Emerging Issue: Emergency Connectivity Fund Program documentation challenges

This article was originally published in the special issue of the Digital Audit Connection for the 2023 Washington Association of School Business Officials conference. Read the full issue here.

While auditing school districts' federal programs this year, auditors have noted a challenge related to the Emergency Connectivity Fund Program, which was part of the federal government's COVID-19 relief package and intended to facilitate a fast conversion to remote learning.

The program often was not listed on districts' Schedule of Expenditures of Federal Awards, when it should have been. This appears to have happened because the federal funds were managed by districts' information technology departments, bypassing their business offices where internal controls over federal programs typically reside.

As a result, the program was not initially included in districts' federal single audits when it likely would have been. Additionally, districts are facing difficulty providing the documentation the program requires.

To make sure we are auditing the program to the correct interpretation of the requirements, we verified them with the Federal Communications Commission, the awarding agency.

Specific to the ECF grant, the documentation must show that award funds were used only to purchase equipment and services for students and staff with “unmet need,” meaning they did not have adequate resources to learn or work remotely. The documentation must be:

• Specific. For example, it might consist of a list of each student or employee who checked out the equipment, along with information supporting the unmet need of each person.
• Relevant and accurate at the time of reimbursement. For example, counts or data from the initial grant application phase are not likely relevant or accurate at the reimbursement stage.

For more information about program requirements and a list of frequently asked questions, please refer to FCC's webpage dedicated to this program: https://www.fcc.gov/emergency-connectivity-fund-faqs.