**UNITED STATES DEPARTMENT OF EDUCATION**

OFFICE OF INSPECTOR GENERAL

Audit Services

New York Audit Region

June 5, 2008

**Control Number**

**ED-OIG/A02H0003**

Wendy Kopp

Chief Executive Officer

Teach for America, Inc.

315 West 36^th^ Street, 6^th^ Floor

New York, NY 10018

Dear Ms. Kopp:

This **Final Audit Report,** entitled *Teach for America, Inc., Review
of the U.S. Department of Education Discretionary Grant Awards*,
presents the results of our audit. Our objective was to determine
whether Teach for America, Inc.'s (TFA's) discretionary grant
expenditures were allowable and spent in accordance with Federal laws
and regulations for the period, October 1, 2003, through September 30,
2005.

BACKGROUND

On October 6, 1989, TFA was incorporated as a non-profit corporation
with its headquarters located in New York City. TFA's mission is to help
eliminate educational inequity by enlisting the nation's most promising
future leaders in the effort. TFA focuses its efforts on building a
corps of outstanding recent college graduates of all academic majors who
commit two years to teach in urban and rural public schools and become
lifelong leaders in ensuring educational equity and excellence for all
children. Most TFA recruits do not have education-related majors in
college, and, therefore, have not received the same training as
traditional teachers.

TFA had 3,500 teachers (corps members) who provided services to 22
regions throughout the United States in school year 2005-2006. During
our October 1, 2003, through September 30, 2005 audit period, TFA
received grant awards from both the U.S. Department of Education (ED)
and the Corporation for National and Community Service (CNCS).
Specifically, ED's Office of Innovation and Improvement (OII) awarded
TFA six grants (see Attachment A) under the Programs of National
Significance, Funds For the Improvement of Education (FIE), of which
three grants were discretionary.[^1]

AUDIT RESULTS

TFA did not fully comply with applicable laws and regulations regarding
its discretionary grant expenditures. We found that \$774,944 (about 50
percent) of the total \$1,534,290 in expenditures sampled was
unsupported. TFA could not provide adequate supporting documentation
because it lacked sound fiscal accountability controls. As a result, we
could not determine whether \$774,944 was spent for the intended grant
purposes.

We provided a draft of this report to TFA for review and comment on
January 24, 2008. We reviewed TFA's response, including five attachments
received on March 7, 2008. TFA did not specifically concur or disagree
with the finding and recommendations, but it did generally agree that
its office supply charges lacked proper documentation. In addition, the
response to three of the five recommendations indicated general
concurrence. We summarized TFA's comments and our response following the
finding. Based on our analysis of TFA's comments and its additional
documentation, our finding and three of the five recommendations remain
unchanged. We revised recommendations 1.3 and 1.4 based on TFA's
comments.

The entire narrative of TFA's comments is included as Attachment B.
Because of the voluminous nature of the attachments to TFA's comments,
we have not included them in Attachment B. Copies of TFA's attachments
are available on request.

FINDING -- TFA Was Unable to Provide Adequate Support for \$774,944 of
its Discretionary Grant Expenditures

TFA could not adequately support about 50 percent of its discretionary
grant expenditures that we sampled. We randomly and judgmentally sampled
\$1,534,290 out of the total \$6,000,000 expended for the 3
discretionary grants awarded during our audit period. The sample
consisted of 26 expenditures for salary and non-salary expenditures. TFA
was not able to provide adequate support for 17 of these expenditures,
totaling \$774,944. TFA could not provide adequate supporting
documentation for its charges to these grants because of significant
deficiencies in its fiscal accountability controls.

During our audit period, TFA did not use a professional accounting
software package, and instead made use of manual input forms with
hand-written notes to account for and support its charges to the grant.
In addition, TFA lacked project identification numbers to track
expenditures for two of the three discretionary grants. Without project
numbers, the expenditures could not be properly identified and
monitored. Although TFA had a project number for one discretionary
grant, the general ledger reports did not show the total amount of
expenditures. Table 1 identifies the \$774,944 in unsupported
expenditures with detailed explanations provided below.

  ------------------------ ------------------------ ---------------------------
  **Table 1: Unsupported                            
  Costs**                                           

  **[Grant                 **[Amount                **[Unsupported
  Number]{.underline}**    Sampled]{.underline}**   Amount]{.underline}**

  U215U040025              \$705,360                \$405,704

  U215U030034              802,118                  342,428

  U215U030014              26,812                   26,812

  **Total**                **\$1,534,290**          **\$774,944**
  ------------------------ ------------------------ ---------------------------

According to 34 C.F.R. § 75.730 (July 1, 2003), "A grantee shall keep
records that fully show: (a) The amount of funds under the grant; (b)
How the grantee uses the funds; . . . and (e) Other Records to
facilitate an effective audit."

Section 1232f(a) of 20 U.S.C. (January 24, 2002) states, "Each recipient
of Federal Funds under any applicable program through any grant . . .
shall keep records which fully disclose the amount and disposition by
the recipient of those funds, the total cost of the activity for which
the funds are used, the share of that cost provided from other sources
and such other records as will facilitate an effective financial or
programmatic audit. The recipient shall maintain such records for three
years after the completion of the activity for which the funds are
used."

OMB Circular A-122, "Cost Principles for Non-Profit Organizations,"
revised May 10, 2004, states that to be allowable under an award, costs
must meet the following general criteria:

a.  Be reasonable for the performance of the award and be allocable
    thereto under these principles.

b.  Conform to any limitations or exclusions set forth in these
    principles or in the award as to types or amount of cost items.

c.  Be consistent with policies and procedures that apply uniformly to
    both federally financed and other activities of the organization.

d.  Be accorded consistent treatment.

e.  Be determined in accordance with generally accepted accounting
    principles (GAAP).

f.  Not be included as a cost or used to meet cost sharing or matching
    requirements of any other federally financed program in either the
    current or a prior period.

g.  Be adequately documented.

According to OMB Circular A-133 § 300(b) (June 24, 1997), "The auditee
shall . . . \[m\]aintain internal control over Federal programs that
provides reasonable assurance that the auditee is managing Federal
awards in compliance with laws, regulations, and the provisions of
contracts or grant agreements that could have a material effect on each
of its Federal programs."

TFA was unable to produce adequate documentation to support \$774,944 of
its discretionary grant expenditures shown in the following examples.

[Unsupported costs for grant number U215U040025]{.underline}

TFA could not provide adequate supporting documentation for \$405,704 of
the \$705,360 in expenditures we sampled that were charged to grant
number U215U040025. The purpose of this grant was to enhance the
recruitment and professional training for TFA teachers. TFA used a
portion of this grant to pay for food and lodging costs, TFA corps
members salaries, and office supplies during the period December 2004 to
September 2005.

*Unsupported Costs for California State University*

We judgmentally sampled TFA's expenditure of \$277,262 in institute food
and lodging costs for California State University. In response to our
request for all supporting documentation for this expenditure, TFA
provided a copy of California State University's "Institute Pay Schedule
Worksheet." This document indicated that the grant was to provide 49
percent of \$565,841, or a net amount of \$277,262. However, TFA did not
provide any source documentation showing the attendees, teachers,
content, or any other details. Therefore, the claimed expenditure of
\$277,262 was not adequately supported.

*Unsupported Costs for Temple University*

We judgmentally sampled TFA's expenditure of \$287,940 for food and
lodging at Temple University. However, TFA did not provide adequate
support for \$123,878. TFA provided only a one-page Microsoft Excel
spreadsheet that listed this expenditure as a "10% Down Payment." TFA
provided no other explanation or documentation, such as attendance
sheets or lists of participants. Based on this limited documentation, we
were unable to determine the validity of, or the reason for, the claimed
costs of \$123,878.

*Unsupported expenditures for Office Supplies*

TFA also charged ED grant number U215U040025 to pay for office supply
charges. During December 15, 2004 through June 28, 2005, TFA charged
\$20,368 for several office supply purchases. We randomly sampled four
expenditures totaling \$4,564 for office supplies charged to this grant.

TFA could not provide specific invoices or documentation for the \$4,564
in supply charges. In addition, TFA's Vice President of Accounting and
Controls acknowledged that this charge was not adequately supported, and
because of the amount of the unsupported costs and time it would take to
research the documentation, it would not be beneficial to go any further
to support the expenditure. Therefore, this expenditure of \$4,564 is
unsupported.

[Unsupported costs for grant number U215U030034]{.underline}

TFA could not provide adequate supporting documentation for \$342,428 of
the \$802,118 in expenditures we sampled that were charged to grant
number U215U030034. The purpose of this grant was to enhance pre-service
training of teachers. TFA used a portion of this grant to pay for food
and lodging costs from June 2004 to September 2004, for corps members
attending the University of Houston.

Included in our sampling, was a judgmental sample of the largest
expenditure for this grant, \$342,428. We found that TFA could not
support this expenditure because it could not provide documentation for
the students and staff who attended this training. TFA provided a
one-page summary that listed 93 staff members, but only 85 had actually
confirmed their training attendance by signing the attendance list.
Furthermore, there was no documentation identifying the staff members or
that they were eligible to receive food and lodging costs.

Similarly, TFA provided and relied on copies of Microsoft Excel
spreadsheets, and in some cases, on hand-written notes, to document and
support ED discretionary grant expenditures. For example, TFA claimed
672 students attended this course, but this claim was not supported by a
hand-written sign-in list. TFA provided no documentation or attendance
list that these students were actually enrolled in the program. On
several occasions, TFA claimed more than 800 staff and students received
lunch or dinner. The documentation indicated that on June 28, 2004, 811
participants received lunch, and on June 15, 2004, 899 participants
received lunch. However, the documentation did not support the claimed
number of participants. There was no agenda, no description of the
meals, and no list of attendees.

On several occasions, we requested additional documentation from TFA's
Vice President of Accounting and Controls, but she did not provide us
with adequate supporting documentation or an explanation of the
expenditures. The documentation provided was primarily copies (not
original documents) and there was no effective way to verify the
validity of the staff and students actually participating in the program
or the food and lodging costs claimed.

In addition to the regular meal reimbursements, we noted that a single
meal charge was claimed on invoices without proper documentation. On
July 10, 2004, \$858 was charged for one meal at Moody Towers, and on
June 23, 2004, a one-time meal charge was submitted for \$471 with no
documentation of who participated or the reason for the charge.

[Unsupported Costs for grant number U215U030014]{.underline}

TFA could not provide adequate supporting documentation for the \$26,812
in expenditures we sampled that were charged to grant number
U215U030014. The purpose of this grant was to expand TFA impact by
increasing the number of highly qualified teachers in our nation's
highest-need schools. TFA used this grant to pay for the alternate
certification of TFA corps members.

TFA provided payment requests for the total amount disbursed of
\$26,812, along with checks for this amount and certification cost
reimbursement forms signed by the students. However, this documentation
was insufficient because it did not indicate that the students actually
attended and satisfactorily completed the classes. There were no
official transcripts or evidence that the courses occurred. Therefore,
\$26,812 of claimed certificate reimbursement expenditures was not
adequately supported.

The unsupported expenditures occurred primarily because TFA did not have
an adequate accounting system in place to support, properly document,
and monitor its ED grant expenditures. We generally were not provided
with original source documentation, but instead were provided
hand-written notes and other materials that were duplicates. TFA also
did not have written policies and procedures[^2] for its accounting and
specific fiscal internal control processes within its organization. Due
to the lack of proper fiscal accountability controls, such as use of a
professional accounting software package, and lack of proper supporting
documentation, there was no effective way to verify the validity of the
costs claimed. As a result, we found that TFA charged unsupported
expenditures of \$774,944 to ED discretionary grants during the October
1, 2003 through September 30, 2005 period. Consequently, there is no
assurance that these grant funds were properly expended in accordance
with the grant objectives to train and support teachers who teach
disadvantaged students at the nation's neediest schools.

**[Recommendations]{.underline}**

We recommend that the Assistant Deputy Secretary for the Office of
Innovation and Improvement require TFA to:

1.1 Provide support for the \$774,944 in non-salary ED discretionary
grant expenditures, or return the funds, with applicable interest, to
ED.

1.2 Provide support for the remaining \$4,465,710 in salary and
non-salary ED discretionary grant expenditures, or return the funds,
with applicable interest, to ED.

1.3 Provide evidence that TFA implemented a professional accounting
system that would enable TFA to support, properly document, and monitor
its ED grant expenditures as required by Federal laws and regulations.

1.4 Provide evidence that TFA established and implemented adequate
written policies and procedures for its accounting and specific fiscal
internal control processes within its organization.

1.5 Maintain required supporting documentation for costs charged to ED's
discretionary grants.

**TFA's Comment**s

In its response to the draft report, TFA did not specifically concur or
disagree with the finding and recommendations, but it did generally
agree that its office supply charges lacked proper documentation.
Regarding the finding, TFA stated the ED grant funds were spent as
directed by the terms of the grants. TFA also stated that the questioned
costs outlined in the draft report were the result of tracking systems
that differ from the systems utilized by TFA in the past which have,
according to TFA, been updated with new personnel and procedures to
effectively monitor existing and future grants. Further, TFA indicated
that it could demonstrate that its corps and staff members attended the
institutes and it could also demonstrate with full confidence that the
questioned food costs were incurred and that the funds were spent
appropriately. TFA stated that all costs related to its summer training
institutes came from its contracts with universities that provided food
and lodging for corps and staff members during fully residential summer
training. TFA also provided statements indicating five corps members had
completed their required course work.

In response to recommendations 1.1 and 1.2, TFA stated it provided
additional documentation which indicated ED funds were utilized in
accordance with required provisions and regulations. TFA provided
extensive spreadsheets with lists of corps members and institute staff,
by location, that TFA contended participated in various institutes from
2003 through 2005. For grant number U215U030034, TFA provided
spreadsheets that showed there were 111 staff members and 725 corps
members, including 26 resignations, who attended the University of
Houston's summer training from June through September 2004. Regarding
the unsupported supply costs, TFA stated that the lack of supporting
documentation was the result of turnover of prior grants and contracts
staff coupled with the limitations of the legacy document storage
systems in place during the time under question.

For recommendation 1.3, TFA stated that beginning in March 2006, the new
grants and contracts team at TFA designed and implemented a
comprehensive accounting system to properly budget, document, report,
and monitor its ED grant expenditures.

For recommendation 1.4, TFA stated it introduced formal updated fiscal
policies on October 1, 2006. In addition, TFA said it published a
finance guide to communicate formal, operational processes to its budget
managers and end-users.

For recommendation 1.5, TFA stated it had an ongoing commitment to build
proper infrastructure and processes for maintaining appropriate source
documentation, including vendor invoices, and corps and staff member
data. In addition, TFA said it had enhanced its chart of accounts to
incorporate funding source codes in place of its old Excel spreadsheets.
This enhancement took effect during the 2005-2006 funding year.

**OIG Response**

We considered TFA's response; however, our finding and three of the five
recommendations remain unchanged. We revised recommendations 1.3 and 1.4
based on TFA's comments. TFA did not specifically concur or disagree
with the finding and recommendations, but it did generally agree that
its office supply charges lacked proper documentation.

For recommendations 1.1 and 1.2, the spreadsheets that TFA provided in
its response for its corps and staff members have significant
discrepancies from previously provided documentation. Furthermore, these
spreadsheets were not provided during the audit. TFA's response did not
provide sufficient documentation that its corps members actually
attended and completed the classes or that the staff members attended
the University of Houston summer training institute from June through
September 2004.

In its response, TFA provided a spreadsheet for 725 corps members,
including 26 corps members who reportedly resigned, who attended the
University of Houston summer institute during this time period. However,
TFA did not indicate when the resignations occurred. During our audit,
TFA provided OIG with a hard copy list indicating 672 corps members,
with no resignations, who attended the program at that time, for a
difference from the response spreadsheet of 53. We also noted other
discrepancies between the original list and the response spreadsheet.
Specifically, the original list had 51 students who were not on the
response spreadsheet, and the response spreadsheet had 104 students who
were not on the original list.

In its response, TFA provided a spreadsheet which listed 111 staff
members at TFA's University of Houston summer institute from June
through September 2004. In contrast, during the audit fieldwork, TFA
provided OIG a manually prepared sign-in list that showed a total of 93
staff at the University of Houston during this time period. The list had
93 hand-written names and spaces for signatures, but only 85 had
confirmed their attendance by signing the list. We compared the response
spreadsheet to the manual list and noted 86 staff were on both lists,
but the response list also indicated 25 additional staff members.

The discrepancies between the original hand-written lists provided
during the audit and the spreadsheets provided in response to the draft
report raised more questions regarding the validity of the source,
accuracy, and reliability of the documentation TFA provided for its
corps and staff members. Furthermore, TFA indicated in its response, it
was not able to provide data for the individual meals and that it did
not maintain corps member sign in sheets.

TFA stated that all costs related to its summer training institutes came
from its contracts with universities that provided food and lodging for
corps and staff members during fully residential summer training.
However, TFA did not provide any documentation of these contracts or
specific cost documentation for the claimed costs. TFA also provided
statements indicating five corps members had completed their required
course work. However, this documentation did not prove that these corps
members had a license, certificate, or permit to teach students in a
public classroom as required by city and state laws in each of the
districts in which they operated. TFA attributed its lack of supporting
documentation for office supply costs to its turnover of prior grants
and contracts staff coupled with the limitations of its document storage
systems in place at that time. TFA's response did not provide sufficient
additional information to what it provided previously, and is therefore,
insufficient support for the \$774,944 of expenditures charged to ED's
discretionary grants.

TFA's response to recommendations 1.3 and 1.4 indicated that it had
implemented a comprehensive accounting system, and updated fiscal
policies and procedures, to address these recommendations. However, we
did not review the new accounting system or the updated fiscal policies
and procedures as stated in TFA's response because this was not in the
scope of our review. We consider the actions taken to address
recommendation 1.5 as TFA's general concurrence to this recommendation.

OBJECTIVE, SCOPE, AND METHODOLOGY

Our audit objective was to determine whether TFA's discretionary grant
expenditures were allowable and spent in accordance with Federal laws
and regulations for the period, October 1 2003 through September 30,
2005.

To ensure the completeness and accuracy of the data provided by TFA, we
obtained and extracted from TFA's accounting system, all expenditures
related to the discretionary grants for the period, October 1, 2003
through September 30, 2005. Expenditures for the three discretionary
grants awarded during the audit period, grant numbers U215U030014,
U215U030034, and U215U040025, totaled \$6,000,000. This constituted our
discretionary grant expenditure universe.

We used different sampling methodologies on each of the three grants
reviewed due to the varying type and nature of the expenditures charged
to each grant. We randomly sampled and reviewed a total of \$166,970 in
salary and non-salary expenditures charged to two grants. Of this
amount, \$26,812 in student alternate certifications was expended in
grant U215U030014, \$135,594 was expended for salaries in grant
U215U040025, and \$4,564 was expended for supplies.

In addition, we judgmentally selected \$1,367,320 in expenditures for
non-salary charges in two of the three grants. Grant U215U030034 had 14
expenditures where we selected the largest dollar expenditures from the
University of Houston, Fordham University, and California

State University, totalling \$781,178, and the smallest expenditure,
\$20,940, charged to this grant. We also judgmentally sampled the two
largest expenditures for Temple University and California State
University, totalling \$565,202, charged to grant U215U040025 for food
and lodging costs.

To accomplish our objective we:

a.  Reviewed TFA approved grant applications and related budgets;

b.  Policies and procedures;

c.  Interviewed the TFA's Vice President of Accounting and Controls;

d.  Reviewed TFA's written policy manual and organizational charts to
    gain an understanding of the accounting process;

e.  Reviewed the Independent Public Accountant reports for TFA for the
    periods ending September 30, 2003, 2004, and 2005; and

f.  Reviewed the General Ledger Report for one grant.

We concluded that the data was sufficiently reliable to support the
finding, conclusions, and recommendations, and that using the data would
not lead to an incorrect or inaccurate conclusion.

We performed our fieldwork at TFA's Headquarters at 315 West 36th
Street, New York, New York, from December 4, 2006, through March 9,
2007. We conducted the audit in accordance with generally accepted
government auditing standards appropriate to the limited scope of the
audit described above.

ADMINISTRATIVE MATTERS

Statements that managerial practices need improvements, as well as other
conclusions and recommendations in this report, represent the opinions
of the Office of Inspector General. Determinations of corrective action
to be taken, including the recovery of funds, will be made by the
appropriate Department of Education officials in accordance with the
General Education Provision Act.

If you have any additional comments or information that you believe may
have a bearing on the resolution of this audit, you should send them
directly to the following Department of Education official, who will
consider them before taking final Departmental action on this audit:

> Doug Mesecar
>
> Assistant Deputy Secretary for Innovation and Improvement
>
> Office of Innovation and Improvement

U.S. Department of Education

400 Maryland Avenue, SW

Washington, DC 20202

It is the policy of the U. S. Department of Education to expedite the
resolution of audits by initiating timely action on the finding and
recommendations contained therein. Therefore, receipt of your comments
within 30 days would be appreciated.

In accordance with the Freedom of Information Act (5 U.S.C. § 552),
reports issued by the Office of Inspector General are available to
members of the press and general public to the extent information
contained therein is not subject to exemptions in the Act.

If you have any further questions, please call me at (646) 428-3888.

> Sincerely,
>
> /s/
>
> Daniel P. Schultz
>
> Regional Inspector General
>
> for Audit

Attachments

**Attachment A**

**ED Grants Received by TFA**

**October 1, 2003 through September 30 2005**

+-------------+-----------+-------------+---------+--------------------+
| **Grant     | **TFA     | **Award**   | **      | **TFA Proposed Use |
| Number**    | Project   |             | Grant** | of Funds**         |
|             | No.**     | **Period**  |         |                    |
|             |           |             | **      |                    |
|             | **If      |             | Award** |                    |
|             | Exis      |             |         |                    |
|             | ted**[^3] |             |         |                    |
+-------------+-----------+-------------+---------+--------------------+
| **Di        |           |             |         |                    |
| scretionary |           |             |         |                    |
| Grants**    |           |             |         |                    |
+-------------+-----------+-------------+---------+--------------------+
| U215U030014 | **No      | 10/01/03-   | \$2,    | Expanding TFA      |
|             | Project   |             | 000,000 | impact: increasing |
|             | Number**  | 9/30/04     |         | the number of      |
|             |           |             |         | highly qualified   |
|             |           |             |         | teachers in our    |
|             |           |             |         | nation's           |
|             |           |             |         | highest-need       |
|             |           |             |         | schools            |
+-------------+-----------+-------------+---------+--------------------+
| U215U030034 | **No      | 10/01/03-   | 2,      | Enhancing the      |
|             | Project   |             | 000,000 | pre-service        |
|             | Number**  | 9/30/04     |         | professional       |
|             |           |             |         | training for TFA   |
|             |           |             |         | teachers in our    |
|             |           |             |         | nation's           |
|             |           |             |         | highest-need       |
|             |           |             |         | schools            |
+-------------+-----------+-------------+---------+--------------------+
| U215U040025 | **Project | 10/01/04-   | 2,      | Enhancing the      |
|             | No.**     |             | 000,000 | recruitment and    |
|             |           | 9/30/05     |         | professional       |
|             | **38-900  |             |         | training for TFA   |
|             | -04-006** |             |         | teachers           |
+-------------+-----------+-------------+---------+--------------------+
| **Di        |           |             | *       |                    |
| scretionary |           |             | *\$6,00 |                    |
| Total**     |           |             | 0,000** |                    |
+-------------+-----------+-------------+---------+--------------------+
| *           |           |             |         |                    |
| *Earmarks** |           |             |         |                    |
+-------------+-----------+-------------+---------+--------------------+
| U215K040231 | **No      | 08/03/04-   | \$1,    | Building TFA's     |
|             | Project   |             | 988,200 | capacity           |
|             | Number**  | 08/02/05    |         |                    |
+-------------+-----------+-------------+---------+--------------------+
| U215K050481 | **Project | 08/22/05-   | 992,000 | Building capacity  |
|             | No.**     |             |         | to maximize        |
|             |           | 08/21/06    |         | effectiveness for  |
|             | **38-900  |             |         | TFA teachers       |
|             | -05-002** |             |         |                    |
+-------------+-----------+-------------+---------+--------------------+
| U215K050483 | **Project | 08/22/05-   | 248,000 | Expanding TFA's    |
|             | No.**     |             |         | impact in the      |
|             |           | 08/21/06    |         | Clark County       |
|             | **38-138  |             |         | School District in |
|             | -05-003** |             |         | Las Vegas, NV      |
+-------------+-----------+-------------+---------+--------------------+
| **Earmarks  |           |             | **\$3   |                    |
| Total**     |           |             | ,228,20 |                    |
|             |           |             | ****0** |                    |
+-------------+-----------+-------------+---------+--------------------+
| **Total**   |           |             | *       |                    |
|             |           |             | *\$9,22 |                    |
|             |           |             | 8,200** |                    |
+-------------+-----------+-------------+---------+--------------------+

**Attachment** **B**

TFA Comments on the Draft Report

![](media/image1.wmf){width="6.497222222222222in"
height="8.391666666666667in"}

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height="8.222222222222221in"}

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height="8.302777777777777in"}

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height="8.386805555555556in"}

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height="8.395833333333334in"}

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height="8.431944444444444in"}

[^1]: The FIE authorizes the Secretary of Education to support
    nationally significant programs to improve the quality of elementary
    and secondary education at the state and local level and to help all
    students meet challenging state academic content and student
    achievement standards.

[^2]: The policies and procedures provided to OIG for review were not
    signed or initialed and were from 2007 forward.

[^3]: These project numbers were assigned by TFA to track and monitor
    Federal expenditures in the TFA accounting system and general
    ledger. Out of the three discretionary grants reviewed, only one had
    a project number assigned for the purpose outlined above.