Yukon-Koyukuk School District's Use of Elementary and Secondary Emergency Relief Funds (ED-OIG/F24NY0182)
Summary
A flash report from the U.S. Department of Education, Office of Inspector General, dated October 30, 2024, control number ED-OIG/F24NY0182, on the Yukon-Koyukuk School District's use of Elementary and Secondary School Emergency Relief funds. The OIG states that all eight expenditures it reviewed were used for allowable purposes, but that Yukon-Koyukuk did not comply with key competitive procurement process or documentation requirements for three of the eight non-personnel expenditures, totaling $24,386 of the $92,527 reviewed. The report makes two recommendations; the Alaska Department of Education and Early Development did not state whether it agreed or disagreed with them but described corrective actions. A transmittal letter signed by Myra Hamilton, Regional Inspector General for Audit, is addressed to Commissioner Deena M. Bishop.
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- Issuer
- U.S. Department of Education, Office of Inspector General
- Document type
- Report
- Date
- 2024-10-30
Cite this document
“Yukon-Koyukuk School District's Use of Elementary and Secondary Emergency Relief Funds (ED-OIG/F24NY0182).”
U.S. Department of Education, Office of Inspector General, dated 2024-10-30. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/yukon-koyukuk-school-district-esser/
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U.S. Department of Education
Office of Inspector General
Yukon-Koyukuk School District’s
Use of Elementary and Secondary
Emergency Relief Funds
October 30, 2024
ED-OIG/F24NY0182
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
October 30, 2024
Deena M. Bishop. Ed.D.
Commissioner
Alaska Department of Education and Early Development
PO Box 110500
Juneau, Alaska 99811
Dear Commissioner Bishop:
Enclosed is our final report, “Yukon-Koyukuk School District’s Use of Elementary and Secondary School
Emergency Relief Funds,” Control Number ED-OIG/F24NY0182. This report incorporates the comments
you provided in response to the draft report. The U.S. Department of Education’s policy is to expedite
audit resolution by timely acting on findings and recommendations. Therefore, if you have any
additional comments or information that you believe may have a bearing on the resolution of this
review, you should send them directly to the following Department of Education official, who will
consider them before taking final Departmental action on this review:
Adam Schott
Delegated the Authority to Perform the Functions and Duties of the Assistant Secretary Office of
Elementary and Secondary Education
U.S. Department of Education
400 Maryland Avenue, SW
Washington, D.C. 20202
We appreciate your cooperation during this review. If you have any questions, please contact me at
(214) 790-5430 or Myra.Hamilton@ed.gov.
Sincerely,
/s/
Myra Hamilton
Regional Inspector General for Audit
Enclosure
400 MARYLAND AVENUE, S.W., WASHINGTON, DC 20202-1510
Promoting the efficiency, effectiveness, and integrity of the Department’s programs and operations.
U.S. Department of Education, Office of Inspector General
Results in Brief
Yukon-Koyukuk School District’s Use of Elementary and
Secondary School Emergency Relief Grant Funds
Why the OIG Performed What Did the OIG Find?
This Work We determined that all the ESSER expenditures we reviewed for Yukon-Koyukuk were
Congress passed three coronavirus allowable. Allowable activities generally include those authorized by the Elementary and
relief acts within a 1-year period that Secondary Education Act, Individuals with Disabilities Education Act, Adult Education and
provided more than $275 billion for Family Literacy Act, Carl D. Perkins Career and Technical Education Act of 2006, and
an Education Stabilization Fund to subtitle B of title VII of the McKinney-Vento Homeless Assistance Act. It also includes
prevent, prepare for, and respond to activities listed in section A-3 of the U.S. Department of Education’s Frequently Asked
the coronavirus, which the President Questions document for the ESSER and Governor’s Emergency Education Relief Programs.
declared as a national emergency in
However, we found that Yukon-Koyukuk did not comply with key competitive
March 2020. This included
procurement process or documentation requirements at 2 Code of Federal Regulations
$189.5 billion for Elementary and
sections 200.318–320 when procuring the goods or services associated with three
Secondary School Emergency Relief
(38 percent) of eight non-personnel expenditures, totaling $24,386 (26 percent) of the
(ESSER), funds intended to provide
$92,527 in non-personnel expenditures we reviewed. For these expenditures, Yukon-
vital support to States, local
Koyukuk used a competitive process but did not maintain documentation supporting its
educational agencies, and schools to
awarding of contracts to the selected vendors.
address the impact of the
coronavirus. Support, in part, What Is the Impact?
includes activities designed to help It is critical that Federal grantees (and subgrantees) document a competitive procurement
students and educators safely return process when required to do so by Federal law or regulation. Without documenting a
to and sustain in-person instruction, competitive process, Yukon-Koyukuk (and by extension, taxpayers) might have paid more
and that address the educational for the same goods and services, potentially resulting in misuse of Federal education
inequities exacerbated by the funds when compared to other vendors.
coronavirus pandemic and students’
social, emotional, mental health, and
What Are the Next Steps?
academic needs. We made two recommendations to address the procurement issues we identified to
ensure ESSER funds are used, documented, and managed in accordance with applicable
Ensuring that ESSER funds are used requirements.
for allowable purposes is critical to
help address the needs of students The Alaska Department of Education and Early Development did not state whether it
and educators. The Yukon-Koyukuk agreed or disagreed with our recommendations, but it described corrective actions to
School District (Yukon-Koyukuk) was address the recommendations. Yukon-Koyukuk did not provide any comments.
allocated approximately $2.6 million We summarized the Alaska Department of Education and Early Development’s comments
in ESSER funds to support 10 schools and provided the OIG’s response at the end of the finding. We also provided the Alaska
serving about 3,100 students. Department of Education and Early Development’s comments at the end of the report
We performed this review to (see Auditee Comments).
determine whether Yukon-Koyukuk
expended ESSER grant funds for
allowable purposes in accordance
with applicable requirements.
Flash Report ED-OIG/F24NY0182
Purpose
The objective of our flash review was to determine whether the Yukon-Koyukuk School
District (Yukon-Koyukuk) 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.
Yukon-Koyukuk School District
The Yukon-Koyukuk School District in Alaska is a local educational agency (LEA) in a small
suburban setting with 10 schools that serves about 3,100 students. Yukon-Koyukuk was
allocated approximately $2.6 million in ESSER funds, and as of March 11, 2024, it had
spent about $1.8 million (68 percent) of this allocation to address the impacts of the
coronavirus. For our review period, Yukon-Koyukuk received $1.6 million in ESSER funds,
$1.1 million of which were American Rescue Plan (ARP) ESSER funds. However, Yukon-
Koyukuk expended only $201,000 of these ARP ESSER funds. In its approved ARP ESSER
plan, Yukon-Koyukuk noted that it planned to use its ARP ESSER funds, in part, for new
curricula in literacy and math, educational technology, support for instructional
intervention, monitoring schools and offices for ventilation and cleanliness, installing
individual cleaning areas, and mental health services.
What We Did
We selected and reviewed 8 non-personnel ARP ESSER 2 expenditures (10 percent) from
a total population of 81 ARP ESSER expenditures for the period July 1, 2022, through
June 30, 2023 (review period). We used a judgmental, risk-based process to select the
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.
2
We limited the scope of our review to ARP ESSER expenditures to be consistent with our reviews of
other LEAs within the State of Alaska. We also limited the scope of our review to non-personnel
expenditures because Yukon-Koyukuk did not have any personnel expenditures.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0182 1
eight expenditures that represented $92,527 (46 percent) of the $200,782 in total ARP
ESSER expenditures for the period July 1, 2022, through June 30, 2023 (review period).
We reviewed each expenditure to determine whether it was (1) connected to the
coronavirus pandemic (intended to prevent, prepare for or respond to the coronavirus
pandemic, including its impact on the social, emotional, mental health, and academic
needs of students); (2) an authorized use of ESSER funds under applicable law and
regulations; and (3) reasonable and necessary and otherwise permissible under the
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for
Federal Awards (Uniform Guidance, 2 Code of Federal Regulations (C.F.R.) part 200). We
also performed additional work, as needed, to determine whether Yukon-Koyukuk
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 Yukon-Koyukuk
officials to gain a basic understanding of how they used ESSER funds, and their
processes for approving and monitoring ESSER expenditures.
An LEA can use ESSER funds for any activity deemed allowable under section 18003(d) of
the Coronavirus Aid, Relief, and Economic Security Act (P.L. 116-136); section 313(d) of
the Coronavirus Response and Relief Supplemental Appropriations Act (P.L. 116-260);
and section 2001(e) of the American Rescue Plan Act (P.L. 117-2). These activities
generally include any activity authorized by the Elementary and Secondary Education
Act, Individuals with Disabilities Education Act, Adult Education and Family Literacy Act,
Carl D. Perkins Career and Technical Education Act of 2006, and subtitle B of title VII of
the McKinney-Vento Homeless Assistance Act; as well as those listed in section A-3 of
the U.S. Department of Education’s Frequently Asked Questions document for the
ESSER and Governor’s Emergency Education Relief Programs (May 2021, and updated
on December 7, 2022).
What We Found
We determined that all eight (100 percent) expenditures that we reviewed for Yukon-
Koyukuk were used for allowable purposes. These expenditures were generally for items
in broad categories such as office supplies, commercial labor, travel costs, and teacher
assistance due to the remote location of the district. They were connected to the
coronavirus pandemic and authorized uses of ESSER funds under applicable law and
regulation. However, we found that Yukon-Koyukuk did not comply with key
competitive procurement process or documentation requirements at 2 C.F.R. sections
200.318–320 when procuring the goods and services associated with three (38 percent)
of the eight non-personnel expenditures, $24,386 (26 percent) of the $92,527 in non-
personnel expenditures we reviewed.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0182 2
Procurement Issues
Yukon-Koyukuk did not comply with key Federal procurement requirements under
2 C.F.R. section 200.320 when procuring the goods or services associated with
three (38 percent) of the eight expenditures we reviewed, totaling $24,386. It used a
competitive process but did not maintain documentation supporting its awarding of
contracts to the selected vendors (three expenditures), contrary to applicable Uniform
Guidance general procurement standards.
When the value of the procurement for property or services under a Federal financial
assistance award exceeds the simplified acquisition threshold of $250,000, formal
procurement methods are required. 3 According to 2 C.F.R. section 200.320(b), the two
types of formal procurement methods that can be used are sealed bids and proposals.
• Sealed bids require two or more responsible bidders that are willing and able to
compete effectively for the business and the procurement lends itself to a firm
fixed price contract. The firm fixed price contract should be made in writing to
the lowest responsive and responsible bidder.
• Proposals require that the non-Federal entity must have a written method for
conducting technical evaluations of the proposals received and making
selections.
For purchases between $10,000.01 and $250,000 (simplified acquisition threshold), the
procurement standards require that price or rate quotations be obtained from an
adequate number of qualified sources as determined by the non-Federal entity.
Competitive Procurement Process Used, but Not Documented
Two of these expenditures, totaling $6,555, were part of a larger purchase that Yukon-
Koyukuk made to install internet connectivity for 7 community sites serving
approximately 150 rural families at a cost of about $700,000. Yukon-Koyukuk verbally
solicited offers from vendors to provide adequate home internet for students and
during our review provided records such as purchase orders, invoices, voucher details,
and pricing information but was unable to provide sufficient documentation to support
its bidding process as required by 2 C.F.R. section 200.320(b). Yukon-Koyukuk also did
3
A non-Federal entity can establish a threshold lower than the simplified acquisition threshold, for
purposes of requiring formal procurement activities; however, for this review, we used the simplified
acquisition threshold of $250,000 established under Federal regulation when assessing the LEA’s
compliance with applicable Federal procurement standards.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0182 3
not provide a contract with the vendor for these expenditures. According to 2 C.F.R.
section 200.403(g), costs must be adequately documented.
For the third expenditure, totaling $17,831, Yukon-Koyukuk site administrators needed
assistance with training staff to work with students on attendance and disciplinary
issues, and overall site administration support. Yukon-Koyukuk provided the contract
with the vendor but did not provide documentation to support that it complied with
small purchase procedures. 4 According to a Yukon-Koyukuk official, Yukon-Koyukuk
verbally requested and received price quotations from two vendors. However, Yukon-
Koyukuk did not provide us with the written price rate quotations from these two
vendors. According to 2 C.F.R. section 200.320(a)(2)(i), if small purchase procedures are
used, price or rate quotations must be obtained from an adequate number of qualified
sources.
It is critical that Federal grantees (and subgrantees) document a competitive
procurement process when required to do so by Federal law or regulation. Without
documenting a competitive procurement process, the grantees (and subgrantees) may
overpay for large purchases; therefore, Yukon-Koyukuk (and by extension, taxpayers)
might have paid more for the same goods and services, potentially resulting in misuse of
Federal education funds when compared to other vendors. We concluded that Yukon-
Koyukuk did not maintain sufficient documentation to support procurement procedures
for the three expenditures. According to 2 C.F.R. section 200.318(i), the non-Federal
entity must maintain records sufficient to detail the history of procurement. These
records must include, but are not necessarily limited to, the following: rationale for the
method of procurement, selection of contract type, contractor selection or rejection,
and the basis for the contract price. Per section 10.03 of the U.S. Government
Accountability Office’s Standards for Internal Control in the Federal Government,
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.
4
A small purchase is the acquisition of property or services, the aggregate dollar amount of which is
higher than the micro-purchase threshold of $10,000 but does not exceed the simplified acquisition
threshold of $250,000. If it meets certain conditions, a non-Federal entity can establish and self-certify a
threshold higher than the micro-purchase threshold, up to $50,000; however, for this review, we used
the micro-purchase threshold of $10,000 established under Federal regulation when assessing the LEA’s
compliance with applicable Federal procurement standards.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0182 4
What We Recommend
We recommend that the Assistant Secretary for the Office of Elementary and Secondary
Education require the Alaska Department of Education to require Yukon-Koyukuk to—
1. Determine whether the $24,386 that Yukon-Koyukuk charged to ARP ESSER for
the three expenditures made without maintaining proper documentation of the
competitive procurement process was reasonable when compared to the costs
of suitable alternatives, and if not, require appropriate corrective actions.
2. Ensure that LEA officials responsible for making and documenting purchasing
decisions receive sufficient training on Federal procurement requirements,
including those covered under 2 C.F.R. sections 200.318(i) and 200.320
(methods of procurement to be followed).
Alaska Department of Education and Early Development’s
Comments
The Alaska Department of Education and Early Development did not state whether it
agreed or disagreed with our finding or recommendations, but it described corrective
actions to address the recommendations. The Alaska Department of Education and Early
Development stated that it would ensure that Yukon-Koyukuk is provided additional
training on Federal procurement requirements. Additionally, the Alaska Department of
Education and Early Development stated that it would work with Yukon-Koyukuk to
verify if costs were reasonable for the provided services and, if costs were determined
unreasonable, additional corrective actions would be taken. Yukon-Koyukuk did not
provide any comments.
OIG Response
The Alaska Department of Education and Early Development’s proposed corrective
actions, if implemented as described, are responsive to our recommendations.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0182 5
Appendix A. Scope and Methodology
Our review covered Yukon-Koyukuk’s ARP ESSER expenditures from July 1, 2022,
through June 30, 2023 (review period). We limited the scope of our review to ARP ESSER
funds to be consistent with our reviews of other LEAs within the State of Alaska. We also
limited our internal control work to gaining a basic understanding of the process Yukon-
Koyukuk used to account for ESSER funds, including the accounting system and
accounting codes used by Yukon-Koyukuk. We conducted our review remotely from
April 2024 through June 2024. We discussed the results of our review with Yukon-
Koyukuk and Alaska Department of Education and Early Development officials on
June 27, 2024.
Sampling Methodology
To determine whether Yukon-Koyukuk expended ARP ESSER grant funds during our
review period for allowable purposes in accordance with applicable requirements, we
selected and reviewed 8 non-personnel expenditures (10 percent) from a total
population of 81 non-personnel expenditures using a judgmental, risk-based, selection
process. We selected the eight expenditures using the two highest dollar transactions
(all exceeding $17,000), generally broad item descriptions, or both criteria. These
expenditures represented $92,527 (46 percent) of the $200,782 in total ARP ESSER
expenditures during our review period. Since the expenditures were selected using a
judgmental, risk-based selection process, the results of our testing cannot be projected
to the universe of ARP ESSER expenditures.
Use of Computer-Processed Data
We relied, in part, on computer-processed data (LEA expenditure data) from Yukon-
Koyukuk’s accounting system. Yukon-Koyukuk provided us with an Excel spreadsheet
(report generated from its accounting system) that contained its ARP 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 ARP ESSER expenditure reports
that Yukon-Koyukuk submitted to the Alaska Department of Education and Early
Development for our review period. To assess the reliability of the expenditure data in
the spreadsheet, we reviewed supporting documentation, such as invoices and proof of
payment, for the eight 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.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0182 6
Compliance with Standards
We conducted our work in accordance with OIG quality control standards and the
Council of the Inspectors General on Integrity and Efficiency “Quality Standards for
Federal Offices of Inspector General,” which require that we conduct our work with
integrity, objectivity, and independence. We believe that the information obtained
provides a reasonable basis for our conclusions.
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0182 7
Appendix B: Acronyms and Abbreviations
ARP American Rescue Plan
C.F.R. Code of Federal Regulations
ESSER Elementary and Secondary School Emergency Relief
LEA local educational agency
Uniform Guidance Uniform Administrative Requirements, Cost Principles, and
Audit Requirements for Federal Awards
Yukon-Koyukuk Yukon-Koyukuk School District
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0182 8
Alaska Department of Education and Early
Development’s Comments
U.S. Department of Education
Office of Inspector General
ED-OIG/F24NY0182 9
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