oversight

Audit of the Department's Oversight of the Rural Education Achievement Program

Published by the Department of Education, Office of Inspector General on 2016-09-12.

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

                            UNITED STATES DEPARTMENT OF EDUCATION
                                           OFFICE OF INSPECTOR GENERAL

                                                                                                              AUDIT SERVICES


                                                  September 12, 2016
                                                                                                       Control Number
                                                                                                       ED-OIG/A19P0006

Ann Whalen
Delegated to Perform Functions and Duties of the Assistant Secretary
Office of Elementary and Secondary Education
U.S. Department of Education
400 Maryland Avenue, S.W.
Washington, DC 20202-4300

Matt Lehrich
Delegated to Perform Functions and Duties of the Assistant Secretary
Office of Communications and Outreach
U.S. Department of Education
400 Maryland Avenue, S.W.
Washington, DC 20202-4300

Dear Ms. Whalen and Mr. Lehrich:

This final audit report, titled Audit of the Department’s Oversight of the Rural Education
Achievement Program, presents the results of our audit. The objectives of our audit were to
(1) determine whether the Department of Education (Department) adequately monitored
grantees’ performance and use of funds, and (2) assess the effectiveness of coordination efforts
both within the Department and with other Federal agencies involved in rural education.


                                                  BACKGROUND


The No Child Left Behind (NCLB) Act of 2002, which reauthorized the Elementary and
Secondary Education Act (ESEA) of 1965, contains Rural Education Achievement Program
(REAP) initiatives designed to help rural districts that may lack the personnel and resources to
compete effectively for Federal competitive grants and that often receive grant allocations in
amounts that are too small to be effective in meeting their intended purposes. 1 REAP consists of

1
 The ESEA was recently reauthorized by the Every Student Succeeds Act (ESSA), signed into law on
December 10, 2015. ESSA retained the REAP initiatives but changed some of the activities for which REAP funds
were authorized to be used under NCLB. It also changed other requirements under NCLB that were applicable to
REAP, which are noted where warranted in applicable sections of this report.
                                400 MARYLAND AVENUE, S.W., WASHINGTON, DC 20202-1510

                Promoting the efficiency, effectiveness, and integrity of the Department’s programs and operations.
Final Audit Report
ED-OIG/A19P0006                                                                                       Page 2 of 21

two separate grant programs: the Small, Rural School Achievement (SRSA) program and the
Rural and Low-Income School (RLIS) program. The SRSA program provides funds to rural
local educational agencies (LEA) that serve small numbers of students, while the RLIS program
provides funds to rural LEAs that serve high concentrations of poor students, regardless of the
LEA’s size.

The Department awards SRSA funds to participating LEAs on a formula basis. 2 LEAs must
apply to the Department to receive an SRSA grant award. Funds received under the program
may be used for any authorized activities under certain Federal grant programs. 3 The
Department awards RLIS funds by formula to State Education Agencies (SEA) based on their
proportionate share of children in average daily attendance in all LEAs eligible to participate in
the RLIS program. SEAs then make subgrants to eligible LEAs, either by formula or
competitively. Eligibility is based on the percentage of children served by the LEA that are from
families with incomes below the poverty line and the school locale code. 4 An LEA is not
eligible to participate in the RLIS program if it is eligible to participate in the SRSA program.
LEAs may use RLIS funds for: 5

    1. Teacher recruitment and retention;
    2. Teacher professional development;
    3. Educational technology that meets the requirements of Part D of Title II;
    4. Parental involvement activities;
    5. Activities authorized under the Safe and Drug-Free Schools and Communities State
       Grants program;
    6. Activities authorized under Part A of Title I; and
    7. Activities authorized under Title III.

SEAs that receive RLIS grants must annually submit a report to the Department that describes:
(1) the method the SEA used to award funds; (2) how LEAs and schools used RLIS funds; and
(3) the degree of progress made by the State toward meeting its goals and objectives.



2
  An LEA is eligible for an award if:
     • The total number of students in average daily attendance at all of the schools served by the LEA is fewer
         than 600, or each county in which a school served by the LEA is located has a total population density of
         fewer than 10 persons per square mile; and
     • All of the schools served by the LEA are designated with a school locale code of 7 (rural) or 8 (rural near
         an urban area) by the Department’s National Center for Education Statistics, or the Secretary has
         determined, based on a demonstration by the LEA and concurrence by SEA, that the LEA is located in an
         area defined as rural by a governmental agency of the State.
3
  These are: (1) Part A of Title I (Improving the Academic Achievement of the Disadvantaged); (2) Part A of Title II
(Improving Teacher Quality State Grants); (3) Part D of Title II (Educational Technology State Grants); (4) Title III
(Language Instruction for Limited English Proficient and Immigrant Students); (5) Part A of Title IV (Safe and
Drug-Free Schools and Communities); (6) Part B of Title IV (21st Century Community Learning Centers); and
(7) Part A of Title V (State Grants for Innovative Programs).
4
  LEAs are eligible if 20 percent or more of the children aged 5 to 17 served by the LEA are from families with
incomes below the poverty line and all schools have a school locale code of 6 (small town), 7, or 8 (as assigned by
the National Center for Education Statistics).
5
  Under the ESSA, authorized activities under the SRSA program no longer include Part D of Title II (Educational
Technology State Grants) or Part A of Title V (State Grants for Innovative Programs). Authorized activities under
the RLIS program have been changed to more closely align with the SRSA program, except funds cannot be used
toward authorized activities under Part B of Title IV (21st Century Community Learning Centers).
Final Audit Report
ED-OIG/A19P0006                                                                                       Page 3 of 21

Under the ESEA, LEAs that participated in either of the REAP programs were required to
administer an annual assessment which was used by the SEA to determine whether the LEA met
the State’s definition of adequate yearly progress (AYP). 6 LEAs that failed to make AYP after
the third year of participation were required to use the funds to carry out school improvement
activities under Section 1116 of the ESEA. 7 For States that received ESEA flexibility waivers,
LEAs could use the funds for any authorized purpose regardless of their AYP status. 8

The Office of School Support and Rural Programs (SSRP), within the Office of Elementary and
Secondary Education (OESE), is responsible for administering and overseeing the REAP.
Applicable funding information is provided in Table 1 below.

                                          Table 1 – REAP Funding
    Fiscal Year      Total REAP           Number of      Average                  Number of          Average
                      Funding 9             SRSA       SRSA Award                   RLIS            RLIS Award
                                           Grantees                                Grantees
       2011         $174,532,236            4,205        $20,753                      43             $2,029,445
       2012         $179,192,684            4,302        $20,827                      44             $2,036,281
       2013         $169,840,000            4,307        $19,717                      45             $1,887,111
       2014         $169,840,000            4,276        $19,860                      44             $1,930,000
       2015         $169,840,000            4,269        $19,892                      43             $1,974,884

In 2009, the Deputy Assistant Secretary (DAS) for Rural Outreach position was created in the
Office of Communications and Outreach (OCO) to serve as the Department’s primary liaison to
education stakeholders in rural and small communities and the organizations that represent them.
The DAS for Rural Outreach also takes the lead on or is involved with the Department’s rural
education coordination efforts.




6
  While ESSA eliminated the AYP requirements, States are still required to develop an accountability system for all
public schools and LEAs that includes challenging academic standards and to annually measure student progress
toward meeting those standards.
7
  These requirements included identifying for school improvement any elementary and secondary school that failed
to make AYP for 2 consecutive years; providing all students enrolled in the school the option to transfer to another
public school served by the LEA; assisting schools identified in developing or revising a school plan that, among
other things, incorporated strategies that addressed the specific academic issues that caused the school to be
identified for school improvement and described how funds would be used to remove the school from school
improvement status; approving the school plan; and providing technical assistance.
8
  In September 2011, the Department offered each SEA the opportunity to request flexibility on behalf of itself and
its LEAs and schools. This voluntary opportunity provided educators and State and local leaders with flexibility
from certain requirements of the ESEA, as amended by the NCLB, in exchange for rigorous and comprehensive
State-developed plans designed to improve educational outcomes for all students, close achievement gaps, increase
equity, and improve the quality of instruction. Under the ESSA, ESEA flexibility is no longer offered and all
approved ESEA flexibility waivers are null and void as of August 1, 2016.
9
  Total REAP funding is divided equally between the SRSA and RLIS programs each year.
Final Audit Report
ED-OIG/A19P0006                                                                       Page 4 of 21


                                     AUDIT RESULTS


Overall, we found that improvements are needed in SSRP’s monitoring of REAP grantees’
performance and use of funds. However, despite the need for improvements within SSRP, we
concluded that the Department’s rural education coordination efforts appear to be effective.

With regard to objective one, we found that SSRP has conducted very limited monitoring to
determine whether REAP grantees are making progress toward program goals or spending grant
funds in accordance with statutory and regulatory guidelines. Instead, we found that efforts are
focused primarily on ensuring grantees are obligating and spending funds by established
deadlines. Of the approximately 4,300 LEAs that received SRSA grants each fiscal year (FY)
between 2011 and 2014, SSRP produced a total of only 18 desk monitoring reports of 16
grantees. Over the same time period, no monitoring was conducted of any of the approximately
44 RLIS SEAs that received grants each year. We also found that while SSRP developed plans
to monitor REAP grantees’ performance and use of funds for FY 2011 and FY 2012, these
monitoring plans were left in draft form and went largely unimplemented. Monitoring plans for
subsequent years were not developed. Additionally, we noted that while SSRP does collect some
data on grantees’ performance and use of funds, there is little evidence that any of the data is
used to inform monitoring efforts or provide assistance to grantees in meeting program goals,
even though grantees appear to be having difficulty meeting established performance targets.
Without adequate monitoring of grantee progress and use of funds, SSRP has little assurance as
to whether REAP grantees are making progress toward program goals and objectives and little to
no insight regarding what grantees are using grant funds for, thereby significantly decreasing the
likelihood that it will be able to detect any instances where grantees are using funds for
unallowable purposes. Further, with regard to RLIS, SSRP lacks assurance that its grantees—the
SEAs—are conducting required monitoring of their subgrantees to ensure compliance with
applicable Federal requirements, including that funds are being used only for allowable purposes,
and that performance goals are being achieved.

With regard to objective two, we found that the Department is involved in various internal and
external rural education coordination efforts and that these efforts appear to be effective. We
found that the Department has placed a greater emphasis on internal and external rural
coordination activities in the last several years. Internal coordination is largely done through an
inter-Principal Office Component (POC) working group, which was created by the DAS for
Rural Outreach in 2009. Most of the Department’s external coordination with other agencies has
come out of its participation in the White House Rural Council, which was established in 2011.
We also found that the National Center for Education Research (NCER), in the Department’s
Institute of Education Sciences (IES), formed a rural education research technical working group
with experts in the field of rural education to discuss priorities for rural education research
efforts. With effective coordination, the Department has more assurance that it is maximizing its
resources and efforts in the area of rural education and may be able to produce a greater benefit
to the public than it could otherwise achieve on its own.

A draft of this report was provided to OESE and OCO for comment. Each office provided a
response addressing the finding and recommendations specific to their office. In response to
Finding 1, OESE did not disagree with the finding and stated that it strives to continuously
Final Audit Report
ED-OIG/A19P0006                                                                                   Page 5 of 21

improve the operation of the REAP. OESE further noted that it has proactively begun addressing
many of the recommendations included in the draft audit report and provided a Corrective Action
Plan with action steps for addressing each recommendation. In response to Finding 2, OCO
concurred with the finding and noted that it is developing a plan to expand capacity around rural
education engagement and coordination to ensure its rural coordination efforts continue during
the next administration.

OESE’s and OCO’s comments are summarized at the end of the applicable finding. As a result
of the comments, we did not make any changes to the audit findings or the related
recommendations. The full text of OESE’s response is included as Attachment 2 to this report.
The full text of OCO’s response is included as Attachment 3.

Finding 1: SSRP Has Not Adequately Monitored REAP Grantees’
           Performance and Use of Funds
We found that improvements are needed in SSRP’s monitoring of REAP grantees’ performance
and use of funds. SSRP has conducted very limited monitoring to determine whether REAP
grantees are making progress toward program goals or spending grant funds in accordance with
statutory and regulatory guidelines. Additionally, SSRP has not developed or fully implemented
procedures or plans for monitoring grantees’ performance and use of funds. While SSRP does
collect some data on grantees’ performance and use of funds, there is little evidence that any of
the data are used to inform monitoring efforts or provide assistance to grantees in meeting
program goals.

Monitoring Efforts for the REAP Are Limited

We found that SSRP has conducted very limited monitoring of REAP grantees’ performance and
use of funds. Efforts are focused primarily on ensuring grantees are obligating and spending
funds by established deadlines.

For the SRSA program, the primary method for monitoring grantees is desk monitoring. 10 Of
the approximately 4,300 LEAs that received SRSA grants each fiscal year between 2011 and
2014, SSRP produced a total of only 18 desk monitoring reports of 16 grantees. No more than
0.2 percent of all SRSA grantees were monitored in any given fiscal year. In FY 2014, no
monitoring reports were produced. While the desk monitoring reports did include some
information on the grantees’ performance and use of funds, the reports appeared to consist only
of write-ups of what the grantee stated. There were no requests for supporting documentation or
any data verification performed. None of the monitoring reports noted any issues or included
any findings requiring corrective action by the grantee. Further, we did not find any evidence
that A-133 single audit reports 11 of any of these grantees were reviewed to inform monitoring

10
   Desk monitoring involves calling SRSA grantees to interview them about, among other things, the LEAs’ use of
funds (including whether the LEA was required to use funds to carry out school improvement activities under
section 1116 of the ESEA), the LEAs’ overall achievement goals and how REAP supports those goals, and any
technical assistance needs.
11
   Office of Management and Budget (OMB) Circular A-133 required non-Federal entities expending $500,000 or
more in a year in Federal awards to have a single audit completed. This changed recently when OMB released its
Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform
Grant Guidance), which supersedes OMB Circular A-133. The guidance increased the funding threshold for non-
Federal entities requiring a single audit to $750,000 for audits of fiscal years beginning on or after
Final Audit Report
ED-OIG/A19P0006                                                                                       Page 6 of 21

efforts. Of the 16 SRSA grantees that were monitored, we found that 5 (31 percent) had A-133
audits completed within the year prior to being monitored. We noted that one of the audit reports
contained findings pertaining to the REAP as well as other Department programs that SRSA
funds can be used toward, but these findings were not discussed in the related monitoring report.

For the RLIS program, the Department did not conduct desk monitoring, on-site reviews, or
virtual site visits for any of the approximately 44 SEAs that received grants each year between
FYs 2011 and 2014. According to SSRP’s FY 2011 monitoring plan for the RLIS program,
31 virtual site visits 12 of RLIS SEAs had been completed since February 2006. One program
officer (PO) noted that these site visits were conducted over a 2-year period and in coordination
with other Federal programs administered by the Department, however the virtual site visits are
no longer being conducted.

In addition to the monitoring reports, SSRP staff also identified 453 grantee files that contained
technical assistance correspondence from October 2010 to November 2015. 13 We randomly
selected 46 files (10 percent) and reviewed the associated correspondence to determine whether
it would constitute monitoring of performance or use of funds. We determined that the
correspondence consisted primarily of transmittals of Grant Award Notifications, updated
contact information, obligation and liquidation deadlines, links to program information on the
Department website, and questions concerning use of the Department’s electronic grants
management system (G5).

Monitoring Plans Were Not Developed or Implemented

We found that SSRP developed monitoring plans for REAP grantees’ performance and use of
funds for FY 2011 and FY 2012, however no monitoring plans were developed for subsequent
years. We noted that the FY 2011 and 2012 plans were left in draft form and went largely
unimplemented. Specifically, these plans set a goal for the office to conduct desk monitoring of
at least 10 percent of SRSA grantees in FY 2011 and at least 5 percent in FY 2012, and 100
percent of RLIS grantees in each year. However, we found that the monitoring of REAP
grantees fell significantly short of these goals (See Table 2). SSRP monitored just 2 percent and
4 percent of the number of SRSA grantees it set as its goal to monitor in FYs 2011 and 2012,
respectively, and, as previously stated, none of the RLIS grantees. Goals were not established
for FYs 2013 and 2014 because monitoring plans were not developed for these years.




December 26, 2014. Several of the programs SRSA funds can be used toward are covered in the Compliance
Supplement to OMB Circular A-133, and the SRSA program is discussed as well. The Compliance Supplement
makes no note of the RLIS program.
12
   Virtual site visits involve reviews of financial and program documentation provided by the grantee, followed by
videoconference interviews with the State’s financial and program staff.
13
   REAP officials noted that POs provided technical assistance telephonically and in writing via email with grantees.
While some of this information was uploaded into G5, they noted that the G5 files do not capture the bulk of
technical assistance that REAP POs provided to grantees during this time period.
Final Audit Report
ED-OIG/A19P0006                                                                                       Page 7 of 21

                              Table 2 – FYs 2011-2014 REAP Monitoring
           FY                      Program            Monitoring Goal                      Actually Monitored
          2011                       SRSA               421 (10%)                                   8
                                     RLIS                   43                                      0
          2012                       SRSA                215 (5%)                                   8
                                     RLIS                   44                                      0
          2013                       SRSA                                                           2
                                                        No goals set
                                     RLIS                                                           0
          2014                       SRSA                                                           0
                                                        No goals set
                                     RLIS                                                           0

All RLIS grantees were to receive one form of monitoring (desk monitoring, on-site review, or
virtual site visit) depending on the SEA’s number of subgrantees, whether the SEA had received
virtual or on-site monitoring in the past, and the percentage of subgrantees that did not make
AYP. SRSA grantees were to be selected for monitoring based on a number of risk factors, 14 as
well as factors relating to the size of the award. 15 The majority of the SRSA desk monitoring
reports we reviewed (61 percent) indicated that the grantee had been selected for monitoring
because of significant or repeating unspent award balances carried over from previous years. In
comparison, just 2 of the 18 desk monitoring reports (11 percent) indicated the grantee was
selected because the SEA had identified the grantee as having issues, while another 2 grantees
(11 percent) were selected because the grantee had participated in REAP for 3 or more years but
did not make AYP based on data for the most recent year. However, we noted that one of these
two grantees had started making AYP by the time the PO conducted the desk monitoring, and the
other grantee was subsequently determined by the PO to not be in improvement status as the
applicable State had been approved for an ESEA flexibility waiver. 16 Risk indicators relating to
previous monitoring findings, the time since the grantee was last monitored, or the number and
severity of audit findings were not cited in any of the monitoring reports.

In addition, we were unable to determine whether grantees that had failed to make AYP and, as a
result, were in school improvement status were monitored any differently. In the desk
monitoring reports we reviewed, there is a section where a PO notes whether the LEA is in
school improvement status, but the reports do not otherwise provide any indication as to whether
POs would give any additional consideration to the restrictions on a grantee’s use of funds under
those conditions. Further, the draft monitoring plans list no separate or additional procedures for
monitoring grantees in school improvement status.




14
   These included: (1) significant or repeating instances of unspent award balances carried over from previous years;
(2) SRSA grantees that have participated in the program for at least 3 years, but did not make AYP based on data
from the most recent school year; (3) the number of previous monitoring findings; (4) the time since the grantee was
last monitored; (5) grantees identified by their respective SEA as having challenges or performance issues, and (6)
number and severity of audit findings.
15
   These are: (1) grantee has an active SRSA allocation over $8,000 per pupil; and (2) grantee has an active SRSA
award greater than $40,000.
16
   LEAs that received SRSA or RLIS program funds had flexibility to use those funds for any authorized purpose
regardless of the LEA’s AYP status if their State had been approved for an ESEA flexibility waiver.
Final Audit Report
ED-OIG/A19P0006                                                                                       Page 8 of 21

Data on Grantees’ Performance and Use of Funds is Not Used for Monitoring Purposes or Not
Collected

We noted that while SSRP does collect some data on grantees’ performance and use of funds,
there is little evidence that it uses any of the data to inform monitoring efforts or provide
assistance to grantees in meeting program goals, even though grantees appear to be having
difficulty meeting established performance targets. Specifically, SSRP collects data on the
SRSA and RLIS performance measures developed under the Government Performance and
Results Act of 1993 (GPRA), 17 as noted in Table 3 below, through eligibility spreadsheets,
Consolidated State Performance Reports (CSPR), and the Department's EDFacts system.

                            Table 3 – GPRA Performance Measures and Goals
                                                      FY         FY         FY         FY         FY         FY
                                                     2011       2011       2012       2012       2013       2013
               Performance Measure
                                                    Target     Actual     Target     Actual     Target     Actual
     The percentage of SRSA LEAs that made
                                                      98%        69%        N/A*      N/A*       N/A*       N/A*
     AYP after 3 years in the program.
     The percentage of RLIS LEAs that made
                                                      94%        31%        N/A*      N/A*       N/A*       N/A*
     AYP after 3 years in the program.
     The percentage of students in SRSA LEAs
     who scored “proficient” or better on State       86%        75%        90%        72%        94%        69%
     assessments in reading or language arts.
     The percentage of students in RLIS LEAs
     who scored “proficient” or better on State       88%        68%        92%        67%        96%        64%
     assessments in reading or language arts.
     The percentage of students in SRSA LEAs
     who scored “proficient” or better on the         86%        71%        91%        68%        96%        65%
     State assessments in mathematics.
     The percentage of students in RLIS LEAs
     who scored “proficient” or better on the         85%        66%        90%        64%        95%        60%
     State assessments in mathematics.
     *The Department last reported on the goals related to AYP in FY 2011 as more than half of the States had been
     approved for ESEA flexibility waivers since then and, therefore, the Department believed success in making
     AYP was no longer a meaningful measure for REAP.

States also report data annually on their progress toward RLIS program goals and subgrantees’
use of funds through the CSPR. In its most recent biennial report to Congress on the RLIS
program for school years 2008-09 and 2009-10, the Department noted that data in the CSPR is
validated through desk monitoring conducted of SEAs and is also used to prioritize RLIS
recipients for desk monitoring. However, SSRP does not review or assess the reliability of this
information, nor does it appear to use this information to assist with or improve monitoring or
provide technical assistance to grantees. As noted above, SSRP has not conducted monitoring of
any RLIS SEAs in the past several years.

Further, we noted that while RLIS progress and use of funds is reported by States through the
CSPR, this information is generally not collected for SRSA grantees other than for the GPRA
performance measures noted above. Additionally, while the Department itself was still
compiling AYP data, SSRP no longer requested the data or used it in its monitoring upon
creation of ESEA flexibility waivers. We found that of the 49 States that received funds under
17
  GPRA was passed to hold Federal agencies accountable for achieving program results. The Act required Federal
agencies to set program goals, measure program performance against those goals, and report publicly on progress
made toward those goals.
Final Audit Report
ED-OIG/A19P0006                                                                                        Page 9 of 21

one of the REAP programs, 7 did not have an ESEA flexibility waiver approved by the
Department at the time of our review, and 1 did not receive an ESEA flexibility waiver until FY
2014. LEAs in States without ESEA flexibility waivers that received REAP funds were still
required to use any REAP funding toward the school improvement activities noted in the ESEA.
Nevertheless, SSRP stopped collecting AYP data from States after FY 2012 and no longer used
LEAs’ school improvement status as a factor in selecting LEAs for monitoring.

We also found that the Department hired a contractor to evaluate the implementation of the RLIS
program. 18 The contractor’s report, published in June 2010, identified how States and school
districts used RLIS funds, assessed the progress districts made toward improving student
achievement, and identified how some States were monitoring their RLIS subgrantees.
However, we did not find any evidence that SSRP used information from this report to inform
monitoring efforts or provide assistance to grantees in meeting program goals.

OMB Circular A-123, Management’s Responsibility for Internal Control, states

         Management has a fundamental responsibility to develop and maintain effective internal
         control. The proper stewardship of Federal resources is an essential responsibility of
         agency managers and staff. Federal employees must ensure that Federal programs
         operate and Federal resources are used efficiently and effectively to achieve desired
         objectives. Programs must operate and resources must be used consistent with agency
         missions, in compliance with laws and regulations, and with minimal potential for waste,
         fraud, and mismanagement.

The Department’s Grant Bulletin #14-06, Policy, Guidance, and Responsibilities for Principal
Office Monitoring Frameworks for Formula Grant Programs (Bulletin), dated April 28, 2014,
establishes guidance to help program offices with regard to the development of monitoring plans
for formula grant programs consistent with their Principal Office Monitoring Frameworks.
OESE developed a monitoring framework, titled Guidance for OESE Monitoring Plans, dated
November 5, 2015, 19 to guide the development of program office monitoring plans for OESE
grant programs. It notes that monitoring is an essential function for OESE, with the purposes of,
among other things, ensuring that the grantee is making substantial progress toward achieving its
stated goals and objectives, providing evidence of the program’s compliance with applicable
statutes and regulations, and determining program-specific areas in which the grantee can benefit
from Federal assistance.

The OESE guidance notes desk monitoring is one of the major forms of monitoring. The
guidance explains that a desk monitoring review is a thorough examination of a specific set of
topics that is conducted from the Department. For most OESE programs, the grantee will be
asked to submit specific documents, which are thoroughly reviewed. The grantee will also be
interviewed via videoconference, webinar, or telephone. The guidance further notes that desk
monitoring reviews are typically less comprehensive than on-site monitoring reviews, but still


18
   The Department has procured another contractor to study the experiences and needs of REAP grantees to gain a
better understanding of uses of funds, activities, and technical assistance needs. SSRP has stressed to grantees that
this is not a monitoring activity. The contractor’s report is anticipated in the spring of 2016.
19
   This version revised the guidance by the same name, dated January 23, 2012. The guidance on monitoring plans
is virtually the same in each version, with the revised guidance updating OESE’s preferred method for program
offices to maintain official grantee files.
Final Audit Report
ED-OIG/A19P0006                                                                                Page 10 of 21

often require a detailed examination of grant documents and generally follow a structured
monitoring instrument and/or protocol.

The guidance notes other oversight activities are available to OESE in addition to formal on-site
or desk monitoring, such as reviewing GPRA indicators and results, Risk Management Service
(RMS) Entity Risk Review (ERR) 20 reports, and audit reports. The guidance states that many
OESE programs review the audit findings in the audit database maintained by the Federal Audit
Clearinghouse (FAC) to ensure that their grantees have complied with A-133 audit filing
requirements. It further notes that the Department tracks, monitors, and reports on audits
through the Audit Accountability and Resolution Tracking System (AARTS) 21 and that staff can
obtain full texts of audits from the FAC or by contacting staff in RMS.

The Bulletin notes that in conducting a risk assessment of each formula grant program, program
offices should include all grantees each year or a subset of grantees that, over an appropriate time
period, will enable the program office to ensure an appropriate level of oversight for all grantees.
The risk assessment process should include a risk rubric to identify and assess a grantee’s
potential risk in the areas of meeting performance standards and complying with program,
financial, and administrative requirements. The Guidance for OESE Monitoring Plans adds that
having a strong risk assessment tool is particularly useful for programs that have such a high
number of grantees that they need to strategically select a sample of grantees to target where
remediation and technical assistance is needed. The guidance specifically recommends that
grant programs that have exceptionally large numbers of grantees, such as REAP, conduct a
different risk assessment than what it suggests for most other OESE programs. It recommends
that these grant programs request that the RMS run an ERR report for all current grantees, and
use it to identify grantees that are in institutions that have been determined to have a high level of
risk. From this list, a sample of grantees to be monitored would be selected.

Reasons for Inadequate Monitoring

SSRP’s limited monitoring can be attributed to a lack of resources and the difficulty in
administering the program to the large number of REAP grantees, a lack of oversight by SSRP
management, and a lack of plans to conduct monitoring. Several POs noted their large workload,
with a few mentioning that there was not enough time to both administer the program and
conduct monitoring. Approximately 4,300 awards are made annually through the SRSA
program and approximately 44 awards are made annually through the RLIS program. Further
exacerbating the issue, SSRP has experienced significant turnover and a decrease in the number
of REAP POs in the last several years. The number of REAP POs has fallen from 9 to 5 since
November of 2011. As a result, the average number of States a PO is responsible for overseeing
has risen from 5 to 10 and the number of LEAs from approximately 480 to 860, placing a greater
burden on the POs and contributing to staff turnover. At times there was just one PO assigned to
REAP exclusively, with the others having responsibilities under other programs. As of
April 2015, we noted that all five of the assigned POs work exclusively on REAP. However
three of the five had worked on REAP for less than 1 year. Some POs noted they received little
guidance or formal training related to their responsibilities. One PO stated that being a REAP
PO was “trial by fire.”

20
  ERR reports include data from A-133 audits and past program performance data, among other data.
21
  AARTS includes data from audits and alternative products issued by the Government Accountability Office
(GAO) and the Office of Inspector General (OIG), as well as single audits.
Final Audit Report
ED-OIG/A19P0006                                                                      Page 11 of 21

We also found that SSRP’s Group Leader position was left unfilled between early 2012 and
November 2015. As the supervisor of the POs, the Group Leader is responsible for developing
monitoring plans and ensuring POs meet their monitoring goals. It appears that without a Group
Leader, SSRP was not developing monitoring plans or tracking whether monitoring was being
conducted. Of the two POs employed in SSRP for over a year, one was surprised to see that so
few monitoring reports had been completed, and the other said they thought more had been
completed.

The PO who noted that the virtual site visits had been completed over a 2-year period could not
explain why SSRP did not continue them. The PO explained that time constraints and the fact
that the virtual site visit reports were cumbersome to write may have been reasons why they were
not continued.

SSRP’s limited monitoring can also be attributed to the lack of plans to do so. When monitoring
plans were in place in FYs 2011 and 2012, 16 monitoring reports were completed. Between
FYs 2013 and 2014, when there were no monitoring plans in place, just two monitoring reports
were completed. Although still significantly short of the proposed targets, one PO explained that
having established targets compelled POs to do some monitoring, but without monitoring plans
and goals, POs no longer had any reason to do them.

When asked why the FY 2011 and FY 2012 monitoring plans were never finalized, one SSRP
PO noted that the POs worked on developing the plans and submitted them for review, but did
not receive any feedback about them from management or otherwise hear about the plans again.
Another PO noted that they were told by the Office of the General Counsel (OGC) to keep the
plans in draft form. The PO believed they were told to do so because the plans are continuously
updated. In written communication following our exit conference, OESE noted that this
statement is based on a misunderstanding and does not reflect the advice actually provided by
OGC. OESE stated that OGC would have advised program officials to continually update its
monitoring plans to address specific matters that arise during monitoring, as these are considered
living documents subject to revision. An OGC official noted that keeping plans in draft form is
not an unusual practice at the Department, and that many other program offices keep documents
in draft form and update them as needed. However, it appears that part of the reason these plans
were not fully implemented was because they were left in draft form and, therefore, the program
office was not being held to the monitoring activities or goals described in the plans.

With regard to additional review procedures for AYP grantees, an OGC official explained that
the school improvement activities of Section 1116 of the ESEA were not much more restrictive
than the SRSA program’s allowable uses of funds. This official further noted that the SRSA
program funds can be used for virtually anything related to education, though still in accordance
with the statute, suggesting that more robust monitoring of SRSA grantees would be an
inefficient allocation of SSRP’s limited resources. Nevertheless, SSRP’s current monitoring
efforts do not satisfy its oversight responsibilities, nor do they provide SSRP with any assurance
that grantees are making progress toward achieving program objectives and spending their funds
in accordance with statutory and regulatory guidelines. Additionally, while the allowable uses of
funds are very flexible under the SRSA program, SRSA funds can still be misappropriated or
used improperly. Regarding grantees that failed to make AYP, while the allowable uses of funds
for these grantees may still have been very flexible, these grantees were nonetheless still subject
to more restrictive allowable uses of funds and should have been held to these further restrictions
defined by the ESEA.
Final Audit Report
ED-OIG/A19P0006                                                                       Page 12 of 21

In written communication following our exit conference, OESE acknowledged that more could
have and should have been done to ensure REAP grantees were complying with program
requirements, but noted that monitoring under the REAP may differ from that under traditional
grant programs given the significant number of REAP grantees, the relatively small size of the
grant awards, and the flexible uses of program funds. OESE also stated that under a cost-benefit
and risk analysis, the program office should not be expected to conduct the type of in-depth
monitoring generally expected in other programs. In addition, OESE stated that it may be
particularly burdensome to attribute increases in student academic achievement to REAP funds,
given the relatively small award amounts, the broad allowable uses of funds, and the inability of
very small districts to provide data sets large enough to be statistically reliable. OESE stated that
the authorized uses of funds under the SRSA and RLIS programs are extremely broad, and
therefore the risk for a district using REAP funds for unauthorized purposes is significantly less
than that in most other Federal education programs. OESE also stated that in allocating limited
resources to monitoring, it is reasonable to take into account the lower risk factors for REAP
grantees.

We agree that due to the attributes noted above, monitoring under the REAP may differ from
monitoring performed under other grant programs. Our report does not specify the level of
monitoring that should have been performed or should be performed currently, but notes a need
for at least a reasonable amount of monitoring to be performed rather than the limited to no
monitoring that we noted. Further, monitoring completed should at least be close to or at the
level specified by the program office itself in its monitoring plans. As noted above, monitoring
of REAP grantees fell significantly short of the targets SSRP set for itself in FYs 2011 and 2012.
As previously referenced, OESE’s Guidance for OESE Monitoring Plans states that monitoring
should be conducted with enough depth to ensure that the grantee is making substantial progress
toward achieving its stated goals and objectives, provide evidence of the program’s compliance
with applicable statutes and regulations, and determine program-specific areas in which the
grantee can benefit from Federal assistance. The guidance notes that having a strong risk
assessment tool is particularly useful for programs that have such a high number of grantees that
they need to strategically select a sample of grantees to target where remediation and technical
assistance is needed. It specifically cites REAP as an example of a program that should conduct
a different risk assessment than what it suggests for most other OESE programs so that resources
can be focused on institutions determined to have a high level of risk.

Recent Efforts to Improve Program Oversight

In its written communication following our exit conference, OESE also noted that SSRP
experienced a change in leadership in January 2015. OESE stated that, upon this change, the
new Acting Director took steps to address areas for possible improvement and growth in the
program office by conducting a three-tiered review designed to increase system alignment, and
to build organizational, team, and individual performance. OESE further explained that as a
result of the reviews and the transition in leadership, SSRP has implemented reforms to improve
the efficiency of grant administration, enhance technical assistance, and make clear the specific
roles and responsibilities of program staff. Steps noted to have been taken include revising the
organizational structure of the office to promote more effective communication, clearly defining
roles and lines of reporting, and realigning the duties and responsibilities of program staff to
ensure the REAP is administered in accordance with all applicable Department policies and
procedures. OESE noted that the REAP’s new Group Leader has been actively working to
develop robust technical assistance activities and conduct monitoring in the
Final Audit Report
ED-OIG/A19P0006                                                                       Page 13 of 21

FY 2016 grant cycle. OESE further noted that the REAP program has begun a comprehensive
review of its past monitoring plans and has sought guidance and assistance from OESE
leadership responsible for monitoring, and that SSRP has begun to develop revised guidance and
procedures in accordance with the ESSA.

While we appreciate OESE’s stated efforts, we note that in October 2015, during our fieldwork,
the Acting Director first mentioned that several assessments had been performed within SSRP, to
include a climate, operational, and internal control assessment. We were informed at that time
that the assessments and a summary of changes that had been made since she took over would be
provided for our review. We subsequently made several requests for this information to both the
Acting Director and Group Leader from October 2015 through January 2016 and were told that
documentation would be forthcoming, however no information was ever provided for our
review. As a result, we were not able to review, assess, or report on these efforts as part of our
audit.

Overall Effect of Inadequate Monitoring

Without adequate monitoring of grantee progress, SSRP has little assurance that REAP grantees
are making progress toward program goals and objectives. Although SSRP does collect data on
grantee progress, much of it is aggregated and cannot be used to assist grantees having trouble
meeting program goals, and reported program data are not validated. As a result, SSRP cannot
identify individual grantees needing assistance in meeting program goals, nor does it have
assurance that program performance data are accurate and reliable.

As noted previously in Table 3, targets for each of the GPRA performance measures for the
SRSA and RLIS programs have not been met in the past several years. In fact, instead of making
progress, performance has actually declined in each of the past several years. With adequate
monitoring of grantee progress, SSRP would have a better idea of the issues that may be
preventing grantees from making further progress and could provide more focused technical
assistance to address these issues.

Regarding monitoring of grantees’ use of funds, SSRP has little to no insight regarding what
grantees and subgrantees are using grant funds for, and lacks information that would enable it to
detect any instances where grantees are using funds for unallowable purposes. SSRP’s limited
monitoring did not require grantees to provide any evidence of grant expenditures. Instead, POs
relied on what grantees told them. Inadequate monitoring increases the risk that grantees will
misuse grant funds. This risk is further increased due to the fact that REAP funding is not
generally covered in A-133 audits, and even when it is, SSRP does not review these audits for
such findings. Further, with regard to RLIS, SSRP lacks assurance that its grantees—the
SEAs—are conducting required monitoring of their subgrantees to ensure compliance with
applicable Federal requirements, including that funds are being used only for allowable purposes,
and that performance goals are being achieved. This is all the more important in light of new
requirements in both the ESSA and OMB’s Uniform Grant Guidance regarding pass-through
entities’ responsibilities to perform risk assessments of their subgrantees and monitor them
accordingly.

Lastly, the risk of misuse of funds will likely increase as grantees realize that the Department is
not monitoring them. One PO told us that one grantee said they had not heard from anyone in
the Department in 10 years. Through reviewing the desk monitoring reports, we also found that
Final Audit Report
ED-OIG/A19P0006                                                                    Page 14 of 21

two grantees stated they were receiving more money than they were able to spend, and one
grantee noted they were grateful someone from the Department was reaching out to them, as they
had not heard from anyone in 8 years. These anecdotes serve only to reinforce the importance of
adequate monitoring in ensuring that Federal funds are protected from waste, fraud, and abuse.

Recommendations

We recommend that the Assistant Secretary for OESE:

    1.1       Ensure that SSRP staff develop, finalize, and implement adequate plans to
              monitor REAP grantees performance toward achieving the program’s goals and
              objectives, and that such monitoring is used to assist grantees with making
              progress toward the program’s goals and objectives.

    1.2       Ensure that SSRP staff develop, finalize, and implement adequate plans to
              monitor REAP grantees use of funds to ensure that funds are being used for
              allowable activities under each of the programs. Consider partnering with other
              program offices within the Department monitoring the same grantees, when
              applicable.

    1.3       Review available A-133 single audit reports for findings pertaining to the REAP
              or other programs under which REAP funds can be used to assist in the
              monitoring of REAP grantees.

    1.4       Implement a risk assessment process to be used in selecting grantees to be
              monitored. In doing so, consider requesting ERR reports for grantees from RMS,
              as suggested by OESE’s Guidance for OESE Monitoring Plans for grant
              programs with a large number of grantees.

    1.5       Consider updating the Compliance Supplement to direct external auditors to
              review grantees’ and subgrantees’ uses of REAP funds, particularly where there
              may be known concerns regarding a grantee’s or subgrantee’s administration of
              other Federal grant programs.

    1.6       Ensure that new POs receive adequate training and guidance so they are prepared
              to adequately manage the responsibilities of being a PO and effectively oversee
              grantees.

    1.7       Review resources currently allocated to SSRP and assess whether SSRP has the
              resources necessary to adequately perform its oversight responsibilities.

    1.8       Ensure that all relevant and available sources of information, such as reports from
              contractor studies and evaluations, are used to inform monitoring efforts or
              provide assistance to grantees in meeting program goals.

    1.9       Ensure that procedures are developed to validate, to the extent possible, data on
              grantees’ performance and use of funds and that collected data is used to inform
              program monitoring.
Final Audit Report
ED-OIG/A19P0006                                                                                 Page 15 of 21

OESE Comments

OESE did not disagree with the finding and stated that OESE and REAP have proactively begun
addressing many of the recommendations contained in the draft audit report. OESE stated that
monitoring materials and monitoring standard operating procedures have been completed and
address the targeted area of financial management. OESE also noted that monitoring of 15
grantees was completed in the spring of 2016. REAP staff utilized an abridged version of
OESE’s risk assessment to conduct a risk assessment of SRSA and RLIS grantees for the
FY 2016 monitoring. Lastly, OESE stated that additional staffing has been requested for REAP.

OIG Response

We appreciate the efforts noted by OESE to improve its monitoring of REAP grantees’
performance and use of funds. As a result of OESE’s comments, we did not make any changes
to the audit finding or the related recommendations.

Finding 2: The Department’s Rural Education Coordination Efforts Appear
           to Be Effective
We found that the Department is involved in various internal and external rural education
coordination efforts and that these efforts appear to be effective. In the last several years, the
Department has placed a greater emphasis on internal and external rural education coordination
activities. These activities have led to increased internal communication about and awareness of
major rural education programs, projects, and priorities. These efforts have also allowed external
entities interested in rural education to more easily connect with the appropriate personnel in the
Department. The DAS for Rural Outreach heads most of the Department’s rural education
coordination efforts, and SSRP serves as a resource for the DAS.

Internal Coordination

The Department’s internal rural coordination efforts appear to be effective. Internal coordination
is largely done through an inter-POC working group, but also includes Senior Staff Scheduling
and Communications meetings and Intergovernmental Affairs (IGA) meetings, which the DAS
for Rural Outreach uses to provide updates to attendees on relevant rural education news and
activities.

Shortly after the position was created in 2009, the DAS for Rural Outreach at the time created
the inter-POC rural working group. 22 This group aims to meet quarterly so that participants can
keep each other informed of current news and activities in their respective areas, as well as talk
about developments in the field of rural education. The working group has provided an
opportunity for several different areas of the Department to meet to discuss rural education.

Approximately 16 employees from 8 different principal offices, including representatives from
SSRP, participate in the working group. In one of the working group’s meetings, they discussed
how the Department could assist with the White House Rural Council’s Rural Impact Initiative
(discussed below), an external initiative the Department is involved in with other Federal
22
  The group stopped meeting when the original DAS for Rural Outreach left the Department in late 2013, and was
restarted when the current DAS for Rural Outreach was hired in July 2014.
Final Audit Report
ED-OIG/A19P0006                                                                     Page 16 of 21

agencies. The DAS for Rural Outreach also formed an ad hoc group of members of the working
group to respond to a special request from the White House Rural Council to provide a document
of ideas of how the Department can assist with the Rural Impact Initiative.

Further coordination is done through two separate meetings the DAS for Rural Outreach attends.
The DAS for Rural Outreach uses Senior Staff Scheduling and Communications meetings to
notify the attendees of important, upcoming rural education events and news, and uses IGA
meetings to update attendees on rural education conferences and feedback received from rural
stakeholders.

External Coordination

The Department’s external rural education coordination efforts also appear to be effective. Most
of the Department’s external coordination with other agencies has resulted from its participation
in the White House Rural Council, on which the DAS for Rural Outreach serves as the
Department’s representative. In addition to coordination efforts through the Council, the DAS
for Rural Outreach also works directly with other Federal agencies and rural advocacy groups.
Further, IES’ NCER formed a rural education research technical working group with experts in
the field of rural education to discuss priorities for rural education research efforts.

The White House Rural Council was established in 2011 to “better coordinate Federal programs
and maximize the impact of Federal investment to promote economic prosperity and quality of
life in rural communities.” Over 25 executive branch departments, agencies, and offices,
including the Department, participate in the Council. The DAS for Rural Outreach, the
Department’s representative on the Council, noted that formal meetings take place twice a year,
though working group meetings take place monthly or bimonthly. The following are White
House Rural Council initiatives that the Department has participated in or is currently
participating in:

   •   Rural Jobs Accelerator – Announced by the White House Rural Council in March 2012,
       this initiative links Federal programs to facilitate job creation and economic development
       in rural communities. Through this initiative, several agencies can coordinate technical
       assistance and grant/loan programs so that participating entities can have a single access
       point within the Federal government, creating improved access, streamlining of
       programs, and better leveraging of resources.

       In August 2012, close to $9 million was awarded to 13 grant recipients. Funding is
       provided by the U.S. Department of Agriculture (USDA), the U.S. Economic
       Development Administration, the Delta Regional Authority, and the Appalachian
       Regional Commission. Technical support is provided by other Federal agencies,
       including the Department. In participating in this initiative, the Department has created a
       webinar series titled “Skills on Purpose,” which is focused on how to form regional
       consortia that align education and training programs with the needs of industry in
       advanced manufacturing. Six webinars were held between June and September 2015.

   •   Investing in Rural Schools – In June 2012, the White House Rural Council announced the
       Investing in Rural Schools initiative, the Department’s new online community of practice
       group for rural schools. This community of practice group provides a platform for
       educators to connect to resources, tools, colleagues, experts, and learning activities, both
Final Audit Report
ED-OIG/A19P0006                                                                    Page 17 of 21

       within and beyond schools. This group currently has 34 members and provides resources
       for rural schools relating to human resource challenges, reaching and engaging rural
       stakeholders, and implementing School Improvement Grants.

       As part of the effort, the Federal Communications Commission (FCC), through its E-rate
       program, is investing $2 billion to expand high-speed internet connectivity for America’s
       schools and libraries. In December 2014, several updates and expansions were made to
       the E-rate program to improve the administration of the program and maximize schools’
       and libraries’ options for purchasing affordable, high-speed broadband networks.
       Department staff worked with the FCC to provide guidance on these changes.

   •   Summer Food Service Program – This program aims to ensure that low-income children
       continue to receive nutritious meals when school is not in session. USDA planned to
       serve more than 200 million free meals to children 18 years old and under at approved
       Summer Food Service sites in the summer of 2015. In June 2015, the White House Rural
       Council coordinated and published a joint blog post from the Department’s Secretary at
       the time, Arne Duncan, and USDA’s Secretary, Tom Vilsack. The blog post supported
       the program and highlighted resources available for those interested in finding a summer
       food location or starting one in their community.

   •   Rural Impact – Announced in February 2015, the Rural Impact Initiative aims to address
       the challenge of rural child poverty by bringing together Federal agencies and public and
       private resources. The initiative aims to develop new approaches to address rural
       challenges and barriers, enhancing public awareness of rural child poverty and its impact
       on the future of rural communities and the nation’s global competitiveness, and
       improving access to high-quality child care, early learning, and continuing education.

       In support of the Rural Impact Initiative, the Administration announced a new technical
       assistance initiative, the Rural Integration Models for Parents and Children to Thrive
       (IMPACT) Demonstration. The Demonstration will focus on providing technical support
       for rural and tribal communities to incorporate a two-generation approach, with the goal
       of reducing child poverty. USDA and the U.S. Department of Health and Human
       Services (HHS) announced in September 2015 that 10 rural and tribal communities
       across the country would be participating in the Rural IMPACT Demonstration. The
       Demonstration will be administered by HHS, and will be implemented in collaboration
       with other Federal agencies, including the Department. Department staff, including the
       DAS for Rural Outreach, participated in the Demonstration’s planning meetings with
       representatives from other agencies, as frequently as weekly throughout the summer. The
       Department will be available to provide technical assistance as needed and where
       applicable to the participating communities.

The DAS for Rural Outreach also communicates with other agencies separately from what is
done through the White House Rural Council. The DAS for Rural Outreach is in frequent
communication with USDA’s Rural Development office so they can relay important information
to each other and ensure the Department and USDA are aware of what’s happening with each
other’s rural programs and efforts. The DAS for Rural Outreach has also coordinated meetings
and held discussions with the U.S. Department of Housing and Urban Development (HUD),
OMB, and the Appalachian Regional Commission. For example, earlier this year, HUD’s Office
of Rural Housing and Economic Development hosted a Rural Gateway conference call in which
Final Audit Report
ED-OIG/A19P0006                                                                                 Page 18 of 21

it asked the DAS for Rural Outreach to speak about funding opportunities through the
Department for rural communities. The DAS for Rural Outreach brought along the Director and
a PO from SSRP to talk during the call as well. Approximately 200 participants, consisting of
rural community leaders, called in to the conference call.

In December 2014, IES’ NCER convened a technical working group of experts in the field of
rural education to discuss research needs in the field and how research could be more useful and
relevant to rural communities. In addition to IES staff, 10 rural education experts were invited,
including individuals from the K-12 system, national associations, universities, and research
organizations. The technical working group focused on (1) current issues in rural education
research, (2) prior large-scale IES investments in rural education research, (3) challenges and
priorities, and (4) next steps. As a result of the conversations held through the technical working
group, IES produced a meeting summary that will be used to guide future plans for support of
research on rural education issues.

The Department of Education Organization Act of 1979 notes that the Department was
established, in part, to improve the coordination of Federal education programs. The Act also
notes that the Department:

        Shall also provide a unified approach to rural education and rural family education
        through the coordination of programs within the Department and shall work with the
        Federal Interagency Committee on Education 23 to coordinate related activities and
        programs of other Federal departments and agencies.

GAO’s Practices That Can Help Enhance and Sustain Collaboration Among Federal Agencies
notes that agencies can enhance and sustain their collaborative efforts by engaging in eight
practices identified below. Common themes throughout these practices are leadership, trust, and
organizational culture. It notes that collaboration among Federal agencies can take many forms,
but collaborations generally consist of two or more agencies following these eight practices:

             •   define and articulate a common outcome;
             •   establish mutually reinforcing or joint strategies;
             •   identify and address needs by leveraging resources;
             •   agree on roles and responsibilities;
             •   establish compatible policies, procedures, and other means to operate across
                 agency boundaries;
             •   develop mechanisms to monitor, evaluate, and report on results;
             •   reinforce agency accountability for collaborative efforts through agency plans and
                 reports; and
             •   reinforce individual accountability for collaborative efforts through performance
                 management systems.

The Department’s coordination efforts in the area of rural education are largely headed by the
Department’s DAS for Rural Outreach. The DAS for Rural Outreach’s primary responsibility is
to build and maintain relationships with rural stakeholders and advocates, and rural education
coordination complements this responsibility. The position, created in 2009, has been the
23
  The Federal Interagency Committee on Education no longer exists, with the last meeting occurring approximately
7 years ago.
Final Audit Report
ED-OIG/A19P0006                                                                       Page 19 of 21

driving force behind the Department’s increased rural education coordination efforts and has led
to increased coordination and communication about rural education between different POCs and
between the Department and other agencies and organizations. Not all education subject areas
have a representative in OCO and not all areas have inter-POC working groups. Having a single
person dedicated to rural education, like the DAS for Rural Outreach, makes it easier for external
groups and other agencies to coordinate and connect with the Department.

However, since the Department’s DAS for Rural Outreach is a political appointee, the current
DAS noted uncertainty as to whether the position will continue when a new administration
begins in January 2017, and, if not, whether these rural education coordination efforts will
continue.

Effective coordination of rural education activities both within the Department and with other
agencies and organizations involved in rural education can produce a greater benefit than the
Department could otherwise achieve on its own. With effective coordination, the Department
has more assurance that it is maximizing its resources and efforts in the area of rural education.

Recommendation

We recommend that the Assistant Secretary for Communications and Outreach:

    2.1        Ensure that the Department continues to effectively coordinate rural education
               initiatives and efforts, both internally and externally.

OCO Comments

In its response to the draft audit report, OCO concurred with the finding. OCO stated that it is
aware that the DAS for Rural Outreach is currently responsible for much of the Department’s
effective rural coordination efforts. To address the recommendation and ensure that coordination
efforts continue during the next administration, OCO stated it is developing a plan to expand
capacity around rural education engagement and coordination through a dedicated unit focused
on rural and community outreach that includes senior career staff. The DAS for Rural Outreach
will work with these senior career staff members to help institutionalize her work to coordinate
rural education efforts both internally and externally.

OIG Response

We appreciate the efforts noted by OCO to ensure the continuation of rural education
coordination efforts. As a result of OCO’s comments, we did not make any changes to the audit
finding or the related recommendation.
Final Audit Report
ED-OIG/A19P0006                                                                    Page 20 of 21


                 OBJECTIVES, SCOPE, AND METHODOLOGY


The objectives of our audit were to (1) determine whether the Department adequately monitored
grantees’ performance and use of funds, and (2) assess the effectiveness of coordination efforts
both within the Department and with other Federal agencies involved in rural education.

To accomplish our objectives, we gained an understanding of internal controls applicable to the
Department’s monitoring of REAP grantees’ performance and use of funds and those controls
over the Department’s coordination efforts between relevant parties within the Department as
well as other Federal agencies involved in rural education. We reviewed applicable laws and
regulations, policies and procedures, OMB guidance, and GAO’s “Standards for Internal Control
in the Federal Government.” In addition, to identify potential vulnerabilities, we reviewed prior
OIG and GAO audit reports with relevance to our audit objectives.

We conducted discussions with SSRP management and staff to obtain a more complete
understanding of the REAP. These discussions focused primarily on the monitoring process and
other efforts undertaken to administer the program. We also conducted discussions with OCO
officials to discuss the Department’s coordination efforts. The scope of our review was limited
to the Department’s monitoring activities for REAP grantees and the Department’s internal and
external coordination efforts between FYs 2011 and 2014.

To determine the adequacy of the Department’s monitoring of REAP grantees’ performance and
use of funds, we reviewed monitoring reports and technical assistance correspondence in G5,
which contains each grantee’s official grant folder. SSRP identified 16 grant files containing
monitoring reports completed between FYs 2011 and 2014, and we reviewed all 18 monitoring
reports contained in these files. SSRP identified 453 grant files containing technical assistance
correspondence occurring between October 2010 and November 2015. We selected a
nonstatistical random sample of 46 files (10 percent) to review to determine whether any of the
technical assistance correspondence could also be deemed as a monitoring activity. We reviewed
the policies and procedures developed to guide REAP monitoring efforts and compared the goals
in these plans with how much monitoring was conducted. We also reviewed REAP guidance
provided to grantees, the most recent RLIS biennial report sent to Congress, SSRP organizational
charts, documentation of webinars held with RLIS SEAs, and contractor evaluations of the RLIS
program. Because there is no assurance that the nonstatistical sample used in this audit is
representative of the respective universe, the results should not be projected over the unsampled
files.

To assess the effectiveness of coordination efforts both within the Department and with other
Federal agencies involved in rural education, we reviewed narrative documents put together by
the DAS for Rural Outreach explaining the various coordination efforts the Department is
involved in; information on the DAS for Rural Outreach position; evidence of the Department’s
participation in White House Rural Council initiatives; IES’ technical working group meeting
summary; and the Department’s press releases, media advisories, and blog posts related to the
Department’s participation in the White House Rural Council.
Final Audit Report
ED-OIG/A19P0006                                                                      Page 21 of 21

We conducted fieldwork at Department offices in Washington, DC, during the period
June 2015 through March 2016. We provided our audit results to Department officials during an
exit conference conducted on March 3, 2016.

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 objectives. We believe that the evidence obtained provides a reasonable basis
for our findings and conclusions based on our audit objectives.



                            ADMINISTRATIVE MATTERS


Corrective actions proposed (resolution phase) and implemented (closure phase) by your
office(s) will be monitored and tracked through the Department’s AARTS. The Department’s
policy requires that you develop a final corrective action plan (CAP) for our review in the
automated system within 30 calendar days of the issuance of this report. The CAP should set
forth the specific action items, and targeted completion dates, necessary to implement final
corrective actions on the findings and recommendations contained in this final audit report.

In accordance with the Inspector General Act of 1978, as amended, the Office of Inspector
General is required to report to Congress twice a year on the audits that remain unresolved after
6 months from the date of issuance.

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 given us during this review. If you have any questions, please
call Michele Weaver-Dugan at (202) 245-6941.


                                             Sincerely,


                                             Patrick J. Howard /s/
                                             Assistant Inspector General for Audit
                                                                         Attachment 1


             Acronyms/Abbreviations/Short Forms Used in this Report


AARTS            Audit Accountability and Resolution Tracking System
AYP              Adequate Yearly Progress
CAP              Corrective Action Plan
CSPR             Consolidated State Performance Report
DAS              Deputy Assistant Secretary
Department       U.S. Department of Education
ERR              Entity Risk Review
ESEA             Elementary and Secondary Education Act of 1965
ESSA             Every Student Succeeds Act
FAC              Federal Audit Clearinghouse
FCC              Federal Communications Commission
FY               Fiscal Year
GAO              Government Accountability Office
GPRA             Government Performance and Results Act
HHS              U.S. Department of Health and Human Services
HUD              U.S. Department of Housing and Urban Development
IES              Institute of Education Sciences
IGA              Intergovernmental Affairs
IMPACT           Integration Models for Parents and Children to Thrive
LEA              Local Educational Agency
NCER             National Center for Education Research
NCLB             No Child Left Behind Act
OCO              Office of Communications and Outreach
OESE             Office of Elementary and Secondary Education
OGC              Office of the General Counsel
OIG              Office of Inspector General
OMB              Office of Management and Budget
PO               Program Officer
POC              Principal Office Component
REAP             Rural Education Achievement Program
RLIS             Rural and Low-Income School
RMS              Risk Management Service
SEA              State Education Agency
SRSA             Small, Rural School Achievement
SSRP             School Support and Rural Programs
USDA             U.S. Department of Agriculture
                                                                                                                                        Attachme nt 2


                                    OESE Res pon se to the Draft Report




                           UNITED SfATES DEPARTMENT OF' EDUCATION
                                Oft'ICE OF ELEMEI'ITMY .1\ND SECONDARY EDUCATION




                                                                                                                :J\ll 'l 7 tt\6
Mtcbclc Weaver-Dugan
SSO 12th Street, SW
Rm8050
WHshington. DC 20202

Dear Michele Wcavcr-Duj,\an:

The Office ofEiemenrnry ami Secondary F.ducauon (OESE) appnxiatcs the opportunity to provide written
commt.'llts to tin: Dmft Audit Report, Control Number EO-OIG/Al9P0006, lltlcd Audit of the Dcp<Jrtment's
Oversight oftbe Rural J:ducation Achievement Program. provided on June 6, ?.016.

A~  with all of the progr.mlS we administer. OESE strives to continuously •mprove the operation of the Rural
Education Achievement l'rogrmn. Our comments should help to clnrifY our ongoing efforts as we strive to e•JSure
that the funds Congress appropriutcs to the Department for th is program will address the uni4uc nt.-cds Ill' rum!
school districts that frequently lack the personnel ~ nd resources needed to compete efft:!:tively for fooc:ral
competitive grants, and receive formal gr.~nt allocations in amounts too small to be effective in meeting their
intended purpose.

OESE's response to the Drnfl Audit Report is detailed in the auachoo Corrective Action Plan (CAP). In the CAP,
the column labeled "nction'' includes each rccommcnd:uion included in the l)rdfi Audit Report (in bold). Each
reconunendation is broken down into more specific actions steps (non-bold) that will help the progmm office
comply with the recommendation. In addition tolhc action column, the CAP also includes columns for "status,"
"completion date." and '1•erson responsible" that correspond with each nctioo. f or example: Item l.O, T'rogram
monitoring ofgratllecs performance towurd achieving pro&rrnm goals and objectives is tbe recommendation from
the Dmft Audit Rcpon. Actions 1.1 and 1.2 are additional action steps. with corresponding status and completion
dnte for Cllch step. The individual responsible for nllttems on the CAP IS consi.~tentty Dr. David C'.:mrrell, Group
Leader. REAP.

OESE and REAP have proacuvcly begun addrcsstng mnny of the recommendations included in the Draft Audit
Report. Spocilicnlly, monitoring mntcrinls and monitoring $tnndard operating procedures have been completed
addressing the targeted nrcn of finnncialmnnngcmcnt, ns well as monitorint: of 15 grantees was completed spring
2016. REAP staffutilir.ed an abridged version of013SE's risk assessment to conduct a risk assessm.:nt ofSRSA
and RLIS grantees for tla: FY 16 monitoring. Additional staffing bas also been requested for REAP.

Any suhscqucnt quesuons, comments, or concerns ~hould be addressed to· Dr. Lisa Ramiru. Acting Director.
School Support ond Rurnll'mernms.

                                                               Sincerely,


                                                               ~{]CimJ~
                                                              Lisa RJmircz
                                                              Acting Director
                                                              School Support and Rurall'rograms

                                           <00 MARYUtro AVE. SW. WASHINGTO:-J. 0C 20702
                                                                  www.<d,to"

             Our mLssttn ~ tQ c:n.·nuv '~ual ClCCc!$S to cduca.tCDtt C111tlto pn>tni)('C ~UCCIICCHtal ~CW'W'V tlvoughou.t chc rwfton.
                                                                                                                     Attachment 3

                                OCO Response to th e Draft Report




                            UNlTJ\U STATI::S DEPARTMENT OF EDUCATION
                                   OffTCE OF COMMUJ>,1CATIONS AND OlTI'REACit

                                                    August4. 20 16



 MEMORANDUM

 TO:               Office of the l.ns~cct
                                    Gcncr· or
                                         ,                               ~
 FROM:             Malt Lchrich
                   Communications Director, delegareclthe duties of the Assistant Secretary

 SUBJECT:          Response to Finding 2 of the Office of Inspector General's Audit of the
                   Department's Oversight of lhe Rural Education Achievement Program



Thank you for the opponunity 10 provide a written response to your drafl audit report. We concur
wi th the finding that the Department is involved in various internal and external rural
coordination effons and that these efforts are effective.

We arc also aware that the Deputy Assistant Secretary for Rural Outreach is currently
responsible for much of the Departmeut's effective rural coordination cffons. In order to best
follow the recommendation of the OIG and ensure that these efforts continue during the next
administration. OCO is developing a plan to expand capacity around rural education engagement
and coordination through a dedicated unit focused on rural and community outreach that includes
senior career staff. In the months ahe<~d, the DAS for Rural Outreach will continue to work with
these senior career staff members to help institutionalize her work to coordinate rural education
effons hoth internally and externally.




                              400 MARYlAND AVE. S.W., WASHJI\GTON, DC 20202
                                                   W\\W.ed t;ov

The Dr:porrmcnt ofEducarion ~mission is to PN?tiiOI~ srudem odticU<:mr:nt and prcporalionfur ylbbol oomMtitiwnrs,,
                          byfost~rtng cduroltono/ ~ll~nc~ and ensuring l'f[Unl OC<'US.