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Federal COVID-era school relief funding and state grant oversight

Two staffers vetted Wisconsin's $151M pandemic-school fund

Summary

A federal audit found Wisconsin's Department of Public Instruction approved more than $20 million in pandemic aid for 184 nonpublic schools that did not meet the state's own low-income eligibility rule -- including 18 schools with zero low-income students enrolled -- while the office reviewing every application had just one full-time and one term employee. The U.S. Department of Education is now pressing Wisconsin to return the money; Wisconsin disputes every recommendation in the report.

By Frontinus · July 19, 2026

Wisconsin's Department of Public Instruction was awarded about $151.4 millionv100_508_SECURED.pdf) in federal Emergency Assistance to Nonpublic Schools (EANS) pandemic-relief funds -- money meant to help private schools serve low-income students through COVID-era disruptions. A U.S. Department of Education Office of Inspector General auditv100_508_SECURED.pdf) released September 29, 2025 found the state approved more than $20 million of it for 184 nonpublic schools that did not meet the low-income enrollment threshold Wisconsin itself had proposedv100_508_SECURED.pdf) -- among them 18 schools reporting zero low-income students. The office responsible for reviewing every application, the audit found, had one full-time employee and one term employeev100_508_SECURED.pdf).

A threshold Wisconsin set, then didn't enforce

Federal rules set a default: at least 40% of a nonpublic school's students had to come from low-income families to qualify for ARP EANS aid, though a state could apply to use a different percentage suited to its own circumstances. The Department approved Wisconsin's request to use 21.9%v100_508_SECURED.pdf) instead. But Wisconsin's application also said it would fund schools that had already drawn on the earlier CRRSA EANS program even if they fell short of that 21.9% mark -- an approach the Department later said, at a December 2024 meeting, it had overlooked when it approved Wisconsin's plan, and that it did not comply with federal requirementsv100_508_SECURED.pdf).

The result: 184 nonpublic schools ineligible under the state's own threshold received more than $20 millionv100_508_SECURED.pdf) in EANS-funded services and assistance. Auditors broke down how far short those schools fell -- 77 had 10% or less low-income enrollment, 38 had less than 5%, and 18 reported none at allv100_508_SECURED.pdf).

To ineligible schools
$20M+
of Wisconsin's $151.4 million EANS award, sent to 184 nonpublic schools that didn't meet the state's own low-income eligibility threshold
Staff reviewing applications
2
one full-time and one term employee vetted every nonpublic school's application across the entire $151.4 million program
Zero-low-income schools funded
18
of the 184 ineligible schools, reported zero low-income students yet still received ARP EANS aid meant to help schools serving low-income families
Wisconsin's EANS award vs. what went to ineligible schools
In dollars: Wisconsin's total EANS award compared with the portion the federal audit found went to schools that didn't meet its own eligibility rule
Total Wisconsin EANS award
151,400,000
Went to 184 ineligible schools
20,000,000
Source: U.S. Dept. of Education OIG, ED-OIG/A24NY0195 (Sept. 29, 2025), Results in Brief and Finding 1 (pp.7, 10)
View data as table
Wisconsin's Department of Public Instruction was awarded about $151.4 million in EANS funds. Of that, a federal audit found more than $20 million went to 184 nonpublic schools that did not meet the low-income enrollment threshold Wisconsin itself set for the program.
Total Wisconsin EANS award$151.4MCRRSA + ARP combined
Went to 184 ineligible schools$20M+13%+ of the total award
How far below the threshold the ineligible schools fell
Of the 184 ineligible schools, count with low-income enrollment at or below each level (nested subsets, not additive)
10% or below low-income
77
Below 5% low-income
38
0% low-income enrollment
18
Source: U.S. Dept. of Education OIG, ED-OIG/A24NY0195 (Sept. 29, 2025), Finding 1 (p.10)
View data as table
Each bar is a nested subset of the 184 ineligible schools, not a separate group: 77 had 10% or less low-income enrollment, including 38 with less than 5%, including 18 that reported zero low-income students at all -- yet all received funds meant to help schools serve low-income students through COVID disruptions.
10% or below low-income77of 184 total ineligible schools
Below 5% low-income38a subset of the 77
0% low-income enrollment18a subset of the 38 -- zero low-income students

Self-certification, checked by no one

Eligibility for EANS required a nonpublic school to be a nonprofit and to certify it had not taken a Paycheck Protection Program loan after December 27, 2020. Wisconsin had no process to independently verify either claimv100_508_SECURED.pdf) and relied entirely on schools' self-certification, because, officials told auditors, the two-person EANS office lacked the resources to checkv100_508_SECURED.pdf).

When ran the state's own applicant list against the Small Business Administration's PPP loan database, it found at least one school that had received a $202,987 PPP loan on March 12, 2021 and had improperly collected $838,829 in EANS-funded services and assistance as a resultv100_508_SECURED.pdf). Wisconsin later identified that school to reporters as Carter's Christian Academy in Milwaukee -- a 270-student school that separately draws about $3.2 million a year in Wisconsin taxpayer funding. The state told it had recovered the $838,829 from the school, but had not, as of the report, shown OIG that money reached the federal governmentv100_508_SECURED.pdf).

Two smaller findings round out the audit: $297,477 in EANS expenditures Wisconsin's contractor could not documentv100_508_SECURED.pdf) -- in some cases, no payroll or timesheet records to show that staff billed to a school actually worked there -- and $21,312 paid for services delivered roughly six months after the CRRSA EANS program had already endedv100_508_SECURED.pdf).

The audit's other dollar findings
Smaller sums the audit separately identifies as improperly paid, unsupported, or unremitted, in dollars
PPP-ineligible school (Finding 2)
838,829
Unsupported expenditures (Finding 3)
297,477
Paid outside program period (Finding 3)
21,312
Source: U.S. Dept. of Education OIG, ED-OIG/A24NY0195 (Sept. 29, 2025), Findings 2-3 (pp.14, 18-19)
View data as table
Beyond the $20 million-plus in Finding 1, the audit separately quantifies $838,829 paid to one nonpublic school that had an undisclosed PPP loan (Finding 2 -- Wisconsin recovered this from the school but had not shown OIG it reached the Department), $297,477 in expenditures the contractor could not document, and $21,312 paid for services delivered after the program period ended (both Finding 3). These are shown independently since each traces to a different finding and is not additive with Finding 1's total.
PPP-ineligible school (Finding 2)838,829recovered from the school by Wisconsin, not shown returned to the Department
Unsupported expenditures (Finding 3)297,477contractor could not document these
Paid outside program period (Finding 3)21,312services delivered ~6 months after CRRSA EANS ended

Wisconsin disputes it all

issued seven recommendations, and Wisconsin disagreed with the findings and every one of themv100_508_SECURED.pdf) in its formal written response. Seven months later, the Department's own press office was still listing the Wisconsin finding as an active fraud-and-waste case alongside pandemic-fund cases in Puerto Rico and West Virginia, and by late April 2026 the Trump administration was pressing Wisconsin's DPI to return the more than $20 million.

DPI spokesperson Chris Bucher countered that the state's approach had been explicitly approved by the Department in 2021 and that Wisconsin acted transparently throughout; School Choice Wisconsin president Ashley Czaja called the state's EANS record one of the best outcomes nationally, compared with states that returned money they couldn't distribute.

  • A federal audit found more than $20 million of Wisconsin's $151.4 million EANS award went to 184 nonpublic schools that missed the state's own low-income eligibility threshold, including 18 schools with zero low-income students.
  • The office vetting every application had one full-time and one term employee, and relied on schools' self-certification because it lacked resources to independently check nonprofit status or PPP-loan history.
  • Cross-checking the 's own PPP database, not Wisconsin's process, is what caught the $838,829 case found -- money the state says it recovered from the school but had not shown reached the Department.
  • Wisconsin disagreed with all seven of 's recommendations; as of late April 2026 the Department was still pressing the state to return the money, and Wisconsin was still refusing.

All dollar figures and staffing details in this piece trace to the audit report itself (ED-/A24NY0195), except the identification of the PPP-ineligible school as Carter's Christian Academy, its enrollment, and its separate annual state funding, plus the post-audit dispute quotes -- those come from Wisconsin Public Radio's April 2026 reporting, which DPI itself is the source for the school's name. The 77/38/18 low-income breakdown are nested subsets of the same 184 schools, not additive. Finding 1's $20 million figure is the report's own floor ('more than $20 million'); no more precise total is given, so the 13.2% share of the total award computed here is itself a floor.

Sources(3) ▾
  • U.S. Department of Education, Office of Inspector General, Wisconsin Department of Public Instruction's Administration and Oversight of Emergency Assistance to Nonpublic Schools Grant Funds (2025-09-29)The final ED- audit report (Control Number ED-/A24NY0195), transmitted to Governor Tony Evers and State Superintendent Jill Underly on September 29, 2025. Fetched directly as a PDF from oig.ed.gov and read in full. Used for every dollar figure and staffing detail in this piece: the Results in Brief, Finding 1 (ineligible-school threshold violation, pp.10-12), Finding 2 (unverified nonprofit/PPP status, pp.13-16), Finding 3 (contractor oversight and service fees, pp.17-22), the seven recommendations, and Wisconsin's point-by-point comments with the 's responses. oig.ed.gov · original document
  • U.S. Department of Education, Victories for American Taxpayers: Exposing COVID-Era Fraud, Waste, and Abuse in Federal Education Programs (2026-04-10)The Department's official press release rounding up recent findings on pandemic-era education fraud and waste nationally, including a one-paragraph summary of the Wisconsin EANS finding. Used to establish that the Department, seven months after the audit, is treating the Wisconsin finding as an active enforcement matter alongside Puerto Rico and West Virginia cases, and for the national funding totals (more than $276 billion for the Education Stabilization Fund, $5.5 billion of it for EANS) that frame the scope of the program. ed.gov · original document
  • Urban Milwaukee (republishing Wisconsin Public Radio, by Corrinne Hess), Trump Administration Wants Wisconsin to Return $20M in COVID-19 Funds (2026-04-28)News coverage of the Department's post-audit demand that Wisconsin return the money, published seven months after the report. Used only for what the primary audit does not itself contain: identifying the unnamed ineligible school in Finding 2 as Carter's Christian Academy in Milwaukee (per DPI, which named it to the reporter), that school's enrollment and separate annual state funding, and on-the-record reactions from DPI spokesperson Chris Bucher and School Choice Wisconsin president Ashley Czaja gathered after the audit's release. Not used as the source for any dollar figure the report itself states. urbanmilwaukee.com · original document
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