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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/, SHA-256 8961bbee6bb7fc4dd0ff3804d6a76e3b30ce442652a1d50f3dd26a9a28a3b8fd.

Full text

               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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