Audit Report on the Department of Education’s Controls over the Distribution of Remote Learning Devices

Executive Summary

The Department of Education (DOE) provides primary and secondary education to over one million students, from early childhood to grade 12, in over 1,800 schools. DOE prepares students to meet grade level standards in reading, writing, and math, and prepares high school students to graduate ready for college and careers.

Due to the COVID-19 pandemic, DOE was forced to close its schools and transition to remote learning in March 2020. However, many students were unable to participate in remote learning because they did not have a device or internet at home.

To address the needs of these students, DOE’s Division of Instructional and Information Technology (DIIT) was tasked with procuring, preparing, and distributing internet-enabled iPads to the hundreds of thousands of students who needed them.  To receive a centrally-issued DOE iPad, a family needed to submit a request (one request per child) using the online request form or call DOE’s Helpdesk or 311.

Some schools provided devices they had in their inventory to students last year during the beginning of remote learning, but this was done independently from the distribution of devices by DIIT.

Due to a limited supply of iPads during the early stages of the pandemic, requests needed to be prioritized. Through April 17, 2020, requests were ranked in order of priority, and only prioritized requests were fulfilled from each batch.  According to DOE, as of April 17, 2020, requests were no longer prioritized because it had enough supply to fulfill all requests.

According to DOE officials, 357,000 iPads were purchased for distribution during School Year 2019-2020, 104,000 iPads were purchased for distribution during School Year 2020-2021, and an additional 50,000 iPads were purchased in December 2020 to fulfill the remaining outstanding requests. According to DOE, the agency spent approximately $287 million for the 511,000 iPads.  DOE also pays approximately $4 million a month for the data plans for these devices.

Audit Findings and Conclusions

In the face of the COVID-19 pandemic, DOE was called on to procure and distribute remote learning devices to its students system-wide to enable remote learning, with no advance planning and under extreme time constraints. While we fully recognize the difficult situation that DOE was in, we found several inadequacies in DOE’s controls over the distribution of remote learning devices that increased the risk of waste, fraud, and abuse. Specifically:

• DOE does not centrally track devices schools issued from their in-house inventories to help ensure that DIIT does not issue additional devices to students who already received them from their schools.
• DOE has not formalized procedures for the tracking and distribution of devices, which increased the risk that the criteria for device request validation, device distribution, and device recall would not be understood and applied on a consistent basis throughout DOE, including at the numerous individual schools throughout the City that, as of School Year 2020-2021, review and validate students’ requests.
• DOE does not perform timely reviews of device-related data. DOE does not have an ongoing process for tracking and reconciling requests for devices and devices that have been distributed.
• Deficiencies exist in DOE’s management of control numbers, specifically, request IDs from DOE’s request data and asset tag numbers assigned to iPads were not sequential.

DOE has, however, developed controls that, if they function as designed, may provide reasonable assurance that DIIT will not issue students more than one device through DOE’s remote learning device program. While these controls would not address the possibility that additional devices could be issued to students by their individual schools, it would, if implemented as intended, reduce the chance that DIIT itself would issue more than one device to an individual student.

According to DIIT’s Chief Technology Officer, of the 357,000 devices purchased in April and June 2020, 3,045 students received more than one of these devices, which could result in the inequitable distribution of devices. As of April 2021, DOE was still reconciling its data; consequently, this number could potentially increase. Based on the data deficiencies discussed above, we are unable to identify:

• the actual number of students who were issued devices by DIIT; and
• the number of devices that were shipped to all of the students who received a device from DIIT.

If the weaknesses we identified in this audit are not corrected, DOE will have increased difficulty distributing devices in an equitable manner and ensuring that students who are in need of a device receive one.

Audit Recommendations

Based on the audit, we make 10 recommendations, including:

• DOE should ensure that a central tracking system to account for all devices issued to students is established, regardless of whether they are issued by DIIT or by schools from their in-house inventories.
• DOE should develop and timely disseminate detailed written policies and procedures governing the agency’s management of validating student requests for a device, distributing and tracking those devices, and recalling those devices, including specific return deadlines.
• DOE should ensure that its device request data is reconciled to the device distribution data to provide an accurate account for all requests made and for the students who received devices.
• DOE should ensure that Request IDs are issued in sequential order and tracked, and that any gaps in these numbers are investigated in a timely manner and the reasons for them adequately documented.
• DOE should modify its policy to ensure that asset tag numbers are issued in sequential order and tracked, and that going forward, any gaps in these numbers are investigated in a timely manner and the reasons for them adequately documented.
• DOE should take steps to ensure that the remaining devices that were shipped to students in error are returned and put back into inventory to be distributed if needed.
• DOE should take appropriate action where devices have not been returned, including referring matters to the agency’s investigative units or DOE’s Special Commissioner for Investigation when war

Agency Response

In its response, DOE agreed with 8 of the audit’s 10 recommendations. However, for two of these recommendations (#3 and #4), officials’ assertion that the agency was already in compliance is contradicted by the audit findings. Additionally, DOE disagreed with the audit’s recommendations that it ensure that Request IDs and asset tag numbers are issued in sequential order and tracked (#7 and #8). DOE also disagreed with some of the report’s findings and conclusions relating to the agency’s reviews of device-related data and the sequential numbering of request IDs and asset tag numbers. After carefully reviewing DOE’s response, we find no basis to alter any of the report’s findings or recommendations.