oversight

Review of Final Expenditures Under the American Recovery and Reinvestment Act for Selected Educational Agencies

Published by the Department of Education, Office of Inspector General on 2013-07-08.

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

                                      UNITED STATES DEPARTMENT OF EDUCATION
                                                           OFFICE OF INSPECTOR GENERAL

                                                                                                                       AUDIT SERVICES
                                                                                                                      Atlanta Audit Region


                                                                   July 8, 2013


                                                                                                                    Control Number
                                                                                                                    ED-OIG/A04M0001


Deborah S. Delisle
Assistant Secretary
Office of Elementary and Secondary Education
U.S. Department of Education
400 Maryland Avenue, S.W.
Washington, DC 20202

Michael K. Yudin
Acting Assistant Secretary
Office of Special Education and Rehabilitative Services
U.S. Department of Education
400 Maryland Avenue, S.W.
Washington, DC 20202

Ann Whalen
Director, Policy and Program Implementation
Implementation and Support Unit
U.S. Department of Education
400 Maryland Avenue, S.W.
Washington, DC 20202


Dear Ms. Delisle, Mr. Yudin, and Ms. Whalen:

This final audit report, “Review of Final Expenditures Under the American Recovery and
Reinvestment Act for Selected Educational Agencies,” presents the results of our audit. The purpose
of our audit was to determine whether selected local educational agencies (LEAs) obligated and spent
final American Recovery and Reinvestment Act of 2009 (Public Law 111-5) (Recovery Act) funding
on reasonable, allocable, and allowable activities in accordance with program requirements.

Our review covered January 1 through December 31, 2011, for the following Recovery Act programs:
Title I, Part A, of the Elementary and Secondary Education Act of 1965 (Title I); Individuals with
Disabilities Education Act, Part B, Special Education Grants to States (IDEA); and State Fiscal
Stabilization Fund, Education Stabilization Fund (ESF).

We performed our review at Puerto Rico Department of Education (Puerto Rico) and four State
educational agencies (SEAs)—Arkansas Department of Education (Arkansas), Delaware Department
    The Department of Education's mission is to promote student achievement and preparation for global competitiveness by fostering educational
                                                      excellence and ensuring equal access.
Final Report
ED-OIG/A04M0001                                                                                           Page 2 of 14

of Education (Delaware), Florida Department of Education (Florida), and Nebraska Department of
Education (Nebraska). In addition, we reviewed a total of nine LEAs: Puerto Rico 1 and two LEAs in
each State—El Dorado Public Schools (El Dorado) and Little Rock School District (Little Rock) in
Arkansas, Christina School District (Christina) and Red Clay Consolidated School District (Red Clay)
in Delaware, Broward County Public Schools (Broward) and Miami-Dade County Public Schools
(Miami-Dade) in Florida, and Omaha Public Schools (Omaha) and Millard Public Schools (Millard) in
Nebraska. 2



                                                BACKGROUND


The Recovery Act was signed into law on February 17, 2009, with the overall goals of stimulating the
economy in the short term and investing in education and other public services to ensure the long-term
economic health of our nation. Education-related Recovery Act funding was provided to States, U.S.
territories, and other entities. The funds were to be distributed as quickly as possible to save and create
jobs to improve education, invested as transparently as possible to measure the impact in the
classroom, and subjected to strict requirements for reporting how the money was spent. As of
September 30, 2010, the U.S. Department of Education (Department) had awarded its entire $97.4
billion appropriation.

Closeout of Recovery Act Grants

Grantees and subgrantees were required to obligate 3 Recovery Act funds (Title I, IDEA, and ESF) by
September 30, 2011, and liquidate (or make final payment on) them within 90 days. After the 90 days,
the funds were no longer accessible unless the grantee submitted a late liquidation request to the
Department and the Department approved the request. On September 21, 2011, the Department
invited SEAs to request a waiver, if needed, to extend the obligation period for Recovery Act Title I
funds for an additional year. 4 Therefore, if a State or LEA received a Recovery Act Title I waiver, it
had to obligate the Recovery Act Title I funds by September 30, 2012, and liquidate them within
90 days. Of the SEAs we reviewed, all but Arkansas received the waiver for Recovery Act Title I
funds. The Department did not have the authority to extend the waiver option to the IDEA or ESF
programs.




1
  Puerto Rico Department of Education is a unitary system that serves as both an SEA and an LEA. It is the only LEA in
Puerto Rico.
2
  The methodology used to select the States and LEAs for review is detailed in the Scope and Methodology section of this
report. Although the results of our review is not projected to all States and LEAs, the findings identified provide an
indication of what the Department may find in its monitoring of Recovery Act grants.
3
  Funds are considered obligated when a recipient places an order, awards a contract or subgrant, receives goods or
services, or performs similar transactions during a given period, which the recipient must pay for during the same or a
future period (Title 34, Code of Federal Regulations, Section 80.3).
4
  The waiver invitation included the FY 2009 funding for State-administered formula grant programs authorized under the
Elementary and Secondary Education Act of 1965, as amended.
Final Report
ED-OIG/A04M0001                                                                                       Page 3 of 14

Recovery Act Funding

As shown in Table 1, the Department awarded recipients $60.9 billion across the three Recovery Act
grants included in our review.

               Table 1: Department of Education Recovery Act Awards
                       Awarding              Grant     Amount Awarded
                         Office              Name         (in billions)
             Office of Elementary and
                                             Title I                  $9.9
             Secondary Education
             Office of Special Education
                                             IDEA                    $11.3
             and Rehabilitative Services
             Implementation and Support
                                              ESF                    $39.7
             Unit
             Total                                                   $60.9

The five SEAs included in our review were awarded a total of $1.1 billion for Title I, $956 million for
IDEA, and $3.4 billion for ESF. Table 2 provides a breakdown of the Recovery Act program funds
awarded to each of the entities reviewed.

                 Table 2: Recovery Act Award Amounts Granted to
                          the Five SEAs Reviewed (in millions)
              SEA Name             Title I      IDEA           ESF
              Arkansas                $111.1         $112.2       $363.1
              Delaware                  $32.4         $32.7       $110.3
              Florida                 $490.6         $627.3     $2,208.8
              Nebraska                  $47.8         $74.7       $234.0
              Puerto Rico             $386.4         $109.1       $529.7
              Total                 $1,068.3         $956.0     $3,445.9

Attachment 2 of this report provides details of the Recovery Act funds awarded to the nine LEAs
included in our review. Of the $1.8 billion in Recovery Act Title I, IDEA, and ESF funds awarded to
the LEAs covered by our review, three of the LEAs had a total of $128,927 of unspent Recovery Act
funds as of the end of the grant liquidation periods. 5 To gain access to the unspent funds through the
Department’s Grant Administration and Payment System, the respective SEAs must submit a late
liquidation request to the Department and the Department has to approve the request. In addition, three
LEAs with Title I waivers had Recovery Act Title I funds remaining as of December 31, 2011.
Specifically, Puerto Rico had a remaining balance of $64,736,987, Omaha had $3,597,962, and
Christina had $205,226. These three LEAs had to obligate the funds by September 30, 2012, and
liquidate them within 90 days. The remaining four LEAs (Little Rock, Red Clay, Miami-Dade, and
Millard) had spent all of their Recovery Act funds by the end of the grant liquidation periods.




5
 Of the total $128,927 of unspent Recovery Act funds, El Dorado had $66, Puerto Rico had $114,873, and Broward had
$13,988 in unspent Recovery Act funds.
Final Report
ED-OIG/A04M0001                                                                           Page 4 of 14


                                        AUDIT RESULTS


Our review at the nine LEAs did not identify any evidence that the LEAs used Recovery Act funds in
an inappropriate or wasteful manner to avoid lapsing the funds. We found that for the three programs
in our scope (Title I, IDEA, and ESF), the LEAs generally obligated and spent Recovery Act funds in
accordance with applicable laws, regulations, guidance, and program requirements.

However, we identified a few instances in which LEAs paid for obligations they made after the
obligation deadline. We also identified unallowable expenditures at three LEAs—El Dorado,
Christina, and Puerto Rico; fiscal and management control issues at another LEA—Miami-Dade; and
internal control weaknesses at two LEAs—Little Rock and Puerto Rico. We issued separate reports to
those LEAs’ respective SEAs (Delaware, Arkansas, Puerto Rico, and Florida) providing details on the
issues identified, along with specific recommendations. Attachment 3 of this report provides the audit
control numbers for the individual audit reports and summarizes the questioned costs related to these
issues.

We provided a draft of this report to the Department’s Office of Elementary and Secondary Education,
Office of Special Education and Rehabilitative Services, and Implementation and Support Unit.
Because this report contains no formal recommendations, the Department was not required to comment
on the draft report, and none of the offices commented. Based on Florida’s response to a separate draft
audit report issued in January 2013, we removed an issue related to computer inventory from this
report.

Payments on Late Obligations

We found that two LEAs paid for obligations that were incurred after the obligation deadline (end of
grant period). One of the instances (from El Dorado) was an obligation that was less than $1,000,
which we consider an immaterial amount. However, one LEA, Christina, paid $41,184 in ESF funds
for personnel services incurred between October 21, 2011, and December 3, 2011. The Department’s
“SFSF Closeout and Late Liquidation” guidelines published in August 2011 state that all State Fiscal
Stabilization Fund money must have been obligated by September 30, 2011. In addition, according to
Title 34, Code of Federal Regulations, Section 76.707 (34 C.F.R. § 76.707), for personal services by an
employee of the State or subgrantee, the grantee obligates the funds when the employee performs the
services.

Unallowable Expenditures

We found that two of the nine LEAs reviewed spent funds on unallowable costs. Specifically, Puerto
Rico spent $14,303 in Recovery Act Title I funds and El Dorado spent $237,302 in ESF funds on
unallowable costs such as professional services, equipment, and construction.

Puerto Rico. Puerto Rico improperly paid $14,303 of Title I Recovery Act funds, which included an
overpayment of $7,000 to the University of Puerto Rico for professional services billed incorrectly and
$7,303 to PMB School Office Solutions in excess of the quoted price for a copier. The purchase order
for the copier was processed by one of the Puerto Rico purchasing officers indicted by a Federal grand
Final Report
ED-OIG/A04M0001                                                                              Page 5 of 14

jury in September 2011 on charges of conspiracy to commit bribery concerning programs receiving
Federal education funds. According to 34 C.F.R. § 76.702, States and subgrantees must use fiscal
control and fund accounting procedures that ensure proper disbursement of and accounting for Federal
funds.

El Dorado. During the 2011–2012 school year, El Dorado spent a total of $237,302 of
ESF funds, representing about 6 percent of its ESF grant, to replace a gym roof at a high school that
was no longer being used to educate children. Section 14003(b) of the Recovery Act states that an
LEA may not use ESF funds to improve stand-alone facilities if the purpose is not to educate children,
including buildings for central office administration, operations, or logistical support.

Fiscal and Management Control Issues

We found that Miami-Dade did not perform due diligence when reviewing a transaction which resulted
in an improperly classified Title I expenditure. Specifically, Miami-Dade miscoded a journal entry
that transferred $400,482 of transportation costs from the general fund into Recovery Act Title I funds.
The journal entry was coded as supplies when it should have been coded as transportation costs.

We also found that although Miami-Dade reconciled the Recovery Act Title I and IDEA funds for the
overall grant period of April 30, 2009, to December 31, 2011, it could not reconcile Recovery Act
Title I and IDEA expenditures for our audit period (January 1, 2011, through December 31, 2011). As
a result, we were unable to determine whether quarterly expenditure reports provided to Florida and
ultimately to the Recovery Act Web site, FederalReporting.gov, were complete and accurate, as
required in Section 1512 (c) of the Recovery Act.

According to 34 C.F.R. § 76.702, States and LEAs must use fiscal control and fund accounting
procedures to ensure Federal funds are properly disbursed and accounted for. In addition, according to
34 C.F.R. § 76.730, records related to grant funds maintained by States and subgrantees should fully
show the amount of funds under the grant or subgrant, how the State or subgrantee used the funds, total
cost of the project, the share of that cost provided from other sources, and other records to facilitate an
effective audit.

Internal Control Weaknesses

We identified internal control weaknesses over inventory and procurement at two of the nine LEAs
reviewed—Little Rock and Puerto Rico.

Little Rock. In September 2011, Little Rock used almost $196,000 of Recovery Act Title I, IDEA,
and ESF funds to purchase technology items and partitions. Although the items qualified as fixed
assets, Little Rock did not record those items in the fixed asset system for more than 5 months after it
received the assets. According to Little Rock’s policy, the schools receiving the items were
responsible for providing the inventory information to the Procurement department, but they did not do
so in a timely manner. Additionally, the Procurement department did not follow up with the schools in
a timely manner to make sure the assets were properly accounted for and recorded in the fixed asset
system. Under 34 C.F.R. § 80.20, States and school districts are required to maintain effective control
and accountability for all grant assets.
Final Report
ED-OIG/A04M0001                                                                              Page 6 of 14

Puerto Rico. Puerto Rico’s Central Procurement Office did not follow Puerto Rico’s procurement
policies and procedures. Specifically, it did not have adequate documentation to support that the
lowest and best offer was obtained and the required number of quotes was received for four purchases
made with Recovery Act Title I funds and one purchase made with Recovery Act IDEA, totaling more
than $3.4 million. In September 2011, Puerto Rico’s former chief procurement officer 6 and five
additional Puerto Rico officials, including the purchasing officer that processed the five purchases
mentioned above, were indicted by a Federal grand jury on multiple charges related to their
procurement activities. In addition, in September 2011, Puerto Rico acquired 6,125 tablet computers at
a total cost of $3.5 million in Title I Recovery Act funds but did not install the software required to use
the tablets for their intended purpose. As of September 2012, almost a year after acquiring the tablets,
Puerto Rico was still in the process of procuring the software; as a result, the teachers and students
were not able to use the tablets for their intended purpose. According to 34 C.F.R. § 80.32(b) and (c),
“A State will use, manage, and dispose of equipment acquired under a grant by the State in accordance
with State laws and procedures,” and other grantees and subgrantees will use the equipment “in the
program or project for which it was acquired as long as needed….”

We suggest that the Assistant Secretary for Office of Elementary and Secondary Education, the
Assistant Secretary for Office of Special Education and Rehabilitative Services, and the Director of
Implementation and Support Unit evaluate, to the extent not already covered by their current processes,
the issues identified in our audit when planning and conducting future monitoring and grant closeout
processes.



                                        OTHER MATTERS


Puerto Rico had $35.3 million of Recovery Act Title I funds remaining as of September 30, 2012 (end
of the obligation period). This significant remaining balance raises concerns about Puerto Rico’s
ability to liquidate its remaining funds on allowable costs that were obligated before the end of the
grant period. Further, other States that received waivers may also have large balances. Therefore, we
suggest that the Assistant Secretary for the Office of Elementary and Secondary Education consider
following up with States that had large balances to spend at the end of the waiver period to determine
whether the funds were spent on allowable costs and were obligated by the end of the obligation
period.




                                 SCOPE AND METHODOLOGY


The purpose of our audit was to determine whether selected LEAs obligated and spent final Recovery
Act funding on reasonable, allocable, and allowable activities in accordance with program
requirements. Our review covered January 1 through December 31, 2011, and Recovery Act
expenditures for three education-related grants: Title I, IDEA, and ESF. We performed this audit from
March 29, 2012, through July 19, 2012, at Puerto Rico, four SEAs (Arkansas, Delaware, Florida, and
6
    Resigned in December 2010.
Final Report
ED-OIG/A04M0001                                                                            Page 7 of 14

Nebraska), and nine LEAs (El Dorado, Little Rock, Christina, Red Clay, Broward, Miami-Dade,
Omaha, Millard, and Puerto Rico (both a SEA and a LEA). For the dates of onsite visits and exit
conferences for each of the entities reviewed, see Attachment 4 of this report.

In selecting entities at which to perform our work, we considered factors such as percentage of
Recovery Act funds remaining as of December 31, 2010, percentage point change in cumulative funds
balance for the three grants (Title I, IDEA, and ESF) for two to four periods after December 31, 2010,
previous Recovery Act audit coverage by the Department’s Office of Inspector General and Single
audits, complaints and investigations, concerns expressed by the Department’s program offices
managing the three grants, and size of Recovery Act awards.

To gain an understanding of the Recovery Act requirements applicable to the grants, the areas of use of
funds, and the closeout of Recovery Act grants, we obtained background and funding information
about the grants and organizations being audited and reviewed; Federal laws, regulations, Office of
Management and Budget Circulars and Recovery Act guidance; and Recovery Act and closeout
guidance issued by the Department. We also interviewed key officials at the Office of Elementary and
Secondary Education, Office of Special Education and Rehabilitative Services, and the Implementation
and Support Unit. To gain an understanding of the entities reviewed, we examined their prior audits
and reviews. In addition, for the entities reviewed, we obtained and reviewed policies and procedures
pertaining to their administration of the Recovery Act programs; interviewed key officials regarding
Recovery Act funding methodology, awards, disbursements, waivers, closeout procedures, and
monitoring; and interviewed officials at other State agencies responsible for previous audits.

We performed a limited assessment of the nine LEAs’ use of funds by examining judgmentally
selected samples of expenditure transactions made by each district from January 1 through
December 31, 2011, for personnel expenditures and from July 1 through December 31, 2011, for
nonpersonnel expenditures. The purpose was to determine whether the costs charged to Recovery Act
grants were reasonable, allocable to the Recovery Act programs charged, and complied with applicable
Federal requirements. Using a risk-based approach, we selected nonpersonnel transactions that
exceeded local LEA guidelines or thresholds, transactions that exceeded the average category amount
by three standard deviations, transactions under but within 10 percent of local LEA guidelines or
thresholds, transactions that were larger than average category transactions and that took place in the
final month of fund availability, transactions with specific keywords in expenditure or vendor
descriptions, and transactions that fell into other risk categories unique to the LEA being reviewed.
We selected personnel transactions based on months with spikes in Recovery Act expenditures, large
dollar amounts, number of transactions, and the importance of the transaction.

At the nine LEAs reviewed, we examined a total of $64,005,451.05 of Recovery Act expenditures
(Title I, IDEA, and ESF), from a total of $344,386,626.10, representing nearly 19 percent of total
expenditures. Because we used a risk-based approach in judgmentally selecting samples, the results
presented in this report cannot be projected to the universe of expenditures for the period covered by
our testing. For a detailed breakdown of the universe and sampled expenditures, see Attachment 5 to
this report.

We relied on computer-processed data contained in the nine LEAs’ accounting systems for purposes of
determining Recovery Act grant award, revenue, and expenditure data. We reconciled the districts’
Recovery Act grant amounts, revenue, and expenditure data with data that the SEAs maintained.
Final Report
ED-OIG/A04M0001                                                                             Page 8 of 14

Based on this reconciliation and the results of our tests of samples of expenditure data, we determined
that the computer-processed data were sufficiently reliable for the purposes of our review.

We conducted this performance audit in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit objective.
We believe that the evidence obtained provides a reasonable basis for our findings and conclusions
based on our audit objective.




                               ADMINISTRATIVE MATTERS


This report does not require a corrective action plan. An electronic copy of this report has been
provided to your audit liaison officer. 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.

We appreciate the cooperation and assistance extended by your staff during the audit. If you have any
questions, please contact Denise Wempe, Regional Inspector General at denise.wempe@ed.gov or
(404) 974-9416.


                                             Sincerely,

                                             /s/
                                             Patrick J. Howard
                                             Assistant Inspector General for Audit

Attachments
Final Report
ED-OIG/A04M0001                                                                         Page 9 of 14

                                                                                     Attachment 1

              Abbreviations, Acronyms, and Short Forms Used in the Report



Arkansas             Arkansas Department of Education

Broward              Broward County Public Schools

C.F.R.               Code of Federal Regulations

Christina            Christina School District

Delaware             Delaware Department of Education

Department           U.S. Department of Education

El Dorado            El Dorado Public Schools

ESF                  State Fiscal Stabilization Fund, Education Stabilization Fund

Florida              Florida Department of Education

IDEA                 Individuals with Disabilities Education Act, Part B, Special Education
                     Grants to States

LEA                  Local Educational Agency

Little Rock          Little Rock School District

Miami-Dade           Miami-Dade County Public Schools

Millard              Millard Public Schools

Nebraska             Nebraska Department of Education

Omaha                Omaha Public Schools

Puerto Rico          Puerto Rico Department of Education

Recovery Act         American Recovery and Reinvestment Act of 2009
Final Report
ED-OIG/A04M0001                                                                    Page 10 of 14


Red Clay          Red Clay Consolidated School District

SEA               State Educational Agency

Title I           Title I, Part A, of the Elementary and Secondary Education Act of 1965
Final Report
ED-OIG/A04M0001                                                                                         Page 11 of 14

                                                                                                     Attachment 2

       Recovery Act Award and Expenditure Data for the Nine LEAs Reviewed
                                   Title I     Received                       IDEA                          ESF
                  Title I         Amount       a Title I      IDEA           Amount                        Amount
                                                                                         ESF Amount
LEA Name         Amount          Not Spent     Waivera       Amount         Not Spent                     Not Spent
                                                                                          Awarded
                 Awarded           as of        From         Awarded           as of                        as of
                                 12/31/11        SEA                        12/31/11                      12/31/11
El Dorado        $1,523,640              $66      No           $1,120,781            -      $3,969,657             -
Little Rock      $7,549,743                -      No           $6,028,310            -     $22,717,522             -
Christina        $5,761,375        $205,226      Yes           $4,945,517            -     $13,026,628             -
Red Clay         $4,298,174                -      No           $4,189,223            -     $10,801,128             -
Broward         $49,751,800                -     Yes          $62,500,333            -   $181,100,656       $13,988
Miami-Dade      $99,027,779                -     Yes          $89,162,412            -   $239,713,997              -
Omaha           $21,072,485      $3,597,962      Yes          $13,355,676            -     $46,277,465             -
Millard          $1,004,809                -     Yes           $5,048,961            -     $18,643,084             -
Puerto Rico    $386,407,681     $64,736,987      Yes         $109,098,472         $289   $404,245,489      $114,584
Total          $576,397,486                                  $295,458,685                $935,024,486
Amount
Awarded
a
  LEAs with Recovery Act Title I waivers had to obligate the funds by September 30, 2012, and liquidate them within
90 days.

The nine LEAs included in our review received a total of $1,806,880,657
($576,397,486 + $295,458,685 + $935,024,486) in Recovery Act Title I, IDEA, and ESF funds.
Final Report
ED-OIG/A04M0001                                                               Page 12 of 14

                                                                            Attachment 3

Audit Control Numbers for the Individual Audit Reports Issued to the SEAs and
Summary of Questioned Costs

                   Table A: Audit Control Numbers for Issued Audit Reports
     SEA Name            Audit Control Number for Issued            Date Report
                                   Audit Report                       Issued
     Arkansas                  ED-OIG/A09M0003                  December 20, 2012
     Delaware                  ED-OIG/A03M0005                  December 19, 2012
     Florida                   ED-OIG/A02M0009                     June 27, 2013
     Nebraska                     No report issued                       ---
     Puerto Rico               ED-OIG/A04M0014                   February 20, 2013

                          Table B: Summary of Questioned Costs
                                                                             Name of
                      Recovery Act
                                          Amount of                           SEA to
                    Program in Which                      Category of
      LEA Name                            Questioned                        Which We
                     Questioned Cost                       Finding
                                            Cost                            Issued the
                      Was Identified
                                                                           Audit Report
     El Dorado             ESF             $237,302     Noneducational       Arkansas
                                                           Building
                                                           Expense
     Christina             ESF              $41,184     Obligation After    Delaware
                                                         Grant Period
     Puerto Rico          Title I           $14,303        Contract        Puerto Rico
                                                         Overpayment
Final Report
ED-OIG/A04M0001                                                              Page 13 of 14

                                                                           Attachment 4

Dates of Onsite Visits and Exit Conferences for Each of the Entities Reviewed

      SEA        Dates of SEA     Dates of LEA 1    Dates of LEA 2    Exit Conference
                     Visit              Visit             Visit             Date
Puerto Rico     3/29/12–7/19/12          N/A              N/A            7/19/2012
                                     Little Rock       El Dorado        SEA 6/18/12
Arkansas       4/17/12–4/20/12    4/16/21–4/20/12    5/1/12–5/4/12     LEA 1 6/8/12
                                                                       LEA 2 6/8/12
                                      Red Clay          Christina       SEA 7/16/12
                                  4/23/12–4/27/12    4/30/12–5/4/12    LEA 1 6/22/12
Delaware       4/10/12–4/12/12
                                          &                &           LEA 2 7/9/12
                                       5/23/12      5/21/12–5/22/12
                                      Broward         Miami Dade       SEA 10/15/12
                                   5/7/12–5/11/12    4/30/12–5/4/12    LEA 1 8/2/12
Florida        4/9/12–4/13/12
                                                           &          LEA 2 10/15/12
                                                    5/21/12–5/25/12
                                  Omaha Public       Millard Public    SEA 7/20/12
Nebraska       4/9/12–4/13/12     5/7/12–5/11/12    4/23/12–4/27/12   LEA 1 7/12/12
                                                                      LEA 2 7/12/12
         Final Report
         ED-OIG/A04M0001                                                                                          Page 14 of 14

                                                                                                            Attachment 5

                                     Sampling Details for the Nine LEAs Reviewed


                                Title I         Title I           IDEA            IDEA               ESF                ESF
                             Amount of        Amount of         Amount of       Amount of         Amount of          Amount of
                            Expenditures     Expenditures     Expenditures     Expenditures     Expenditures in     Expenditures
              Expenditure    in Universe      in Sample        in Universe      in Sample          Universe          in Sample
   LEA           Type
El Dorado    Personnel          $38,751.50        $4,148.09                -                -                 -                    -
El Dorado    Nonpersonnel       $62,718.12      $13,398.07      $312,939.38      $155,893.31      $2,493,886.46       $820,746.59
Little
Rock         Personnel       $1,435,380.74        $8,176.63     $657,482.00                 -     $1,455,832.21                    -
Little
Rock         Nonpersonnel    $1,973,241.00     $145,794.00     $3,121,134.00     $649,282.00      $5,934,415.00     $1,603,932.00
Christina    Personnel         $371,398.65      $32,985.02      $909,140.56       $54,687.00      $1,082,605.17       $130,586.97
Christina    Nonpersonnel      $667,717.45     $313,283.32     $1,599,097.66     $796,436.28        $879,059.18       $402,163.93
Red Clay     Personnel         $701,580.68      $16,423.51     $1,465,199.00      $68,241.47      $4,938,084.40     $2,491,826.84
Red Clay     Nonpersonnel      $174,198.88     $171,874.23      $584,522.00      $236,996.18        $113,209.31        $91,184.00
Broward      Personnel      $16,260,525.28     $183,299.26     $8,855,849.95     $404,584.33     $46,077,926.28       $276,966.28
Broward      Nonpersonnel    $5,512,822.33    $2,836,963.00     $257,390.01       $93,486.00        $342,536.09        $80,643.38
Miami-
Dade         Personnel      $25,023,860.33     $214,110.90    $7,108,570.14       $87,387.90    $56,034,109.97       $294,087.26
Miami-
Dade         Nonpersonnel    $7,065,482.78   $3,868,938.81    $1,791,973.90    $1,091,463.07                 -                     -
Omaha        Personnel       $4,582,532.34      $51,750.71     $2,787,591.15      $19,066.40     $10,438,343.76       $124,397.37
Omaha        Nonpersonnel    $1,635,891.25      $95,189.32      $475,592.00      $161,298.45      $7,416,446.00     $3,321,567.97
Millard      Personnel         $268,873.83      $62,678.55     $1,988,918.28     $134,719.80      $6,560,943.67        $62,194.90
Millard      Nonpersonnel       $28,969.61        $5,597.00    $1,177,634.24     $547,455.00      $4,972,828.07     $2,471,847.00
Puerto
Rico         Personnel       $1,527,863.02      $20,448.45    $21,687,449.47    $6,414,194.71    $32,164,447.88     $2,430,943.48
Puerto
Rico         Nonpersonnel   $11,224,362.61   $10,741,394.31   $16,892,193.06    $7,337,881.00    $13,253,105.45    $12,362,837.00
            Total           $78,556,170.40   $18,786,453.18   $71,672,676.80   $18,253,072.90   $194,157,778.90    $26,965,924.97


         The total amount of expenditures in universes for all nine LEAs across all three Recovery Act
         programs is $344,386,626.10. The total amount of expenditures sampled for all nine LEAs across all
         three Recovery Act programs is $64,005,451.05.