Reports

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, in
consultation with the Governor of Florida, to— Obtain a revised ARP EANS application from the 73 nonpublic schools that
used proportionality data (in whole or in part) to estimate its low-income student count and ensure that the schools
include a revised low-income student count that is based on a proper data source. FDOE should use the revised counts
to reassess the eligibility of the 73 schools and any EANS funds used to provide services to ineligible nonpublic schools
must be reverted to Florida’s Governor to be used for allowable purposes under the Governor’s Emergency Education
Relief Fund as authorized by the CRRSA Act or returned to the Department. Alternatively, FDOE could de-obligate EANS
funds used to provide services or assistance to ineligible nonpublic schools and identify another allowable source of funds
for such services or assistance.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, in
consultation with the Governor of Florida, to— Formally document its expenditure review and approval procedures to guide
FDOE personnel through the expenditure review and approval processes. The procedures should be designed to ensure
compliance with applicable requirements, including those pertaining to EANS in both CRRSA and ARP EANS as well as
the regulations at 2 C.F.R. Part 200 (Uniform Guidance).

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, in
consultation with the Governor of Florida, to— Retroactively obtain prior written approval from the Department for the 5
equipment expenditures or return the $187,660 expended for those equipment purchases and perform a review of the
remaining 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 is
required to obtain prior approval from the Department for certain expenditures related to any Department grants, or
whether it can provide prior approval for subrecipients.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require FDOE, in
consultation with the Governor of Florida, to— Develop a process to track and periodically check on the use of
EANS-funded supply purchases with a unit cost under $5,000 to ensure that all supplies are accounted for and used for
allowable purposes.