ECF Funds May be Subject to Uniform Guidance Audit

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AAFCPAs would like to make Charter School clients aware that funds received under the ECF (Emergency Connectivity Fund) Program are federal funds and must be included in the calculation for determining your need for a Uniform Guidance audit.

In May 2021, the ECF program was established by the FCC (Federal Communications Commission) to distribute ARPA (American Rescue Plan Act) funding to eligible schools, school districts, and libraries for the purchase of qualifying equipment and telecommunication services. The goal of this funding was to provide communities with resources needed to close the Homework Gap and keep students connected to their classrooms.

Schools, school districts, and libraries have historically been able to apply for funding under the FCC’s E-Rate program, which provides schools and libraries with internet access. The traditional E-Rate funding is not subject to Uniform Guidance Single Audit requirements. ECF funding is Federal in nature and recipients of this funding must adhere to specific compliance requirements, including the use of funding to satisfy unmet needs, and adherence to per-user and per-location limitations. ECF expenditures must be included in your calculation to determine if recipients may be required to undergo an audit in accordance with Subpart F of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance or UG), known as a Single Audit.

AAFCPAs recommends that schools, school districts, and libraries who have received ECF program funding consider the impact that the funding may have on their current and/or upcoming annual financial statement audit(s). For those recipients who undergo a Single Audit, ECF expenditures will be required to be reported on the SEFA (Schedule of Expenditures of Federal Awards).

If you have questions, please contact John Buckley, CPA, CGMA, at jbuckley@nullaafcpa.com, 774.512.4039; or your AAFCPAs Partner.


About the Author

John Buckley

John Buckley, CPA, CGMA

John is the leader of AAFCPAs’ Educational Services practice, serving diverse academic and education services clients spanning independent schools, colleges/universities, special education schools, education services, charter schools and charter management organizations (CMOs). He fully understand the nuances of the educational services industry and  business and operational challenges faced by these institutions, including funding and regulatory issues such as: capital campaign structures, complex endowments, alternative investments, debt financing and tax credit options, and unique governance concerns and …