Southeast Polk Community School District's Use of Elementary and Secondary School Emergency Relief Grant Funds (ED-OIG/F24CA0173)
Summary
Flash Report ED-OIG/F24CA0173 of the U.S. Department of Education Office of Inspector General, dated September 24, 2024, addressed to McKenzie Snow, Director of the Iowa Department of Education, on the Southeast Polk Community School District's use of Elementary and Secondary School Emergency Relief (ESSER) grant funds. It reports that all 20 expenditures reviewed were allowable, but that for one expenditure of $62,000 for school bus air conditioners Southeast Polk did not award or maintain documentation supporting a contract, which did not comply with 2 C.F.R. sections 200.318 or 200.320. It makes one recommendation, that officials receive sufficient training on Federal grant rules. Iowa did not state whether it agreed or disagreed, and Southeast Polk believed all expenditures met applicable requirements.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
- Issuer
- U.S. Department of Education, Office of Inspector General
- Document type
- Report
- Date
- 2024-09-24
Cite this document
“Southeast Polk Community School District's Use of Elementary and Secondary School Emergency Relief Grant Funds (ED-OIG/F24CA0173).”
U.S. Department of Education, Office of Inspector General, dated 2024-09-24. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/southeast-polk-community-school-district-esser/
, SHA-256 8d01a1cfe4ebb33de594d1727dcd72489de084e1c69b844c7f3fc5442ea951e5.Full text
U.S. Department of Education
Office of Inspector General
Southeast Polk Community
School District’s Use of
Elementary and Secondary
School Emergency Relief Grant
Funds
September 24, 2024
ED-OIG/F24CA0173
FLASH REPORT
NOTICE
Statements that managerial practices need improvements, as well as other conclusions
and recommendations in this report, represent the opinions of the Office of Inspector
General. The appropriate Department of Education officials will determine what
corrective actions should be taken.
In accordance with Freedom of Information Act (Title 5, United States Code, Section
552), reports that the Office of Inspector General issues are available to members of the
press and general public to the extent information they contain is not subject to
exemptions in the Act.
UNITED STATES DEPARTMENT OF EDUCATION
OFFICE OF INSPECTOR GENERAL
Audit Services
September 24, 2024
McKenzie Snow
Director
Iowa Department of Education
400 E 14th St
Des Moines, IA 50319
Dear Director Snow:
Enclosed is our final report, “Southeast Polk Community School District’s Use of Elementary and
Secondary School Emergency Relief Grant Funds,” Control Number ED-OIG/F24CA0173. This report
incorporates the comments you provided in response to the draft report. The U.S. Department of
Education’s policy is to expedite audit resolution by timely acting on findings and recommendations.
Therefore, if you have any additional comments or information that you believe may have a bearing on
the resolution of this flash review, you should send them directly to the following Department of
Education official, who will consider them before taking final Departmental action on this review:
Adam Schott
Delegated the Authority to Perform the Functions and Duties of the Assistant Secretary
Office of Elementary and Secondary Education
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202
We appreciate your cooperation during this review. If you have any questions, please contact me at
(916) 213-7630 or Ben.Sanders@ed.gov.
Sincerely,
/s/
Ben C. Sanders
Regional Inspector General for Audit
Enclosure
400 MARYLAND AVENUE, S.W., WASHINGTON, DC 20202-1510
Promoting the efficiency, effectiveness, and integrity of the Department’s programs and operations.
U.S. Department of Education, Office of Inspector General
Results in Brief
Southeast Polk Community School District’s Use of Elementary and
Secondary School Emergency Relief Grant Funds
Why the OIG Performed What Did the OIG Find?
This Work We determined that all 20 expenditures (5 personnel and 15 non-personnel) that we
Congress passed three coronavirus reviewed were allowable. Allowable activities generally include those authorized by the
relief acts within a 1-year period that Elementary and Secondary Education Act, Individuals with Disabilities Education Act, Adult
provided more than $275 billion for Education and Family Literacy Act, Carl D. Perkins Career and Technical Education Act of
an Education Stabilization Fund to 2006, and subtitle B of title VII of the McKinney-Vento Homeless Assistance Act. It also
prevent, prepare for, and respond to includes activities listed in section A-3 of the U.S. Department of Education’s Frequently
the coronavirus, which the President Asked Questions document for the ESSER and Governor’s Emergency Education Relief
declared as a national emergency in Programs.
March 2020. This included $189.5
However, for one expenditure totaling $62,000 for school bus air conditioners, Southeast
billion for Elementary and Secondary
Polk did not award or maintain documentation supporting its awarding of a contract to
School Emergency Relief (ESSER),
the selected vendor, which did not comply with 2 Code of Federal Regulations sections
funds intended to provide vital
200.318 or 200.320.
support to States, local educational
agencies, and schools to address the What Is The Impact?
impact of the coronavirus. Support, Without a contract stipulating the terms and conditions of the award for the school bus
in part, includes activities designed air conditioners, Southeast Polk might not be able to adequately monitor vendor
to help students and educators performance or ensure that it receives what it paid for in terms of cost, quality, and
safely return to and sustain in- timeliness of the product.
person instruction, and that address
the educational inequities
What Are the Next Steps?
exacerbated by the coronavirus We made one recommendation to address the procurement issue that we identified to
pandemic and students’ social, ensure ESSER funds are used, documented, and managed in accordance with applicable
emotional, mental health, and requirements.
academic needs.
The Iowa Department of Education (Iowa) did not state whether it agreed or disagreed
Ensuring that ESSER funds are used with our recommendations, but requested that we perform an additional review of the
for allowable purposes is critical to report after considering comments from Southeast Polk. Southeast Polk believed that all
help address the needs of students
expenditures that we reviewed met applicable ESSER and procurement requirements, and
and educators. The Southeast Polk
it provided additional context that included information regarding the funding source at
Community School District
the time of purchase and subsequent reclassification of costs, its use of vendors, and the
(Southeast Polk) was allocated
circumstances surrounding the coronavirus pandemic intended to support that belief.
approximately $6 million in ESSER
funds to support 11 schools serving Based on Southeast Polk’s clarification and further analysis of available information, we
about 7,400 students. removed part of the finding and two recommendations from the report. We summarize
Iowa’s and Southeast Polk’s comments and provide our response at the end of the
We performed this review to
finding. We also provide the full text of Iowa’s and Southeast Polk’s comments at the end
determine whether Southeast Polk
of the report (see Iowa Department of Education's Comments).
expended ESSER grant funds for
allowable purposes in accordance
with applicable requirements.
Flash Report ED-OIG/F24CA0173
Purpose
The objective of our flash review was to determine whether the Southeast Polk
Community School District (Southeast Polk) expended Elementary and Secondary School
Emergency Relief (ESSER) 1 grant funds for allowable purposes in accordance with
applicable requirements. This flash review report presents the results of our review.
Southeast Polk Community School District
The Southeast Polk Community School District in Iowa is a local educational agency
(LEA) in a rural, fringe setting with 11 schools serving about 7,400 students. Southeast
Polk was allocated approximately $6 million in ESSER funds, and as of August 15, 2023, it
had spent about $4.8 million (80 percent) of its $6 million ESSER allocation to address
the impacts of the coronavirus pandemic. In its approved American Rescue Plan Act
(ARP) ESSER plan, Southeast Polk noted that it planned to use its ARP ESSER funds for
evidence-based accelerated learning interventions in literacy, mathematics, and social-
emotional-behavioral health (including mental health); cleaning supplies for LEA
facilities; repairs and improvements in school facilities to reduce the risk of virus
transmission and exposure to environmental health hazards; and summer learning and
supplemental after-school programs activities.
What We Did
We selected and reviewed 20 ESSER expenditures (3 percent) from a total population of
591 ESSER expenditures for the period July 1, 2022, through June 30, 2023 (review
period). We used a judgmental, risk-based process to select the 20 expenditures
(15 non-personnel and 5 personnel), which represented $345,583 (44 percent) of the
$790,066 in total ESSER expenditures during our review period.
We reviewed each expenditure to determine whether it was (1) connected to the
coronavirus pandemic (intended to prevent, prepare for or respond to the coronavirus
pandemic, including its impact on the social, emotional, mental health, and academic
needs of students); (2) an authorized use of ESSER funds under applicable law and
1
ESSER is one of multiple emergency relief funds comprising the Education Stabilization Fund, which
was first authorized and funded under the Coronavirus Aid, Relief, and Economic Security Act (March 27,
2020), and for which Congress later provided additional funding under the Coronavirus Response and
Relief Supplemental Appropriations Act (December 27, 2020) and the American Rescue Plan (March 11,
2021). Under ESSER, the U.S. Department of Education awarded grants to State educational agencies for
the purpose of providing local educational agencies with emergency relief funds to address the impacts
that the coronavirus pandemic had on elementary and secondary schools and their students.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0173 1
regulations; and (3) reasonable and necessary and otherwise permissible under the
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards (Uniform Guidance, 2 Code of Federal Regulations (C.F.R.) part 200. We
also performed additional work, as needed, to determine whether Southeast Polk
complied with key Federal procurement requirements, specifically those covered under
2 C.F.R. sections 200.320 (methods of procurement to be followed), 200.324 (contract
cost and price), and 200.327 (contract provisions), when procuring the goods or services
associated with each non-personnel expenditure. We interviewed Southeast Polk
officials to gain a basic understanding of how they used ESSER funds, and their
processes for approving and monitoring ESSER expenditures.
An LEA can use ESSER funds for any activity deemed allowable under section 18003(d) of
the Coronavirus Aid, Relief, and Economic Security Act (P.L. 116-136); section 313(d) of
the Coronavirus Response and Relief Supplemental Appropriations Act (P.L. 116-260);
and section 2001(e) of ARP (P.L. 117-2). These activities generally include any activity
authorized by the Elementary and Secondary Education Act, Individuals with Disabilities
Education Act, Adult Education and Family Literacy Act, Carl D. Perkins Career and
Technical Education Act of 2006, and subtitle B of title VII of the McKinney-Vento
Homeless Assistance Act; as well as those listed in section A-3 of the U.S. Department of
Education’s Frequently Asked Questions document for the ESSER and Governor’s
Emergency Education Relief Programs (May 2021, updated on December 7, 2022).
What We Found
We determined that all 20 (100 percent) expenditures that we reviewed were allowable.
These expenditures were generally for counselor salaries, cleaning supplies, textbooks,
and air conditioning equipment. They were connected to the coronavirus pandemic and
authorized uses of ESSER funds under applicable law and regulation. However, we found
that Southeast Polk did not comply with the procurement process or documentation
requirements at 2 C.F.R. sections 200.318 or 200.320 when procuring the goods
associated with 1 (7 percent) of the 15 non-personnel expenditures, totaling $62,000
(36 percent) of the $173,527 in non-personnel expenditures.
Procurement Issue—No Contract Awarded or Maintained
For one expenditure totaling $62,000 for school bus air conditioners, Southeast Polk
either did not award or maintain documentation to support its awarding of a contract to
the vendor. Formal procurement methods, which include publicly soliciting prices from
prospective vendors, are required for purchases over $250,000. When using formal
procurement, a non-Federal entity must award a contract to the responsible offeror
(2 C.F.R. section 200.320(b)(2)(iii)). Additionally, the non-Federal entity must maintain
records sufficient to detail the history of the procurement, including but not limited to
U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0173 2
records documenting the rationale for the procurement method used, vendor selection
or rejection, and basis for the contract price (2 C.F.R. section 200.318(i)). This
expenditure was part of an $834,000 purchase for school buses and related items;
therefore, a formal procurement process was required and a contract should have been
awarded to the selected vendor to comply with 2 C.F.R. section 200.320(b)(2)(iii).
Based on our review of LEA board meeting minutes showing summary-level bid
information from three vendors 2 and pre-approval from the Iowa Department of
Education (Iowa) for the purchase of buses and related items, we concluded that
Southeast Polk used a formal procurement process for this expenditure as required by
applicable Uniform Guidance general procurement standards. Southeast Polk’s
Executive Director of Business Services told us that once Southeast Polk selected and its
board approved the vendor, the specification sheet that the vendor was required to
submit as part of its bid package would serve as the agreement between Southeast Polk
and the vendor. We requested the specification sheet that was signed by the LEA and
selected vendor. In response, the executive director told us that he could not locate the
bid documentation (which would have included the specification sheet) that the
selected vendor submitted to Southeast Polk.
Without this information, we concluded that Southeast Polk either did not award a
contract to the vendor contrary to 2 C.F.R. section 200.320(b)(2)(iii), or failed to
maintain the contract in its procurement files contrary to 2 C.F.R. section 200.318(i).
Further, without a contract stipulating the terms and conditions of the award for the
school bus air conditioners, Southeast Polk might not be able to adequately monitor
vendor performance or ensure that it receives what it paid for in terms of cost, quality,
and timeliness of the product. Per section 10.03 of the U.S. Government Accountability
Office’s Standards for Internal Control in the Federal Government (September 2014),
documents and records should be completely and accurately recorded, properly
managed and maintained, and management should clearly document all transactions
and other significant events in a manner that allows the documentation to be readily
available for examination.
What We Recommend
We recommend that the Assistant Secretary for the Office of Elementary and Secondary
Education require Iowa to require Southeast Polk to ensure that LEA officials responsible
for making or reviewing and approving purchases receive sufficient training on Federal
2
In the minutes for a November 2021 LEA board meeting, there was information identifying the names
of the three vendors that submitted proposals, the vendors’ bid amounts, and which vendor was
selected and approved by the board.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0173 3
rules and regulations related to grant administration and management, particularly
those addressing procurement process and documentation requirements.
Iowa’s Comments
Iowa did not state whether it agreed or disagreed with our recommendations, but
requested that we perform an additional review of the report after considering the
comments from Southeast Polk. Southeast Polk believed that all expenditures that we
reviewed met applicable ESSER requirements and followed the LEA’s procurement
policies and procedures. Southeast Polk stated that it understood why we identified
issues with certain expenditures, but it did not agree or fully agree with the practicality
of the findings or the conclusions reached.
Our draft report identified two expenditures totaling $53,733 for cleaning supplies that
appeared to be unsupported. Southeast Polk noted that the expenditures represented
reclassified costs that were initially funded with general fund dollars but ultimately
funded with ESSER dollars after reclassification. The LEA added that the two ESSER-
funded expenditures were comingled in a larger purchase with non-ESSER funded
cleaning supplies expenditures. Southeast Polk stated that it provided a spreadsheet of
the ESSER-funded items included in the larger purchase, while also acknowledging that
there was some confusion reconciling to the total dollar amount of cleaning supplies
charged to ESSER. The LEA noted that it could document that the vendor was paid for
the larger order consisting of both ESSER and non-ESSER funded items.
Our draft report also identified five expenditures totaling $80,997 that did not appear to
be subject to a competitive procurement process. Southeast Polk provided additional
context by noting that the expenditures were an aggregate of cleaning supply and air
filter costs incurred from July 2022 through December 2022, and that it did not know
whether non-general fund dollars (for example, ESSER funds) would be available to help
cover the costs at the time the items were acquired. Using vendors with which it had
long-term relationships, Southeast Polk initially used non-ESSER funds to make these
purchases to mitigate coronavirus-related health challenges and minimize the health
effects on students and staff. Through a reclassification of costs, Southeast Polk later
used available ESSER funds to fund these purchases which freed up its general fund
(non-ESSER) dollars for other purposes.
Regarding the expenditure totaling $62,000 for school bus air conditioners, Southeast
Polk stated that the expenditure was pre-approved by Iowa and the LEA’s School Board.
The LEA noted that it received sealed bids from bus manufacturers for school buses and
alternative pricing for school bus air conditioners, while also acknowledging that it could
not locate the bid documentation for these items due to key personnel changes in its
Transportation Department.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0173 4
OIG Response
We did not make any changes to the report based on Southeast Polk’s comments
regarding its procurement of school bus air conditioners. However, based on Southeast
Polk’s clarification and further analysis of available information, we removed from the
finding the two unsupported expenditures totaling $53,733 for cleaning supplies and
the five expenditures totaling $80,997 that were not subject to a competitive
procurement process. We also removed two recommendations related to those
expenditures from the report.
Southeast Polk acknowledged that it could not locate the bid documentation associated
with its purchase of school bus air conditioners, documentation that likely would have
included any contract the LEA would have executed with the vendor. As we note in the
body of the report, without this information, Southeast Polk either did not award a
contract to the vendor contrary to 2 C.F.R. section 200.320(b)(2)(iii), or failed to
maintain the contract in its procurement files contrary to 2 C.F.R. section 200.318(i). We
did not make any changes to the report for this expenditure.
During our final review and analysis of available information for the two unsupported
expenditures, we located documentation (invoices and checks) that supported proof of
payment for the $53,733 in cleaning supplies and therefore removed them as
unsupported costs from the finding. We considered Southeast Polk’s clarification
regarding the five expenditures that were not subject to a competitive procurement
process and further analyzed available information for those expenditures, including the
type and cost of the items purchased (cleaning supplies and air filters), funding source at
the time of purchase, and the circumstances surrounding the coronavirus pandemic.
Based on Southeast Polk’s clarification and that analysis, we concluded that there were
no procurement issues related to these five expenditures and we removed information
related to these expenditures from the finding and two recommendations from the
report.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0173 5
Appendix A. Scope and Methodology
Our review covered Southeast Polk’s ESSER expenditures from July 1, 2022, through
June 30, 2023 (review period). We limited our internal control work to gaining a basic
understanding of how Southeast Polk’s accounting system was used to account for
ESSER funds and how to interpret accounting codes. We conducted our review remotely
from February 2024 through June 2024. We discussed the results of our review with
Southeast Polk and Iowa officials on June 20, 2024.
Sampling Methodology
To determine whether Southeast Polk expended ESSER grant funds for allowable
purposes in accordance with applicable requirements, we used a judgmental, risk-based
process to select 20 expenditures (3 percent) for review from a total population of
591 expenditures for the period July 1, 2022, through June 30, 2023. The selected
expenditures represented $345,583 (44 percent) of the $790,066 in total ESSER
expenditures during our review period. For purposes of selection, we first divided the
expenditures into two strata: one for personnel expenditures (totaling $527,022) and
one for non-personnel expenditures (totaling $263,044). We then selected samples as
follows:
• From the personnel population, we judgmentally selected five expenditures,
totaling $172,056 (33 percent of total personnel expenditures). We selected the
four highest dollar payroll transactions (over $30,000) and one additional
payroll transaction based on a combination of dollar amount and employee
position description.
• From the non-personnel population, we judgmentally selected 15 expenditures,
totaling $173,527 (66 percent of total non-personnel expenditures). We
selected the nine highest dollar transactions (over $6,000) and six additional
transactions using one or a combination of the following factors: high-dollar
amount, reclassified transaction, or duplicate amount.
The results of our testing apply only to the expenditures reviewed and cannot be
projected to the universe of ESSER expenditures.
Use of Computer-Processed Data
We relied, in part, on computer-processed data (LEA expenditure data) from Southeast
Polk’s accounting system. Southeast Polk provided us with a spreadsheet that contains
its ESSER expenditure data from July 1, 2022, through June 30, 2023. To assess the
completeness of the expenditure data in the spreadsheet, we compared total
expenditures in the spreadsheet to total expenditures in the four quarterly ESSER
U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0173 6
expenditure reports that Southeast Polk submitted to Iowa for our review period. To
assess the reliability of the expenditure data in the spreadsheet, we reviewed
supporting documentation, such as invoices, proof of payment, and payroll records (as
applicable), for the 20 expenditures covered by our review. We did not identify any
issues and concluded that the expenditure data in the spreadsheet were reliable for
their intended use.
Compliance with Standards
We conducted our work in accordance with OIG quality control standards and the
Council of the Inspectors General on Integrity and Efficiency’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 our conclusions.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0173 7
Appendix B. Acronyms and Abbreviations
ARP American Rescue Plan Act
C.F.R. Code of Federal Regulations
ESSER Elementary and Secondary School Emergency Relief
Iowa Iowa Department of Education
LEA local educational agency
Southeast Polk Southeast Polk Community School District
Uniform Guidance Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards
U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0173 8
Iowa Department of Education’s Comments
U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0173 9
U.S. Department of Education
Office of Inspector General
ED-OIG/F24CA0173 10
File and source
- File
- southeast-polk-community-school-district-esser.pdf
- Size
- 890,878 bytes
- SHA-256
- 8d01a1cfe4ebb33de594d1727dcd72489de084e1c69b844c7f3fc5442ea951e5
- Original
- oig.ed.gov