SOUTH SAN ANTONIO INDEPENDENT SCHOOL DISTRICT

2023-001 ALN 32.009 Emergency Connectivity Fund Equipment/Real Property Management Type of Finding: Significant Deficiency and Non-Compliance Federal Communications Commission Criteria The 2023 2 CFR Part 200 (Compliance Supplement) identified Equipment/Real Property Management as an applicable compliance requirement for the Emergency Connectivity Fund (ECF). Specifically, recipients of ECF are required to maintain equipment and service inventories of the devices and services purchased with program funds. Inventories should contain information such as equipment or service type, make and model of equipment, equipment serial number, service plan details, names of person(s) (student or District employee) who is responsible for the equipment or service provided, and dates the equipment was in service. Condition The District was unable to support adherence to all of the various equipment and service inventory requirements under the federal program for fiscal year ending August 31, 2023. Specifically, the District’s inventory records did not include equipment type, equipment makes and models, and dates the equipment was in service for an order of iPads purchased under the program. This information was provided by the District at a later date from information obtained from the service/equipment provider. The iPad serial numbers and name of the school employee responsible for the device were correctly inventoried. In addition, the District’s inventory records did not include service plan details, name of the school employee responsible for the service, and descriptions of intended service areas for hotspot and iPad services when these services were put into place. The type of service provided was on file. The majority (70%) of the District’s purchases under ECF for the fiscal year were for Chromebooks. No exceptions were noted for the inventory records for these devices. Cause The District experienced turnover in the technology department, which oversaw the ECF application and document retention process, and did not have adequately documented policies and procedures in place to ensure compliance with the Equipment/Real Property Management requirement for this program. Effect or Potential Effect Noncompliance with the Equipment/Real Property Management requirement did occur and could continue to not be prevented, or detected and corrected, by the District’s system of internal control over compliance, leading to federally funded equipment and services not being properly maintained and tracked during the life of the equipment or service, and therefore potential loss of Federal award funding in the future. No questioned costs were identified as equipment and services under this program were deemed to be allowable and properly accounted for upon further discussion with the client. Recommendation The District should review its inventory policies and procedures, particularly those policies and procedures for federally funded equipment and services, and ensure records are maintained for the life of the use of equipment or service, and contain all the required information as specified by the grantor. Views of Responsible Officials and Planned Corrective Actions See corrective action plan.