Our objective was to determine whether the Department designed and implemented State plan review and approval processes that provided reasonable assurance that it (1) identified and resolved potential instances of State plans’ noncompliance with ESEA and Title VII, Subpart B of the McKinney-Vento Homeless Assistance Act of 1987, as amended by the Every Student Succeeds Act (McKinney-Vento Act) requirements; (2) acted within its authority as set forth in section 1111(a)(4)(A)(vi) of the ESEA; 2 and (3) complied with Department policy.
The Department designed review and approval processes that provided reasonable assurance that it identified and resolved potential instances of State plans’ noncompliance with the ESEA and McKinney-Vento Act requirements subjected to peer review; however, it did not (1) always retain records that ensured adequate and proper documentation of its peer reviewer selection decisions or its analysis of peer reviewer comments on the McKinney-Vento Act requirements of State plans, (2) publish all versions of States’ plans on its website, or (3) always show that it considered conflict of interest information collected from peer reviewers before assigning them to panels. We did not identify any evidence that would suggest that the Department acted outside its authority to disapprove a State plan as set forth in the ESEA. However, because of the issues identified, we could not determine why the Department selected certain peer reviewers. We also could not always determine whether the Department considered the results of the peer review process when providing feedback on the McKinney-Vento Act section of State plans. Further, we could not ensure that the Department considered conflict of interest information it collected from peer reviewers before assigning them to panels, which could affect the integrity of the peer review processes.
We made three recommendations. Specifically, we recommended that the Department (1) strengthen its policy for creating and retaining records so those records demonstrate adequate and proper documentation of its functions, policies, decisions, procedures, and essential transactions relevant to the review and approval of the McKinney-Vento Act section of State plans; (2) make publicly available all submissions and resubmissions of States’ plans, including individual and consolidated plans, to promote full transparency; and (3) adhere to its policy and consider all conflict of interest information collected from peer reviewers before assigning them State plans to review.
Oversight and Monitoring—Grantees
See other OIG reports involving the Every Student Succeeds Act.