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We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Tennessee, in consultation with the Governor of Tennessee, to review its policies and procedures for drawing down Department grant funds to pay for corresponding grant expenditures and determine whether any updates are necessary to ensure funds drawn down from one grant (for example, CRRSA EANS) are not being used to pay for expenditures under another grant (for example, ARP EANS).

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Tennessee, in consultation with the Governor of Tennessee, to ensure that Tennessee officials responsible for making, reviewing, and approving G5 drawdowns receive sufficient training on Federal rules and regulations and State policies and procedures related to drawing down funds from G5 and documenting the process correctly.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Tennessee, in consultation with the Governor of Tennessee, to ensure full implementation of procedures that will identify, locate, and track assets purchased with EANS funds at nonpublic schools and verify that those assets were still being used for purposes related to COVID-19 or for allowable purposes under another Federal education program in which the nonpublic school participates. If assets purchased with EANS funds are no longer being used for purposes related to COVID-19 or for allowable purposes under another Federal education program in which the nonpublic school participates, retrieve them for use in other allowable activities or dispose of them in accordance with State laws and procedures. If assets purchased with EANS funds cannot be identified and located, determine any liabilities owed to the Department and return funds if required.

We recommend that the Assistant Secretary for the Office of Elementary and Secondary Education require Tennessee, in consultation with the Governor of Tennessee, to retroactively obtain prior written approval from the Department for the three equipment expenditures or return the approximately $123,000 expended for those equipment purchases and perform a review of the remaining equipment expenditures to determine whether there are additional purchases that require prior written approval. Tennessee should also incorporate into its grants management policies and procedures a step to determine for any Department grants whether it is required to obtain prior approval from the Department for certain expenditures, or whether Tennessee can provide prior approval for subrecipients.