Audit 307944

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001 Program Names/Assistance Listing Titles: COVID‐19 Emergency Connectivity Fund Program; Special Education Cluster Assistance Listing Numbers: 32.009, 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: N/A, H027A220007, H027X210007, H173A220003, H173X210003 Questioned Costs: N/A Federal Agencies: Federal Communications Commission, U.S. Department of Education Pass‐Through Agencies: N/A, Arizona Department of Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment Criteria Non‐Federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Condition Verification of suspension and debarment was not performed for one vendor the District utilized in each of these programs, with whom the District spent at least $25,000 of federal grant monies. Cause Due to turnover in the procurement department, the District did not perform due diligence for the cooperative contracts used to make the purchases, therefore documentation was not prepared or maintained for verification of suspension and debarment. Effect The District was not in compliance with the requirements set forth by the federal government. However, it was subsequently determined that the two vendors utilized were not suspended or debarred. Context For one vendor the District utilized in each of these programs, the District did not perform or document its verification of whether the vendor was suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should follow purchasing policies and procedures established to ensure compliance with federal requirements regarding suspension and debarment. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001 Program Names/Assistance Listing Titles: COVID‐19 Emergency Connectivity Fund Program; Special Education Cluster Assistance Listing Numbers: 32.009, 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: N/A, H027A220007, H027X210007, H173A220003, H173X210003 Questioned Costs: N/A Federal Agencies: Federal Communications Commission, U.S. Department of Education Pass‐Through Agencies: N/A, Arizona Department of Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment Criteria Non‐Federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Condition Verification of suspension and debarment was not performed for one vendor the District utilized in each of these programs, with whom the District spent at least $25,000 of federal grant monies. Cause Due to turnover in the procurement department, the District did not perform due diligence for the cooperative contracts used to make the purchases, therefore documentation was not prepared or maintained for verification of suspension and debarment. Effect The District was not in compliance with the requirements set forth by the federal government. However, it was subsequently determined that the two vendors utilized were not suspended or debarred. Context For one vendor the District utilized in each of these programs, the District did not perform or document its verification of whether the vendor was suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should follow purchasing policies and procedures established to ensure compliance with federal requirements regarding suspension and debarment. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001 Program Names/Assistance Listing Titles: COVID‐19 Emergency Connectivity Fund Program; Special Education Cluster Assistance Listing Numbers: 32.009, 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: N/A, H027A220007, H027X210007, H173A220003, H173X210003 Questioned Costs: N/A Federal Agencies: Federal Communications Commission, U.S. Department of Education Pass‐Through Agencies: N/A, Arizona Department of Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment Criteria Non‐Federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Condition Verification of suspension and debarment was not performed for one vendor the District utilized in each of these programs, with whom the District spent at least $25,000 of federal grant monies. Cause Due to turnover in the procurement department, the District did not perform due diligence for the cooperative contracts used to make the purchases, therefore documentation was not prepared or maintained for verification of suspension and debarment. Effect The District was not in compliance with the requirements set forth by the federal government. However, it was subsequently determined that the two vendors utilized were not suspended or debarred. Context For one vendor the District utilized in each of these programs, the District did not perform or document its verification of whether the vendor was suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should follow purchasing policies and procedures established to ensure compliance with federal requirements regarding suspension and debarment. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001 Program Names/Assistance Listing Titles: COVID‐19 Emergency Connectivity Fund Program; Special Education Cluster Assistance Listing Numbers: 32.009, 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: N/A, H027A220007, H027X210007, H173A220003, H173X210003 Questioned Costs: N/A Federal Agencies: Federal Communications Commission, U.S. Department of Education Pass‐Through Agencies: N/A, Arizona Department of Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment Criteria Non‐Federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Condition Verification of suspension and debarment was not performed for one vendor the District utilized in each of these programs, with whom the District spent at least $25,000 of federal grant monies. Cause Due to turnover in the procurement department, the District did not perform due diligence for the cooperative contracts used to make the purchases, therefore documentation was not prepared or maintained for verification of suspension and debarment. Effect The District was not in compliance with the requirements set forth by the federal government. However, it was subsequently determined that the two vendors utilized were not suspended or debarred. Context For one vendor the District utilized in each of these programs, the District did not perform or document its verification of whether the vendor was suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should follow purchasing policies and procedures established to ensure compliance with federal requirements regarding suspension and debarment. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001 Program Names/Assistance Listing Titles: COVID‐19 Emergency Connectivity Fund Program; Special Education Cluster Assistance Listing Numbers: 32.009, 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: N/A, H027A220007, H027X210007, H173A220003, H173X210003 Questioned Costs: N/A Federal Agencies: Federal Communications Commission, U.S. Department of Education Pass‐Through Agencies: N/A, Arizona Department of Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment Criteria Non‐Federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Condition Verification of suspension and debarment was not performed for one vendor the District utilized in each of these programs, with whom the District spent at least $25,000 of federal grant monies. Cause Due to turnover in the procurement department, the District did not perform due diligence for the cooperative contracts used to make the purchases, therefore documentation was not prepared or maintained for verification of suspension and debarment. Effect The District was not in compliance with the requirements set forth by the federal government. However, it was subsequently determined that the two vendors utilized were not suspended or debarred. Context For one vendor the District utilized in each of these programs, the District did not perform or document its verification of whether the vendor was suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should follow purchasing policies and procedures established to ensure compliance with federal requirements regarding suspension and debarment. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001 Program Names/Assistance Listing Titles: COVID‐19 Emergency Connectivity Fund Program; Special Education Cluster Assistance Listing Numbers: 32.009, 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: N/A, H027A220007, H027X210007, H173A220003, H173X210003 Questioned Costs: N/A Federal Agencies: Federal Communications Commission, U.S. Department of Education Pass‐Through Agencies: N/A, Arizona Department of Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment Criteria Non‐Federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Condition Verification of suspension and debarment was not performed for one vendor the District utilized in each of these programs, with whom the District spent at least $25,000 of federal grant monies. Cause Due to turnover in the procurement department, the District did not perform due diligence for the cooperative contracts used to make the purchases, therefore documentation was not prepared or maintained for verification of suspension and debarment. Effect The District was not in compliance with the requirements set forth by the federal government. However, it was subsequently determined that the two vendors utilized were not suspended or debarred. Context For one vendor the District utilized in each of these programs, the District did not perform or document its verification of whether the vendor was suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should follow purchasing policies and procedures established to ensure compliance with federal requirements regarding suspension and debarment. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001 Program Names/Assistance Listing Titles: COVID‐19 Emergency Connectivity Fund Program; Special Education Cluster Assistance Listing Numbers: 32.009, 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: N/A, H027A220007, H027X210007, H173A220003, H173X210003 Questioned Costs: N/A Federal Agencies: Federal Communications Commission, U.S. Department of Education Pass‐Through Agencies: N/A, Arizona Department of Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment Criteria Non‐Federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Condition Verification of suspension and debarment was not performed for one vendor the District utilized in each of these programs, with whom the District spent at least $25,000 of federal grant monies. Cause Due to turnover in the procurement department, the District did not perform due diligence for the cooperative contracts used to make the purchases, therefore documentation was not prepared or maintained for verification of suspension and debarment. Effect The District was not in compliance with the requirements set forth by the federal government. However, it was subsequently determined that the two vendors utilized were not suspended or debarred. Context For one vendor the District utilized in each of these programs, the District did not perform or document its verification of whether the vendor was suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should follow purchasing policies and procedures established to ensure compliance with federal requirements regarding suspension and debarment. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001 Program Names/Assistance Listing Titles: COVID‐19 Emergency Connectivity Fund Program; Special Education Cluster Assistance Listing Numbers: 32.009, 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: N/A, H027A220007, H027X210007, H173A220003, H173X210003 Questioned Costs: N/A Federal Agencies: Federal Communications Commission, U.S. Department of Education Pass‐Through Agencies: N/A, Arizona Department of Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment Criteria Non‐Federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Condition Verification of suspension and debarment was not performed for one vendor the District utilized in each of these programs, with whom the District spent at least $25,000 of federal grant monies. Cause Due to turnover in the procurement department, the District did not perform due diligence for the cooperative contracts used to make the purchases, therefore documentation was not prepared or maintained for verification of suspension and debarment. Effect The District was not in compliance with the requirements set forth by the federal government. However, it was subsequently determined that the two vendors utilized were not suspended or debarred. Context For one vendor the District utilized in each of these programs, the District did not perform or document its verification of whether the vendor was suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should follow purchasing policies and procedures established to ensure compliance with federal requirements regarding suspension and debarment. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001 Program Names/Assistance Listing Titles: COVID‐19 Emergency Connectivity Fund Program; Special Education Cluster Assistance Listing Numbers: 32.009, 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: N/A, H027A220007, H027X210007, H173A220003, H173X210003 Questioned Costs: N/A Federal Agencies: Federal Communications Commission, U.S. Department of Education Pass‐Through Agencies: N/A, Arizona Department of Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment Criteria Non‐Federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Condition Verification of suspension and debarment was not performed for one vendor the District utilized in each of these programs, with whom the District spent at least $25,000 of federal grant monies. Cause Due to turnover in the procurement department, the District did not perform due diligence for the cooperative contracts used to make the purchases, therefore documentation was not prepared or maintained for verification of suspension and debarment. Effect The District was not in compliance with the requirements set forth by the federal government. However, it was subsequently determined that the two vendors utilized were not suspended or debarred. Context For one vendor the District utilized in each of these programs, the District did not perform or document its verification of whether the vendor was suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should follow purchasing policies and procedures established to ensure compliance with federal requirements regarding suspension and debarment. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2023‐001 Repeat Finding: Yes, 2022‐001 Program Names/Assistance Listing Titles: COVID‐19 Emergency Connectivity Fund Program; Special Education Cluster Assistance Listing Numbers: 32.009, 84.027, 84.027X, 84.173, 84.173X Federal Award Numbers: N/A, H027A220007, H027X210007, H173A220003, H173X210003 Questioned Costs: N/A Federal Agencies: Federal Communications Commission, U.S. Department of Education Pass‐Through Agencies: N/A, Arizona Department of Education Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment Criteria Non‐Federal entities are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. “Covered transactions” include those procurement contracts for goods and services awarded under a non‐procurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR §180.220. Condition Verification of suspension and debarment was not performed for one vendor the District utilized in each of these programs, with whom the District spent at least $25,000 of federal grant monies. Cause Due to turnover in the procurement department, the District did not perform due diligence for the cooperative contracts used to make the purchases, therefore documentation was not prepared or maintained for verification of suspension and debarment. Effect The District was not in compliance with the requirements set forth by the federal government. However, it was subsequently determined that the two vendors utilized were not suspended or debarred. Context For one vendor the District utilized in each of these programs, the District did not perform or document its verification of whether the vendor was suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should follow purchasing policies and procedures established to ensure compliance with federal requirements regarding suspension and debarment. Views of Responsible Officials See Corrective Action Plan.