Congress provided $5.5 billion for the Emergency Assistance to Nonpublic Schools (EANS) program. The purpose of the EANS programs, authorized under the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSA) and American Rescue Plan (ARP), is to provide services or assistance to eligible nonpublic schools to address educational disruptions caused by the COVID-19 emergency. We conducted an audit to determine whether the Florida Department of Education (FDOE) designed and implemented (1) application processes that adequately assessed nonpublic schools’ eligibility for EANS-funded services or assistance and complied with other applicable requirements and (2) oversight processes to ensure that EANS-funded services or assistance were used for allowable purposes. The assistance and comply with other applicable requirements were generally adequate; however, it did not have written procedures for its we found that the application that FDOE developed for nonpublic schools to apply for services and assistance did not ensure that it could use the application data to adequately assess nonpublic schools’ eligibility. The ARP EANS application was not adequate because it included instructions that allowed nonpublic schools to use proportionality data as one of five data source options for estimating the number of students enrolled in their school that were from low-income families. Further, FDOE’s oversight of its CRRSA and ARP EANS expenditure and inventory processes needs strengthening. Specifically, FDOE did not have formal written procedures for its expenditure review and approval processes. Also, FDOE’s processes did not ensure that it obtained prior approval from the Department before funding nonpublic school equipment purchases with a per unit cost of $5,000 or more. Additionally, FDOE did not ensure that it inventoried or tracked items, such as supplies, that were purchased with a per unit cost under $5,000.
Open Recommendations
| Recommendation Number | Significant Recommendation | Recommended Questioned Costs | Recommended Funds for Better Use | Additional Details | |
|---|---|---|---|---|---|
| 2.1 | Yes | $0 | $0 | ||
| We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Obtain a revised ARP EANS application from the 73 nonpublic schools thatused proportionality data (in whole or in part) to estimate its low-income student count and ensure that the schoolsinclude a revised low-income student count that is based on a proper data source. FDOE should use the revised countsto reassess the eligibility of the 73 schools and any EANS funds used to provide services to ineligible nonpublic schoolsmust be reverted to Florida’s Governor to be used for allowable purposes under the Governor’s Emergency EducationRelief Fund as authorized by the CRRSA Act or returned to the Department. Alternatively, FDOE could de-obligate EANSfunds used to provide services or assistance to ineligible nonpublic schools and identify another allowable source of fundsfor such services or assistance. | |||||
| 3.1 | Yes | $0 | $0 | ||
| We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Formally document its expenditure review and approval procedures to guideFDOE personnel through the expenditure review and approval processes. The procedures should be designed to ensurecompliance with applicable requirements, including those pertaining to EANS in both CRRSA and ARP EANS as well asthe regulations at 2 C.F.R. Part 200 (Uniform Guidance). | |||||
| 3.2 | Yes | $187,660 | $0 | ||
| We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Retroactively obtain prior written approval from the Department for the 5equipment expenditures or return the $187,660 expended for those equipment purchases and perform a review of theremaining equipment expenditures to determine whether there are additional purchases that require prior written approval.FDOE should also incorporate into its grants management policies and procedures a step to determine whether it isrequired to obtain prior approval from the Department for certain expenditures related to any Department grants, orwhether it can provide prior approval for subrecipients. | |||||
| 3.3 | Yes | $0 | $0 | ||
| We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, inconsultation with the Governor of Florida, to— Develop a process to track and periodically check on the use ofEANS-funded supply purchases with a unit cost under $5,000 to ensure that all supplies are accounted for and used forallowable purposes. | |||||
