Illinois’ Oversight of Local Educational Agency ARP ESSER Plans and Spending

The objectives of the audit were to determine whether the Illinois State Board of Education (Illinois) had an adequate oversight process in place to ensure that (1) local educational agencies’ (LEA) American Rescue Plan (ARP) Elementary and Secondary School Emergency Relief (ESSER) plans met applicable requirements and (2) LEAs use ARP ESSER funds in accordance with applicable requirements and their approved LEA ARP ESSER plans.We found that Illinois generally had adequate processes to ensure that LEA ARP ESSER plans met applicable requirements. However, it did not communicate accurate guidance to LEAs regarding when to submit their ARP ESSER plans according to U.S. Department of Education (Department) guidance. As a result, 434 (54 percent) of 801 LEAs did not submit their ARP ESSER plans within a reasonable timeframe as provided for in Department guidance, with one LEA submitting its plan to Illinois more than 540 days after receiving its allocation. Further, six LEAs still had not submitted their ARP ESSER grant application and plan to Illinois as of January 11, 2024, more than 2.5 years after the LEAs received their ARP ESSER allocations. Thus, some LEAs may not have received critical ARP ESSER funds timely or early enough to adequately respond to the impacts of the coronavirus pandemic by addressing students’ academic, social, emotional, and mental health needs, which was the purpose of the ARP ESSER program. We also found that Illinois’ process for reviewing LEA ARP ESSER reimbursement requests could be strengthened in a key area to provide additional assurance that LEAs use ARP ESSER funds for allowable purposes, and although Illinois has been consistent in how it oversees LEAs’ use of ARP ESSER funds, it does not request a listing of expenditures or review any supporting documentation from LEAs as part of its review of LEA reimbursement requests. Without supporting documentation to verify that the expenditures are allowable and properly accounted for, there is an increased risk that Illinois will not identify or become aware of significant compliance issues involving the ARP ESSER program.