oversight

Teach for America, Inc., Review of the U.S. Department of Education Discretionary Grant Awards

Published by the Department of Education, Office of Inspector General on 2008-06-05.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

                            UNITED STATES DEPARTMENT OF EDUCATION
                                   OFFICE OF INSPECTOR GENERAL

                                                                                                                    Audit Services
                                                                                                            New York Audit Region

                                                                June 5, 2008
                                                                                                                   Control Number
                                                                                                                 ED-OIG/A02H0003
Wendy Kopp
Chief Executive Officer
Teach for America, Inc.
315 West 36th Street, 6th Floor
New York, NY 10018

Dear Ms. Kopp:

This Final Audit Report, entitled Teach for America, Inc., Review of the U.S. Department of
Education Discretionary Grant Awards, presents the results of our audit. Our objective was to
determine whether Teach for America, Inc.’s (TFA’s) discretionary grant expenditures were
allowable and spent in accordance with Federal laws and regulations for the period, October 1,
2003, through September 30, 2005.



                                                         BACKGROUND


On October 6, 1989, TFA was incorporated as a non-profit corporation with its headquarters
located in New York City. TFA’s mission is to help eliminate educational inequity by enlisting
the nation’s most promising future leaders in the effort. TFA focuses its efforts on building a
corps of outstanding recent college graduates of all academic majors who commit two years to
teach in urban and rural public schools and become lifelong leaders in ensuring educational
equity and excellence for all children. Most TFA recruits do not have education-related majors
in college, and, therefore, have not received the same training as traditional teachers.

TFA had 3,500 teachers (corps members) who provided services to 22 regions throughout the
United States in school year 2005-2006. During our October 1, 2003, through September 30,
2005 audit period, TFA received grant awards from both the U.S. Department of Education (ED)
and the Corporation for National and Community Service (CNCS). Specifically, ED’s Office of
Innovation and Improvement (OII) awarded TFA six grants (see Attachment A) under the
Programs of National Significance, Funds For the Improvement of Education (FIE), of which
three grants were discretionary. 1
1
 The FIE authorizes the Secretary of Education to support nationally significant programs to improve the quality of
elementary and secondary education at the state and local level and to help all students meet challenging state
academic content and student achievement standards.

    The Department of Education's mission is to promote student achievement and preparation for global competitiveness by fostering educational
                                                      excellence and ensuring equal access.
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                                     AUDIT RESULTS


TFA did not fully comply with applicable laws and regulations regarding its discretionary grant
expenditures. We found that $774,944 (about 50 percent) of the total $1,534,290 in expenditures
sampled was unsupported. TFA could not provide adequate supporting documentation because
it lacked sound fiscal accountability controls. As a result, we could not determine whether
$774,944 was spent for the intended grant purposes.

We provided a draft of this report to TFA for review and comment on January 24, 2008. We
reviewed TFA’s response, including five attachments received on March 7, 2008. TFA did not
specifically concur or disagree with the finding and recommendations, but it did generally agree
that its office supply charges lacked proper documentation. In addition, the response to three of
the five recommendations indicated general concurrence. We summarized TFA’s comments and
our response following the finding. Based on our analysis of TFA’s comments and its additional
documentation, our finding and three of the five recommendations remain unchanged. We
revised recommendations 1.3 and 1.4 based on TFA’s comments.

The entire narrative of TFA’s comments is included as Attachment B. Because of the
voluminous nature of the attachments to TFA’s comments, we have not included them in
Attachment B. Copies of TFA’s attachments are available on request.

FINDING – TFA Was Unable to Provide Adequate Support for $774,944 of its
          Discretionary Grant Expenditures

TFA could not adequately support about 50 percent of its discretionary grant expenditures that
we sampled. We randomly and judgmentally sampled $1,534,290 out of the total $6,000,000
expended for the 3 discretionary grants awarded during our audit period. The sample consisted
of 26 expenditures for salary and non-salary expenditures. TFA was not able to provide
adequate support for 17 of these expenditures, totaling $774,944. TFA could not provide
adequate supporting documentation for its charges to these grants because of significant
deficiencies in its fiscal accountability controls.

During our audit period, TFA did not use a professional accounting software package, and
instead made use of manual input forms with hand-written notes to account for and support its
charges to the grant. In addition, TFA lacked project identification numbers to track
expenditures for two of the three discretionary grants. Without project numbers, the
expenditures could not be properly identified and monitored. Although TFA had a project
number for one discretionary grant, the general ledger reports did not show the total amount of
expenditures. Table 1 identifies the $774,944 in unsupported expenditures with detailed
explanations provided below.
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Table 1: Unsupported Costs
       Grant Number                   Amount Sampled                Unsupported Amount

U215U040025                                $705,360                               $405,704
U215U030034                                  802,118                               342,428
U215U030014                                   26,812                                26,812
          Total                           $1,534,290                              $774,944

According to 34 C.F.R. § 75.730 (July 1, 2003), “A grantee shall keep records that fully show:
(a) The amount of funds under the grant; (b) How the grantee uses the funds; . . . and (e) Other
Records to facilitate an effective audit.”

Section 1232f(a) of 20 U.S.C. (January 24, 2002) states, “Each recipient of Federal Funds under
any applicable program through any grant . . . shall keep records which fully disclose the amount
and disposition by the recipient of those funds, the total cost of the activity for which the funds
are used, the share of that cost provided from other sources and such other records as will
facilitate an effective financial or programmatic audit. The recipient shall maintain such records
for three years after the completion of the activity for which the funds are used.”

OMB Circular A-122, “Cost Principles for Non-Profit Organizations,” revised May 10, 2004,
states that to be allowable under an award, costs must meet the following general criteria:
        a. Be reasonable for the performance of the award and be allocable thereto under
             these principles.
        b. Conform to any limitations or exclusions set forth in these principles or in the
             award as to types or amount of cost items.
        c. Be consistent with policies and procedures that apply uniformly to both
             federally financed and other activities of the organization.
        d. Be accorded consistent treatment.
        e. Be determined in accordance with generally accepted accounting principles
             (GAAP).
        f. Not be included as a cost or used to meet cost sharing or matching
             requirements of any other federally financed program in either the current or a
             prior period.
        g. Be adequately documented.

According to OMB Circular A-133 § 300(b) (June 24, 1997), “The auditee shall . . . [m]aintain
internal control over Federal programs that provides reasonable assurance that the auditee is
managing Federal awards in compliance with laws, regulations, and the provisions of contracts
or grant agreements that could have a material effect on each of its Federal programs.”

TFA was unable to produce adequate documentation to support $774,944 of its discretionary
grant expenditures shown in the following examples.
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Unsupported costs for grant number U215U040025

TFA could not provide adequate supporting documentation for $405,704 of the $705,360 in
expenditures we sampled that were charged to grant number U215U040025. The purpose of this
grant was to enhance the recruitment and professional training for TFA teachers. TFA used a
portion of this grant to pay for food and lodging costs, TFA corps members salaries, and office
supplies during the period December 2004 to September 2005.

Unsupported Costs for California State University
We judgmentally sampled TFA’s expenditure of $277,262 in institute food and lodging costs for
California State University. In response to our request for all supporting documentation for this
expenditure, TFA provided a copy of California State University’s “Institute Pay Schedule
Worksheet.” This document indicated that the grant was to provide 49 percent of $565,841, or a
net amount of $277,262. However, TFA did not provide any source documentation showing the
attendees, teachers, content, or any other details. Therefore, the claimed expenditure of
$277,262 was not adequately supported.

Unsupported Costs for Temple University
We judgmentally sampled TFA’s expenditure of $287,940 for food and lodging at Temple
University. However, TFA did not provide adequate support for $123,878. TFA provided only
a one-page Microsoft Excel spreadsheet that listed this expenditure as a “10% Down Payment.”
TFA provided no other explanation or documentation, such as attendance sheets or lists of
participants. Based on this limited documentation, we were unable to determine the validity of,
or the reason for, the claimed costs of $123,878.

Unsupported expenditures for Office Supplies
TFA also charged ED grant number U215U040025 to pay for office supply charges. During
December 15, 2004 through June 28, 2005, TFA charged $20,368 for several office supply
purchases. We randomly sampled four expenditures totaling $4,564 for office supplies charged
to this grant.

TFA could not provide specific invoices or documentation for the $4,564 in supply charges. In
addition, TFA’s Vice President of Accounting and Controls acknowledged that this charge was
not adequately supported, and because of the amount of the unsupported costs and time it would
take to research the documentation, it would not be beneficial to go any further to support the
expenditure. Therefore, this expenditure of $4,564 is unsupported.

Unsupported costs for grant number U215U030034

TFA could not provide adequate supporting documentation for $342,428 of the $802,118 in
expenditures we sampled that were charged to grant number U215U030034. The purpose of this
grant was to enhance pre-service training of teachers. TFA used a portion of this grant to pay for
food and lodging costs from June 2004 to September 2004, for corps members attending the
University of Houston.
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Included in our sampling, was a judgmental sample of the largest expenditure for this grant,
$342,428. We found that TFA could not support this expenditure because it could not provide
documentation for the students and staff who attended this training. TFA provided a one-page
summary that listed 93 staff members, but only 85 had actually confirmed their training
attendance by signing the attendance list. Furthermore, there was no documentation identifying
the staff members or that they were eligible to receive food and lodging costs.

Similarly, TFA provided and relied on copies of Microsoft Excel spreadsheets, and in some
cases, on hand-written notes, to document and support ED discretionary grant expenditures. For
example, TFA claimed 672 students attended this course, but this claim was not supported by a
hand-written sign-in list. TFA provided no documentation or attendance list that these students
were actually enrolled in the program. On several occasions, TFA claimed more than 800 staff
and students received lunch or dinner. The documentation indicated that on June 28, 2004, 811
participants received lunch, and on June 15, 2004, 899 participants received lunch. However, the
documentation did not support the claimed number of participants. There was no agenda, no
description of the meals, and no list of attendees.

On several occasions, we requested additional documentation from TFA’s Vice President of
Accounting and Controls, but she did not provide us with adequate supporting documentation or
an explanation of the expenditures. The documentation provided was primarily copies (not
original documents) and there was no effective way to verify the validity of the staff and students
actually participating in the program or the food and lodging costs claimed.

In addition to the regular meal reimbursements, we noted that a single meal charge was claimed
on invoices without proper documentation. On July 10, 2004, $858 was charged for one meal at
Moody Towers, and on June 23, 2004, a one-time meal charge was submitted for $471 with no
documentation of who participated or the reason for the charge.

Unsupported Costs for grant number U215U030014

TFA could not provide adequate supporting documentation for the $26,812 in expenditures we
sampled that were charged to grant number U215U030014. The purpose of this grant was to
expand TFA impact by increasing the number of highly qualified teachers in our nation’s
highest-need schools. TFA used this grant to pay for the alternate certification of TFA corps
members.

TFA provided payment requests for the total amount disbursed of $26,812, along with checks for
this amount and certification cost reimbursement forms signed by the students. However, this
documentation was insufficient because it did not indicate that the students actually attended and
satisfactorily completed the classes. There were no official transcripts or evidence that the
courses occurred. Therefore, $26,812 of claimed certificate reimbursement expenditures was not
adequately supported.

The unsupported expenditures occurred primarily because TFA did not have an adequate
accounting system in place to support, properly document, and monitor its ED grant
expenditures. We generally were not provided with original source documentation, but instead
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were provided hand-written notes and other materials that were duplicates. TFA also did not
have written policies and procedures 2 for its accounting and specific fiscal internal control
processes within its organization. Due to the lack of proper fiscal accountability controls, such
as use of a professional accounting software package, and lack of proper supporting
documentation, there was no effective way to verify the validity of the costs claimed. As a
result, we found that TFA charged unsupported expenditures of $774,944 to ED discretionary
grants during the October 1, 2003 through September 30, 2005 period. Consequently, there is no
assurance that these grant funds were properly expended in accordance with the grant objectives
to train and support teachers who teach disadvantaged students at the nation’s neediest schools.

Recommendations

We recommend that the Assistant Deputy Secretary for the Office of Innovation and
Improvement require TFA to:

1.1        Provide support for the $774,944 in non-salary ED discretionary grant expenditures, or
           return the funds, with applicable interest, to ED.
1.2        Provide support for the remaining $4,465,710 in salary and non-salary ED discretionary
           grant expenditures, or return the funds, with applicable interest, to ED.
1.3        Provide evidence that TFA implemented a professional accounting system that would
           enable TFA to support, properly document, and monitor its ED grant expenditures as
           required by Federal laws and regulations.
1.4        Provide evidence that TFA established and implemented adequate written policies and
           procedures for its accounting and specific fiscal internal control processes within its
           organization.
1.5        Maintain required supporting documentation for costs charged to ED’s discretionary
           grants.

TFA’s Comments

In its response to the draft report, TFA did not specifically concur or disagree with the finding
and recommendations, but it did generally agree that its office supply charges lacked proper
documentation. Regarding the finding, TFA stated the ED grant funds were spent as directed by
the terms of the grants. TFA also stated that the questioned costs outlined in the draft report
were the result of tracking systems that differ from the systems utilized by TFA in the past which
have, according to TFA, been updated with new personnel and procedures to effectively monitor
existing and future grants. Further, TFA indicated that it could demonstrate that its corps and
staff members attended the institutes and it could also demonstrate with full confidence that the
questioned food costs were incurred and that the funds were spent appropriately. TFA stated that
all costs related to its summer training institutes came from its contracts with universities that
provided food and lodging for corps and staff members during fully residential summer training.
TFA also provided statements indicating five corps members had completed their required
course work.



2
    The policies and procedures provided to OIG for review were not signed or initialed and were from 2007 forward.
Final Audit Report                                                                   Page 7 of 18
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In response to recommendations 1.1 and 1.2, TFA stated it provided additional documentation
which indicated ED funds were utilized in accordance with required provisions and regulations.
TFA provided extensive spreadsheets with lists of corps members and institute staff, by location,
that TFA contended participated in various institutes from 2003 through 2005. For grant number
U215U030034, TFA provided spreadsheets that showed there were 111 staff members and 725
corps members, including 26 resignations, who attended the University of Houston’s summer
training from June through September 2004. Regarding the unsupported supply costs, TFA
stated that the lack of supporting documentation was the result of turnover of prior grants and
contracts staff coupled with the limitations of the legacy document storage systems in place
during the time under question.

For recommendation 1.3, TFA stated that beginning in March 2006, the new grants and contracts
team at TFA designed and implemented a comprehensive accounting system to properly budget,
document, report, and monitor its ED grant expenditures.

For recommendation 1.4, TFA stated it introduced formal updated fiscal policies on October 1,
2006. In addition, TFA said it published a finance guide to communicate formal, operational
processes to its budget managers and end-users.

For recommendation 1.5, TFA stated it had an ongoing commitment to build proper
infrastructure and processes for maintaining appropriate source documentation, including vendor
invoices, and corps and staff member data. In addition, TFA said it had enhanced its chart of
accounts to incorporate funding source codes in place of its old Excel spreadsheets. This
enhancement took effect during the 2005-2006 funding year.

OIG Response

We considered TFA’s response; however, our finding and three of the five recommendations
remain unchanged. We revised recommendations 1.3 and 1.4 based on TFA’s comments. TFA
did not specifically concur or disagree with the finding and recommendations, but it did
generally agree that its office supply charges lacked proper documentation.

For recommendations 1.1 and 1.2, the spreadsheets that TFA provided in its response for its
corps and staff members have significant discrepancies from previously provided documentation.
Furthermore, these spreadsheets were not provided during the audit. TFA’s response did not
provide sufficient documentation that its corps members actually attended and completed the
classes or that the staff members attended the University of Houston summer training institute
from June through September 2004.

In its response, TFA provided a spreadsheet for 725 corps members, including 26 corps members
who reportedly resigned, who attended the University of Houston summer institute during this
time period. However, TFA did not indicate when the resignations occurred. During our audit,
TFA provided OIG with a hard copy list indicating 672 corps members, with no resignations,
who attended the program at that time, for a difference from the response spreadsheet of 53. We
also noted other discrepancies between the original list and the response spreadsheet.
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Specifically, the original list had 51 students who were not on the response spreadsheet, and the
response spreadsheet had 104 students who were not on the original list.

In its response, TFA provided a spreadsheet which listed 111 staff members at TFA’s University
of Houston summer institute from June through September 2004. In contrast, during the audit
fieldwork, TFA provided OIG a manually prepared sign-in list that showed a total of 93 staff at
the University of Houston during this time period. The list had 93 hand-written names and
spaces for signatures, but only 85 had confirmed their attendance by signing the list. We
compared the response spreadsheet to the manual list and noted 86 staff were on both lists, but
the response list also indicated 25 additional staff members.

The discrepancies between the original hand-written lists provided during the audit and the
spreadsheets provided in response to the draft report raised more questions regarding the validity
of the source, accuracy, and reliability of the documentation TFA provided for its corps and staff
members. Furthermore, TFA indicated in its response, it was not able to provide data for the
individual meals and that it did not maintain corps member sign in sheets.

TFA stated that all costs related to its summer training institutes came from its contracts with
universities that provided food and lodging for corps and staff members during fully residential
summer training. However, TFA did not provide any documentation of these contracts or
specific cost documentation for the claimed costs. TFA also provided statements indicating five
corps members had completed their required course work. However, this documentation did not
prove that these corps members had a license, certificate, or permit to teach students in a public
classroom as required by city and state laws in each of the districts in which they operated. TFA
attributed its lack of supporting documentation for office supply costs to its turnover of prior
grants and contracts staff coupled with the limitations of its document storage systems in place at
that time. TFA’s response did not provide sufficient additional information to what it provided
previously, and is therefore, insufficient support for the $774,944 of expenditures charged to
ED’s discretionary grants.

TFA’s response to recommendations 1.3 and 1.4 indicated that it had implemented a
comprehensive accounting system, and updated fiscal policies and procedures, to address these
recommendations. However, we did not review the new accounting system or the updated fiscal
policies and procedures as stated in TFA’s response because this was not in the scope of our
review. We consider the actions taken to address recommendation 1.5 as TFA’s general
concurrence to this recommendation.



                  OBJECTIVE, SCOPE, AND METHODOLOGY


Our audit objective was to determine whether TFA’s discretionary grant expenditures were
allowable and spent in accordance with Federal laws and regulations for the period, October 1
2003 through September 30, 2005.
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To ensure the completeness and accuracy of the data provided by TFA, we obtained and
extracted from TFA’s accounting system, all expenditures related to the discretionary grants for
the period, October 1, 2003 through September 30, 2005. Expenditures for the three
discretionary grants awarded during the audit period, grant numbers U215U030014,
U215U030034, and U215U040025, totaled $6,000,000. This constituted our discretionary grant
expenditure universe.

We used different sampling methodologies on each of the three grants reviewed due to the
varying type and nature of the expenditures charged to each grant. We randomly sampled and
reviewed a total of $166,970 in salary and non-salary expenditures charged to two grants. Of
this amount, $26,812 in student alternate certifications was expended in grant U215U030014,
$135,594 was expended for salaries in grant U215U040025, and $4,564 was expended for
supplies.

In addition, we judgmentally selected $1,367,320 in expenditures for non-salary charges in two
of the three grants. Grant U215U030034 had 14 expenditures where we selected the largest
dollar expenditures from the University of Houston, Fordham University, and California
State University, totalling $781,178, and the smallest expenditure, $20,940, charged to this grant.
We also judgmentally sampled the two largest expenditures for Temple University and
California State University, totalling $565,202, charged to grant U215U040025 for food and
lodging costs.

To accomplish our objective we:
   a. Reviewed TFA approved grant applications and related budgets;
   b. Policies and procedures;
   c. Interviewed the TFA’s Vice President of Accounting and Controls;
   d. Reviewed TFA’s written policy manual and organizational charts to gain an
       understanding of the accounting process;
   e. Reviewed the Independent Public Accountant reports for TFA for the periods ending
       September 30, 2003, 2004, and 2005; and
   f. Reviewed the General Ledger Report for one grant.

We concluded that the data was sufficiently reliable to support the finding, conclusions, and
recommendations, and that using the data would not lead to an incorrect or inaccurate
conclusion.

We performed our fieldwork at TFA’s Headquarters at 315 West 36th Street, New York, New
York, from December 4, 2006, through March 9, 2007. We conducted the audit in accordance
with generally accepted government auditing standards appropriate to the limited scope of the
audit described above.
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                            ADMINISTRATIVE MATTERS


Statements that managerial practices need improvements, as well as other conclusions and
recommendations in this report, represent the opinions of the Office of Inspector General.
Determinations of corrective action to be taken, including the recovery of funds, will be made by
the appropriate Department of Education officials in accordance with the General Education
Provision Act.

If you have any additional comments or information that you believe may have a bearing on the
resolution of this audit, you should send them directly to the following Department of Education
official, who will consider them before taking final Departmental action on this audit:

                              Doug Mesecar
                              Assistant Deputy Secretary for Innovation and Improvement
                              Office of Innovation and Improvement
                              U.S. Department of Education
                              400 Maryland Avenue, SW
                              Washington, DC 20202


It is the policy of the U. S. Department of Education to expedite the resolution of audits by
initiating timely action on the finding and recommendations contained therein. Therefore,
receipt of your comments within 30 days would be appreciated.

In accordance with the Freedom of Information Act (5 U.S.C. § 552), reports issued by the
Office of Inspector General are available to members of the press and general public to the extent
information contained therein is not subject to exemptions in the Act.

If you have any further questions, please call me at (646) 428-3888.

                                              Sincerely,

                                              /s/
                                              Daniel P. Schultz
                                              Regional Inspector General
                                                for Audit



Attachments
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                                                                                                 Attachment A

                                   ED Grants Received by TFA
                             October 1, 2003 through September 30 2005

                                                                                   TFA Proposed Use of
                         TFA Project             Award              Grant
    Grant Number                                                                         Funds
                              No.                Period             Award
                          If Existed 3
    Discretionary
       Grants
                                                                                   Expanding TFA impact:
                                                                                  increasing the number of
                                               10/01/03-
    U215U030014            No Project                             $2,000,000       highly qualified teachers
                            Number              9/30/04
                                                                                    in our nation’s highest-
                                                                                          need schools
                                                                                      Enhancing the pre-
                                                                                      service professional
                                               10/01/03-
    U215U030034            No Project                              2,000,000      training for TFA teachers
                            Number              9/30/04
                                                                                    in our nation’s highest-
                                                                                          need schools
                                                                                         Enhancing the
                          Project No.          10/01/04-                                recruitment and
    U215U040025          38-900-04-006
                                                                   2,000,000
                                                9/30/05                            professional training for
                                                                                         TFA teachers
     Discretionary
                                                                  $6,000,000
         Total
    Earmarks
                           No Project          08/03/04-
    U215K040231             Number
                                                                  $1,988,200      Building TFA’s capacity
                                               08/02/05
                                                                                    Building capacity to
                          Project No.          08/22/05-
    U215K050481          38-900-05-002
                                                                     992,000       maximize effectiveness
                                               08/21/06
                                                                                      for TFA teachers
                                                                                  Expanding TFA’s impact
                                               08/22/05-                            in the Clark County
    U215K050483           Project No.                                248,000
                         38-138-05-003         08/21/06                            School District in Las
                                                                                         Vegas, NV
      Earmarks                                                    $3,228,200
         Total
    Total                                                         $9,228,200




3
 These project numbers were assigned by TFA to track and monitor Federal expenditures in the TFA accounting
system and general ledger. Out of the three discretionary grants reviewed, only one had a project number assigned
for the purpose outlined above.
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                                                        Attachment B
                     TFA Comments on the Draft Report
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