According to the audit report, OIG made five recommendations for the Virgin Islands:

Finalize the monitoring and internal control plan and implement processes that provide reasonable assurance that the Virgin Islands Department of Education will spend Restart program funds in a timely manner and conduct effective programmatic monitoring of the program.
Update its monitoring and internal control plan once an external evaluator is contracted to include the role the external evaluator will have in assisting the Virgin Islands DOE in monitoring the Restart program and how the contractor will monitor the program to ensure compliance.
Staff its Internal Audit Division at planned levels and develop and implement standard operating procedures to provide reasonable assurance that it will fulfill its responsibilities.
Assess the risk of fraud in department programs and develop and implement control activities to prevent, detect, and respond to potential fraud.
Develop and implement a fraud reporting mechanism and display in public places the OIG hotline contact information.

Graham also pointed to an audit of the internal controls used by the Texas State Educational Agency for its Restart Grant as an example of the controls auditors could be looking for in reviewing the internal controls for CARES Act funds. Graham said OIG lauded the Texas SEA for the following:

A well-defined process to allocate program funds to subgrantees, including LEAs and nonpublic schools.
Appropriate existing processes for submission and review of subrecipient applications, as well as payment for allowable expenditures.
A description of a well-established fiscal monitoring in its required internal control and monitoring plan.
Technical assistance provided to LEAs and nonpublic schools that ensured they used funds in compliance with the Restart program.

Charles Hendrix covers education funding and other Title I issues for LRP Publications.

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Why strong internal controls are key for spending CARES Act funds

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