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PAGO PAGO, American Samoa (Samoa News, Aug. 5) - While appreciative of the progress ASG [American Samoa Government] has made with grant management and accountability issues dealing with U.S Department of Education grants [USDOE], more needs to be done in order for the 'high risk' status to be lifted, according to a USDOE official.

This was outlined in a June 19 letter to Gov. Togiola Tulafono about the latest review of USDOE funding for ASG, from Hudson La Force III, the USDOE senior counselor to the secretary.

La Force says the progress made by ASG will help "address the challenging grant management and accountability issues that ASG has been facing with regard to the administration of federal education grants.

However, La Force said ASG's status as a 'high risk' grantee will continue under federal regulations, and therefore "special conditions will be applied to program grants and funds awarded to ASG agencies from USDOE."

Under reporting requirements, ASG is to provide a detailed semiannual report on the administration by each USDOE funded program; the expenditures made by ASG that will satisfy the accountability needs of the USDOE Expenditure Report, and descriptions of the progress of each significant aspect of the program at school, ASDOE, and ASG levels (Program Progress Report).

The reports must show that the funds are being spent for allowable purposes, that sufficient program progress is being made, and that the funds drawn down are being recorded and spent in a timely manner with appropriate certifications.

The semiannual reports, signed by an authorized ASG representative shall include, among other things, progress made towards resolving audit findings on all matters affecting funds under grant programs, such as procurement and internal controls.

In addition to report student and teacher assessments, ASG must report on its consideration of, and progress in adopting, a 'transparent' budgeting and expenditure reporting system that would be readily available to the public, and USDOE and its representatives. This is so that all of these parties can easily understand the expenditures that are planned and carried out under each of the USDOE grant programs.

"At a minimum, ASG must post on an Internet web site (available to the general public) that it maintains, the budget, application, and reports mentioned above, and the information in the reports must be updated on the site on a monthly basis," according to USDOE. "ASDOE may continue to post its portion of the semiannual reports on its web site; however, ASG needs to report on its progress in this area as well."

USDOE also set a timeline of when these reports are to be submitted.

USDOE says all ASG's required single audits shall be completed and the report published within nine months after the end of each fiscal year as required by the Single Audit Act of 1984.

If the audit or report is expected to be delayed, ASG is to notify USDOE of the reason and extent of the delay as soon as possible.

Since ASG has made progress in submitting its delinquent single audits and is now in the position to submit its required single audits on a timely basis, USDOE says it will rely on ASG's single audits, along with monitoring conducted by USDOE, to perform oversight of ASG's administration of the grants.

However, if ASG is unable to submit timely and complete single audits, USDOE says it may again require ASG to provide USDOE with timely confirmation of the matters covered in its semi-annual reports through an independent oversight agent or an appropriate independent internal audit unit of ASG that would provide extra monitoring of ASG's expenditures and progress.

If USDOE determines that ASG has not made substantial progress in meeting the objectives of the programs, or has not met program requirements or the special conditions, the agency may consider not continuing the grant(s) or take additional action such as withholding funding for a grant program, according to the agency.

And if ASG fails to meet any of the special conditions cited in the letter, USDOE said it is authorized to take other appropriate enforcement action.

"We look forward to seeing continued progress as ASG works to address challenges in the areas of grants management and accountability and meets these special conditions," La Force wrote to Togiola.

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