Education Stabilization Fund to prevent, prepare for, and respond to
coronavirus, domestically or internationally. The Education Stabilization Fund is
composed of three primary emergency relief funds: a GEER Fund, an Elementary and
Secondary School Emergency Relief Fund, and a Higher Education Emergency Relief
Fund.
1
Throughout the remainder of this report, “State” is inclusive of the 50 States, the District of Columbia,
and Puerto Rico.
2
Public Law No. 116-136.
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Governor’s Emergency Education Relief Fund
Congress set aside approximately $3 billion for the GEER Fund. The Department
awarded these grants to States based on a formula stipulated in the legislation:
60 percent awarded based on the State’s relative population of individuals aged
5 through 24, and 40 percent awarded based on the State’s relative number of children
counted under section 1124(c) of the Elementary and Secondary Education Act of 1965.
According to the Department’s GEER Fund Frequently Asked Questions, States may
provide funds to entities within three authorized categories: LEAs, IHEs, and education-
related entities. The Department defines an education-related entity as a governmental,
nonprofit, or for-profit entity within the State that provides services supporting
preschool, elementary, secondary, or higher education. Examples of education-related
entities identified by the Department include
• State agencies that oversee or directly provide early childhood education
services;
• public agencies or private entities that coordinate or directly provide early
intervention services under Part C of the Individuals with Disabilities Education
Act;
• State agencies that oversee or provide vocational rehabilitative services;
• State mental health agencies;
• State Higher Education Boards;
• education-related non-profit organizations;
• non-public elementary, secondary, and postsecondary schools;
• for-profit elementary, secondary, and postsecondary schools;
• charter management organizations;
• non-profit and for-profit child-care centers;
• public libraries;
• community centers; and
• State or local agencies coordinating food services for students and their families.
The funds may be used to provide emergency support through subgrants to LEAs and
IHEs that have been “most significantly impacted by coronavirus” to support their ability
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to continue providing educational services to their students and to support the ongoing
functionality of these entities. 3 In addition, States may use funds to provide support
through subgrants or contracts to any other LEA, IHE, 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 the Elementary and
Secondary Education Act or the Higher Education Act, the provision of child-care and
early childhood education, social and emotional support, and the protection of
education-related jobs. The Department also encouraged States, LEAs, and IHEs to
invest GEER funds in technology infrastructure and professional development that will
improve capacity to provide high-quality, accessible distance education or remote
learning. Funds that are not awarded within 1 year of receipt must be returned to the
Department for reallocation to the remaining States.
The Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSA),
enacted on December 27, 2020, provided an additional $4 billion for the GEER Fund. The
CRRSA provides that $1.3 billion of the funds be used to supplement the funds awarded
to each State with an approved GEER application under the CARES Act. These funds are
referred to as GEER II funds. The remainder of the funds are reserved for an Emergency
Assistance to Non-Public Schools program. The American Rescue Plan Act of 2021 did
not allocate additional funds to the GEER Fund.
Reporting Requirements
Each Governor that receives GEER funds must meet the reporting requirements of
section 15011 of the CARES Act. Governors satisfy these requirements through the
following:
• monthly reporting in accordance with the Federal Funding and Transparency Act
(FFATA) requirements, which includes reporting subgrantee data on awards
equal to or greater than $30,000 via the FFATA Sub-Award Reporting System
(FSRS), and
• initial reports, annual reports, and other reporting the Secretary may require.
Under the CRRSA Act, each Governor that receives GEER II funds must meet the CARES
Act reporting requirements that apply to GEER funds.
3
The Department’s guidance states that if the recipients are LEAs, the State educational agency must
determine that the LEAs have been the “most significantly impacted by coronavirus” to be eligible for a
GEER Fund emergency grant. Similarly, if IHEs are the recipients, the Governor must determine them to
be the “most significantly impacted by coronavirus.”
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Initial Reports
States applied for their allocation of GEER funds provided under the CARES Act by
submitting to the Department an executed Certification and Agreement, which included
programmatic, fiscal, and reporting assurances. This included an assurance that within
45 days of receiving GEER funds the State would submit to the Department an initial
report detailing the State’s process for awarding the funds to LEAs, IHEs, or other
education-related entities, including the criteria for determining those entities that are
“most significantly impacted by coronavirus” or “essential for carrying out emergency
educational services.” In a clarification document sent to States in June 2020, the
Department specifically requested that States provide
a. a timeline for awarding funds to LEAs, IHEs, or other education-related entities;
b. the criteria, process and deliberations the State used to determine which LEAs,
IHEs, or other education-related agencies are “most significantly impacted by
coronavirus” or “essential for carrying out emergency educational service”;
c. the funding mechanisms (e.g., grants, contracts) the State will use to provide
funds to LEAs, IHEs, or other education-related entities; and
d. any specific funding conditions or requirements the State will place on awards
to ensure the funds are spent for specific purposes or activities.
The Department conducted an initial review of each State’s report for completeness,
and States that provided insufficient information were given an opportunity to provide
additional information to the Department.
Annual Reports
The Department’s GEER Fund Recipient Reporting Data Collection Form (data collection
form), dated December 2020, 4 requires States to provide an annual report that includes
information related to the types of entities that were awarded funds, including a listing
of LEAs, IHEs, and other education-related entities and their expended funds. The data
collection form requested that States acknowledge and identify any changes to the
State’s LEA and IHE 5 GEER funding conditions or requirements since the State’s initial
45-day report to the Department. The first annual report, due February 1, 2021, had an
applicable reporting period of March 13, 2020, to September 30, 2020.
4
See the following link for a copy of the data collection form: Recipient Reporting Data Collection Form.
5
Other education-related entities were not included.
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What We Found
Initial 45-Day Reports
We reviewed the initial 45-day reports submitted by each of the States to determine
how they planned to allocate funds to entities within the three authorized categories
and the criteria upon which these decisions were based. 6
Allocation of Funding
We found that within the three authorized entity categories, 45 States (87 percent)
planned to allocate GEER funds to LEAs, 39 States (75 percent) planned to allocate funds
to IHEs, and 36 States (69 percent) planned to allocate funds to other education-related
entities. See Figure 1. 7
Figure 1. Number of States Allocating Funds by Entity Category
50
45
45
39
40 36
35
30
25
20
15
10
5
0
LEA IHE Other Education-Related
Entities
Further, we found that 41 States (79 percent) planned to allocate GEER funds among
more than one entity category. Of the remaining 11 States, 5 States (10 percent)
planned to allocate funds to only LEAs, 3 States (6 percent) to only IHEs, and 2 States
(4 percent) to only other education-related entities. One State did not include
6
The 45-day reports include information pertaining to GEER funding provided by only the CARES Act.
7
The 45-day reports did not include enough detail to determine the actual amount of funding to be
allocated to each entity category.
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information that specified its intended allocation of funds by entity category. See
Figure 2.
Figure 2. Number and Percentage of States Allocating GEER Funds to Multiple and
Individual Entity Categories
2%
4%
6% Multiple Entity Categories
(41 States)
9% Only LEAs (5 States)
Only IHEs (3 States)
Only Other-Education
Related Entities (2 States)
79%
Unknown (1 State)
Regarding other education-related entities, we found that States planned to allocate
funding to entities in both the private and public sector. These entities included daycare
facilities, charter and private schools, tribal schools, career and technical centers, home
school organizations, telecommunications and public broadcasting entities, career
centers, scholarship funding organizations, State education agencies, and other State
agencies related to information technology and behavioral health. The entities provided
programs and services related to early childhood education and literacy, childcare,
special needs, math and science programs, higher education, mental health programs,
teacher recruitment, blended and adaptive learning, digital learning strategies, teacher
retention, and workforce training. The identified entities and services conformed to the
Department’s guidance related to other education-related entities.
Commonly Noted Usages of Funding
We found that 38 States (73 percent) specifically identified information technology as a
priority for use of funds. While some States were more detailed than others in their
descriptions for how they intended to use GEER funds for information technology, we
noted the following observations related to information technology expenditures:
• Twenty States planned on using GEER funds to increase online capacity learning
and remote learning.
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• Nineteen States planned to expand broadband access and provide mobile hot
spots in communities, including improving connectivity and providing devices to
teachers and students.
• Two States planned to provide funding to internet service providers.
• One State planned to equip school buses with Wi-Fi capabilities.
• One State planned to improve classroom technology at public institutions of
higher learning to help accommodate remote learning.
We also noted that 19 States (37 percent) specifically identified professional
development related to online, digital, or distance education as a funding priority.
Criteria for Determining Entities Most Significantly Impacted
by Coronavirus or Essential for Carrying out Emergency
Educational Service
We found that 46 States (88 percent) identified criteria and processes used to
determine which LEAs, IHEs, or other education-related entities were “most significantly
impacted by coronavirus,” or “essential for carrying out emergency educational
service.” These States identified entity categories or priority areas within authorized
entity categories that were “most significantly impacted” or essential, and included
data, research, or other explanations related to how they made these determinations.
For example,
• one State noted that its Governor convened the leaders of three primary State
agencies and divisions to request their assistance in shaping a plan for the use of
GEER funds. In developing this plan, the agencies and divisions reached out to
school districts, education service districts, public and private universities, early
learning providers, childcare facilities, non-profit service providers, tribal
government, private business industry representatives, and other
community--based organizations. As a result, the State noted that the pandemic
has created a greater disparate impact on low-income, and historically
underserved and economically disadvantaged children, students, and families,
which has placed these populations at increased risk of poverty, homelessness,
and food insecurity and has significantly impacted opportunities for students to
meet their educational goals. To implement strategies that address each risk
area, the State indicated there would be a focus to prioritize populations that
are at greater risk, and provided funding for specific programs within LEAs, IHEs,
early childhood program providers, relief nursery program providers, and tribal
government partners that focus on those populations.
• another State created a GEER advisory group of State leaders of higher
education, the public school system, private schools, and charter schools to
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assess impact, identify priority needs, and seek solutions. Based on the advisory
group’s identified priorities, the State developed strategies for use of GEER
funds and criteria for determining the “most significantly impacted,” including
criteria on the lack of access to and availability of devices and connectivity for
the most vulnerable students and families for remote instruction. The State
determined that the impact of the coronavirus will be a dynamic and ongoing
process, and cited results from a State Department of Education survey on the
significant impact of secondary students and schools with high levels of poverty.
Conversely, we found that six States (12 percent) did not identify criteria and processes
used to determine which entities were “most significantly impacted by coronavirus” or
“essential for carrying out emergency educational service.” We noted that some of
these States simply provided which entities would receive funds but did not state how
they determined which entities were “most significantly impacted” or essential. Others
identified priority areas but did not explain how those were determined.
Annual Reports
We found that 51 States submitted their GEER fund annual report. 8 The Department
stated that all reports were submitted by the February 1 due date; however,
Department reviews of the reports identified areas that needed further explanation or
indicated potential data quality issues. The Department shared its questions and
possible concerns regarding data quality with applicable grantees and allowed a report
revision period through March 31, 2021. After the revision period, the Department
identified three grantees that still had data issues and provided targeted technical
assistance. A subsequent report revision period was established through July 2021. The
Department indicated that all remaining data issues were resolved and all State reports
are posted on the Department’s Education Stabilization Fund portal (portal) website.
We noted that 38 States (75 percent) resubmitted reports during the report revision
periods.
Changes from Initial 45-Day Reports
We found that the posted reports did not include information related to changes made
since the initial 45-day reports were submitted to the Department. The data collection
form requires States to include information specific to any changes made to funding
conditions or requirements that had been placed to ensure that LEAs and IHEs spent the
funds on specified purposes or activities. The Department stated that only three States
8
One report was not required to be submitted since funds were not received until March 2021.
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had reported any changes in this area and that this factored into its decision on whether
to publish this particular data point.
Entity Categories
The data collection form requested that States identify the types of entities within the
State that were awarded GEER funds. We compared entity categories listed on the
annual reports with those that were noted in the initial 45-day reports and noted the
following:
• Sixteen States identified the same entity categories in their annual reports as in
their initial 45-day reports.
• Seven States identified at least one category in their annual reports that was not
included in their initial 45-day reports.
• Fourteen States identified fewer entity categories in their annual reports than
were included in their initial 45-day reports; however, these differences may be
attributed to the States not yet awarding funds to entities in all initially reported
entity categories by September 30, 2020. For example, a State may have
identified LEAs and IHEs in its 45-day report, but checked only the LEA category
in its annual report because it had not yet awarded funds to IHEs.
• Fourteen States did not identify any entity categories in their annual reports.
While 12 of the 14 reports indicated that no funds had been expended yet and
therefore no entity categories would be reported, 2 of the reports did indicate
that funds had been expended but did not provide any subgrantee data that
could be used to compare to the initial 45-day reports. 9
When asked whether there were any concerns with States identifying awards to entity
categories that were not included in their initial 45-day reports, the Department stated
that the 45-day report was intended to be a snapshot in time, and therefore the
Department did not ask States to resubmit these reports if their plans had changed.
9
As noted above, one State did not include information in its 45-day report that specified its intended
allocation of funds by entity category. In its annual report, the State is one of the 14 that did not identify
any entity categories.
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GEER Fund Expenditures 10
As of September 30, 2020, the annual reports indicated that States expended
$535 million (18 percent) of the $3 billion in GEER funds awarded under the CARES
Act. 11 We found that 31 States reported no expenditures; 5 States reported that all of
their GEER funds had been expended. See Figure 3 for the percentage of expenditures
to award amounts noted in the annual reports.
Figure 3. Annual Report Percentage of Expenditures
5 States
3 States
0% Expenditures
Expenditures Greater than
0% and Less than 25%
12 States Expenditures Greater than
31 States
25% and Less than 100%
100% Expenditures
However, we found discrepancies in data provided in the annual reports. Of the
31 States that reported no funds expended on the top part of the report, 15 listed
expenditures for individual entities—LEAs, IHEs, or other education-related entities—on
the bottom part of the report. Further, for the five States that reported expending
100 percent of their GEER fund awards as of September 30, 2020, data from the
Department’s portal, which reflects data reported by the Department to
USASpending.gov, indicated that the funds had not all been spent by each State as of
10
The annual reports include a line item noting the total amount of the grant expended, which actually
represents the amount of the GEER award drawn down by the State.
11
The amounts reported in the annual reports pertain to GEER funding provided by only the CARES Act.
Annual reports do not include funds from the CRRSA as it was enacted after the reporting period ended.
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April 30, 2021. 12 See Figure 4 for a listing of States that reported expending all of their
GEER funds compared to the data on the portal.
Figure 4. Annual Report Expenditures vs. Portal Expenditures
100
100 100 100 100 100
90 94
33
80
78
70
60 67
50
40
30
28
20
10
10
0
State #1 State #2 State #3 State #4 State #5
% of Grant Expended - Annual Report - September 30, 2020
% of Grant Expended - Portal as of April 30, 2021
The Department noted that the discrepancies related to the five States noted above
were the result of the States returning their unexpended GEER funds in response to the
Department’s targeted monitoring, which occurred after the annual report end date of
September 30, 2020. According to the monitoring report we reviewed for one of these
States, the State drew down its total award amount before it was ready to spend it
(award to subgrantees), in violation of cash management requirements. The
Department subsequently required the State to return unexpended funds until it was
ready to make awards.
We noted that the reasons for the discrepancies noted on the reports associated with
the other 15 States could be attributed to data coming from different systems and
related timing differences associated with the data. Total expenditure data included on
the top part of the annual reports comes from information in the Department’s G5
(grants management) system. These amounts would reflect total drawdowns made by
the States as of the reporting period end date. Data included on the bottom of the
States’ annual reports comes from subaward data reported directly by the States to the
FFATA Sub-Award Reporting System and related expenditure data from the subgrantees
12
This was the most current data available on the Department’s portal at the time of our analysis
(July 2021).
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as of the reporting period end date. The Department agreed that the timing of the
drawdown of funds from the Department does not align perfectly with the timing of
expenditures at the subaward level, noting that States typically draw down funds to
reimburse subgrantees after the subgrantees have expended awarded funds. It added
that the absence of drawdowns does not necessarily equate to an absence of
expenditures.
Office of Elementary and Secondary Education Comments
We provided a draft of this report to the Office of Elementary and Secondary Education
for comment. In its response, the Office of Elementary and Secondary Education offered
a few technical comments reflecting suggested clarifications. The full text of the Office
of Elementary and Secondary Education’s comments is provided at the end of the
report.
OIG Response
We considered and addressed, as appropriate, the technical comments provided by the
Office of Elementary and Secondary Education. We did not make any substantive
changes to the report.
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Appendix A. Scope and Methodology
To answer our objective, we reviewed the laws, criteria, and guidance related to GEER
Fund reporting requirements. We conducted discussions with Office of Elementary and
Secondary Education officials and staff to gain an understanding of reporting
requirements and the Department’s process for reviewing State reports. We also
reviewed prior OIG, Government Accountability Office, and other Federal agency
reports related to our objective.
45-Day Reports
We reviewed 45-day reports submitted by the 50 States, the District of Columbia, and
Puerto Rico, to determine how States planned to allocate funds to entities within the
three authorized categories and the criteria upon which these decisions were based.
Our review included a determination of whether the State reports included the process
used to determine the entities and areas “most significantly impacted by the
coronavirus” or considered most essential, as well as the criteria used to determine the
“most significantly impacted” or essential entities and areas. In addition, we compiled
information related to the types of other education-related entities and services to
which the States planned to allocate funds, and any common usages of funds noted
across States.
Annual Reports
To identify changes to and progress made from States’ initial plans in the 45-day
reports, we reviewed the annual reports from each State for the period ending
September 30, 2020, that were submitted and posted on the Department’s portal. 13 Our
review included a determination of whether the annual reports contained the
information requested by the Department. We also compiled information reported by
each State related to the total grant amount expended and compared that to subaward
data provided on the reports as well as to total expenditure data reflected on the
Department’s portal. In addition, we compared categories of entities that States
reported awarding funds to with those that were noted in the initial 45-day reports and
identified any discrepancies.
Use of Computer-Processed Data
Use of computer-processed data was limited to identifying GEER Fund obligation and
drawdown amounts from the Department’s Education Stabilization portal for
comparison with information reported by States in their 45-day and annual reports. We
13
One report was not required to be submitted since funds were not received until March 2021.
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did not assess the reliability of the computer-processed data. We used this data for
informational purposes only.
Compliance with Standards
We prepared this flash report in alignment with OIG’s quality control standards and the
Council of Inspectors General for Integrity and Efficiency’s “Quality Standards for
Federal Offices of Inspector General,” which require that we conduct our work with
integrity, objectivity, and independence. We believe that the information obtained
provides a reasonable basis for the conclusions contained in this report.
We performed our work for this review from March 2021 through August 2021.
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Appendix B. Acronyms and Abbreviations
CARES Act Coronavirus Aid, Relief, and Economic Security Act
coronavirus Coronavirus Disease 2019
CRRSA Coronavirus Response and Relief Supplemental
Appropriations Act, 2021
data collection form The Department’s Governor’s Emergency Education
Relief Fund Recipient Reporting Data Collection Form
Department U.S. Department of Education
GEER Governor’s Emergency Education Relief
FFATA Federal Funding Accountability and Transparency Act
IHE Institution of Higher Education
LEA Local Educational Agency
OIG Office of Inspector General
U.S. Department of Education
Office of Inspector General
ED-OIG/F20DC0028 15
Office of Elementary and Secondary Education
Comments
U.S. Department of Education
Office of Inspector General
ED-OIG/F20DC0028 16
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