Signal or Static? Unpacking ESSER Expenditures with Benford’s Law

• In Event: Money Talks: Implementing and Interpreting Values Through Education Finance Policy

Abstract

The COVID-19 pandemic prompted an unprecedented influx of federal funding into the U.S. K–12 education system through the Elementary and Secondary School Emergency Relief (ESSER) programs. This paper applies Benford’s Law, a mathematical principle often used in forensic accounting, to assess the validity of federally reported financial figures. Applying mean absolute deviation and Euclidean distance measures, we find that while overall data generally align with Benford’s Law, several states, districts, and spending categories show significant deviations. Non-random missingness also complicates future analyses. These findings raise concerns for researchers, policymakers, and analysts using ESSER data. We recommend that future federal reporting efforts prioritize fewer, high-value, preplanned metrics with built-in incentives for accuracy, rather than relying on broad, retroactive data collection.

Author

• Jason Godfrey, Harvard University