The objective of our audit was to determine whether the U.S. Department of Education (Department) Office of Elementary and Secondary Education (OESE) implemented processes to provide reasonable assurance that it awarded School-Based Mental Health (SBMH) Grant Program grants in accordance with grant requirements and Department policy and monitored grantee performance. Our audit covered OESE’s processes for awarding grants during the fiscal year 2022 SBMH Grant Program competition and for monitoring the performance of the seven grantees included in the fiscal years 2020 and 2021 cohorts. We found that OESE generally implemented processes that provided reasonable assurance that it awarded SBMH Grant Program grants in accordance with grant requirements and Department policy. It completed processes for peer review in accordance with Department policy; however, OESE did not screen grant applications to ensure that they met all application requirements before entering them into the peer review process. Additionally, OESE assessed applicant risk before awarding grants; however, it did not retain all risk assessment records that Department policy requires. In addition, we found that OESE did not always implement post-award activities as designed. Specifically, OESE did not design, finalize, and implement SBMH Grant Program monitoring plans. Additionally, its reviews of grantees’ annual performance reports (APR) were limited to ensuring that the APRs included information in each section. Finally, while OESE designed risk mitigation strategies for fiscal year 2020 grantees with elevated risk, it did not keep records showing that it implemented the strategies as designed.
Open Recommendations
| Recommendation Number | Significant Recommendation | Recommended Questioned Costs | Recommended Funds for Better Use | Additional Details | |
|---|---|---|---|---|---|
| 1.1 | Yes | $0 | $0 | ||
| We recommend that the Assistant Secretary for Elementary and Secondary Education require OESE to review the work of program officers to ensure that for future SBMH grant competitions they screen all grant applications for all application requirements before entering them into the peer review process and ensure that review of requirements checklists are completed before making new awards. | |||||
| 1.2 | Yes | $0 | $0 | ||
| We recommend that the Assistant Secretary for Elementary and Secondary Education require OESE to review the work of program officers to ensure that for future SBMH grant competitions they consult with their program attorney, create a written justification, and obtain the principal officer’s approval before deviating from or changing the ATRP. | |||||
| 1.3 | Yes | $0 | $0 | ||
| We recommend that the Assistant Secretary for Elementary and Secondary Education require OESE to review the work of program officers to ensure that for future SBMH grant competitions they consistently follow records retention policies for official grant files as described in the Handbook. | |||||
| 2.1 | Yes | $0 | $0 | ||
| We recommend that the Assistant Secretary for Elementary and Secondary Education verify that OESE developed, finalized, and implemented a program monitoring plan for the fiscal year 2022 SBMH Grant Program cohort. The plan should consider the use of desk reviews for a sample of grantees. | |||||
| 2.2 | Yes | $0 | $0 | ||
| We recommend that the Assistant Secretary for Elementary and Secondary Education verify that OESE retains records of all SBMH Grant Program monitoring activities, including but not limited to email and telephone communications, grantee performance-related calls, and reviews of drawdown reports and APRs, in official grant files. | |||||
| 2.3 | Yes | $0 | $0 | ||
| We recommend that the Assistant Secretary require OESE to develop, finalize, and implement procedures for reviewing grantees’ APRs and documenting the reviews of those APRs. At a minimum, the review procedures should cover (a) the quality of Government Performance and Results Act of 1993 data, (b) how to assess a grantee’s progress toward achieving approved goals, and (c) follow up with grantees when the information they provide is inaccurate or incomplete. | |||||
| 2.4 | Yes | $0 | $0 | ||
| We recommend that the Assistant Secretary require OESE to implement the risk mitigation strategies as designed in the grant funding slates for new SBMH Grant Program awards and noncompeting continuation awards. | |||||
