Gilbert Unified School District No. 41

Finding Number: 2024‐001 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Emergency Connectivity Fund 32.009 ECF202208394 $141,445 Education Stabilization Fund 84.425 S425U210038 141,445 Federal Agencies: Department of Education and USAC Pass‐Through Agencies: Arizona Department of Education and USAC Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Activities Allowed or Unallowed and Allowable Costs/Cost Principles Criteria Management is responsible for establishing and maintaining internal controls over its accounting records. Further, in accordance with 2 CFR 200.510, the District is responsible for the design and implementation of controls over the preparation of the Schedule of Expenditures of Federal Awards (SEFA) each fiscal year. Additionally, 2 CFR 200.303 requires the District establish and maintain internal control over the federal awards that provides reasonable assurance that the District is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of federal awards. Condition The District was awarded several new Federal grants in response to the COVID‐19 pandemic, which made proper preparation of the SEFA challenging and the District failed to include the new grant on the fiscal year 2022 SEFA. The District also submitted the same expenditures for reimbursement for two federal programs. Cause The District did not account for the Emergency Connectivity Fund (ECF) properly as the program was unique and not part of the District’s normal federal program operations. It was not known that the program was subject to Single Audit. In addition, there was a lack of financial oversight of the ECF grant application submitted by the Technology Department during fiscal year 2022. Effect The District received reimbursements for two federal grants, one for the Education Stabilization Fund in fiscal year 2022 and the other for the ECF grant in fiscal year 2024, for expenditures totaling $141,445. In addition, the fiscal year 2022 SEFA was incorrect as the ECF expenditures were not included on the SEFA; however, it was determined the error did not have an effect on the selection of major federal programs. Context During fiscal year 2021‐22, the District applied for and was approved for funding under the Universal Service Company (USAC)'s Emergency Connectivity Fund (ECF). The District, in conjunction with its consultant, submitted expenditures from two purchase orders to USAC's ECF for purchases made in fiscal year 2021‐22, one of which was paid for and previously reimbursed under the Education Stabilization Fund. The District received the USAC ECF reimbursement in fiscal year 2023‐24. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should ensure all federal programs are properly reviewed prior to submitting any applications or expenditures for reimbursements. The expenditures should be included in the SEFA for the fiscal year in which the expenditures occurred. In addition, the District should strengthen controls over the accounting records to ensure reimbursements are not submitted for multiple programs. Views of Responsible Officials See Corrective Action Plan.