Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Title I Grants to Local Educational Agencies 84.010 S010A220003 $48,491
Supporting Effective Instruction State Grants 84.367 S367A220049 $41,547
Student Support and Academic Enrichment Program 84.424 S424A210003 $29,979
Education Stabilization Fund 84.425C N/A $4,206
Education Stabilization Fund 84.425D S425D200038 $10,867
Education Stabilization Fund 84.425U S425U210038 $9,812,251
Federal Agency: U.S. Department of Education
Pass‐Through Agency: Arizona Department of Education
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Activities allowed or unallowed, Allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not maintain effective internal control over activities allowed or unallowed and
allowable costs/cost principles for several grants.
Cause
The District’s grant budgets were not approved until well after the beginning of each grant’s period
of performance. Additionally, the District did not verify actual spending was within approved budgets,
and, therefore, did not submit for budget revisions in a timely manner.
Effect
Costs were disallowed or entitlement funding was forfeited after the close of the fiscal year. Audit
adjustments were necessary to properly state the grant activity on the District’s Schedule of
Expenditures of Federal Awards (SEFA). Due to the manner in which the District moved expenditures,
the auditors could not determine if costs moved between grants complied with relevant Federal
statutes, regulations, and the terms and conditions of the Federal award.Context
The District was not timely managing and revising grant agreements with the Arizona Department of
Education throughout the fiscal year. As a result, material adjustment to the grant activity of four
entitlement grants was posted during the completion report process in February 2024. The District
moved unallowed costs in total from each grant to the American Rescue Plan ‐ Elementary and
Secondary School Emergency Relief (ARP ESSER) grant without identifying specific transactions or
positions to ensure allowability under the ARP ESSER grant. Activity moved en‐masse to the ARP
ESSER grant was as follows:
$1,299,850 from Title I Grants to Local Educational Agencies (ALN 84.010)
$120,986 from Supporting Effective Instruction State Grants (ALN 84.367)
$41,547 from Student Support and Academic Enrichment Program (ALN 84.424)
$8,345,868 from Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN
84.425D)
Additionally, the District did not have controls in place to ensure costs were not charged to inactive
grant funds. As a result, the following grants had transactions recorded to them that were not
associated with an active grant agreement:
Title I Grants to Local Educational Agencies (ALN 84.010) ‐ $48,491
Supporting Effective Instruction State Grants (ALN 84.367) ‐ $45,152
Student Support and Academic Enrichment Program (ALN 84.424) ‐ $29,979
Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN 84.425D) ‐ $10,867
Governor’s Emergency Education Relief (GEER) Fund (ALN 84.425C) ‐ $4,206
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
the State’s grants management enterprise to ensure grant budgets are not overexpended going
forward. The District should also have more consistent and timely oversight of grants by higher level
management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Title I Grants to Local Educational Agencies 84.010 S010A220003 $48,491
Supporting Effective Instruction State Grants 84.367 S367A220049 $41,547
Student Support and Academic Enrichment Program 84.424 S424A210003 $29,979
Education Stabilization Fund 84.425C N/A $4,206
Education Stabilization Fund 84.425D S425D200038 $10,867
Education Stabilization Fund 84.425U S425U210038 $9,812,251
Federal Agency: U.S. Department of Education
Pass‐Through Agency: Arizona Department of Education
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Activities allowed or unallowed, Allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not maintain effective internal control over activities allowed or unallowed and
allowable costs/cost principles for several grants.
Cause
The District’s grant budgets were not approved until well after the beginning of each grant’s period
of performance. Additionally, the District did not verify actual spending was within approved budgets,
and, therefore, did not submit for budget revisions in a timely manner.
Effect
Costs were disallowed or entitlement funding was forfeited after the close of the fiscal year. Audit
adjustments were necessary to properly state the grant activity on the District’s Schedule of
Expenditures of Federal Awards (SEFA). Due to the manner in which the District moved expenditures,
the auditors could not determine if costs moved between grants complied with relevant Federal
statutes, regulations, and the terms and conditions of the Federal award.Context
The District was not timely managing and revising grant agreements with the Arizona Department of
Education throughout the fiscal year. As a result, material adjustment to the grant activity of four
entitlement grants was posted during the completion report process in February 2024. The District
moved unallowed costs in total from each grant to the American Rescue Plan ‐ Elementary and
Secondary School Emergency Relief (ARP ESSER) grant without identifying specific transactions or
positions to ensure allowability under the ARP ESSER grant. Activity moved en‐masse to the ARP
ESSER grant was as follows:
$1,299,850 from Title I Grants to Local Educational Agencies (ALN 84.010)
$120,986 from Supporting Effective Instruction State Grants (ALN 84.367)
$41,547 from Student Support and Academic Enrichment Program (ALN 84.424)
$8,345,868 from Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN
84.425D)
Additionally, the District did not have controls in place to ensure costs were not charged to inactive
grant funds. As a result, the following grants had transactions recorded to them that were not
associated with an active grant agreement:
Title I Grants to Local Educational Agencies (ALN 84.010) ‐ $48,491
Supporting Effective Instruction State Grants (ALN 84.367) ‐ $45,152
Student Support and Academic Enrichment Program (ALN 84.424) ‐ $29,979
Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN 84.425D) ‐ $10,867
Governor’s Emergency Education Relief (GEER) Fund (ALN 84.425C) ‐ $4,206
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
the State’s grants management enterprise to ensure grant budgets are not overexpended going
forward. The District should also have more consistent and timely oversight of grants by higher level
management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Title I Grants to Local Educational Agencies 84.010 S010A220003 $48,491
Supporting Effective Instruction State Grants 84.367 S367A220049 $41,547
Student Support and Academic Enrichment Program 84.424 S424A210003 $29,979
Education Stabilization Fund 84.425C N/A $4,206
Education Stabilization Fund 84.425D S425D200038 $10,867
Education Stabilization Fund 84.425U S425U210038 $9,812,251
Federal Agency: U.S. Department of Education
Pass‐Through Agency: Arizona Department of Education
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Activities allowed or unallowed, Allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not maintain effective internal control over activities allowed or unallowed and
allowable costs/cost principles for several grants.
Cause
The District’s grant budgets were not approved until well after the beginning of each grant’s period
of performance. Additionally, the District did not verify actual spending was within approved budgets,
and, therefore, did not submit for budget revisions in a timely manner.
Effect
Costs were disallowed or entitlement funding was forfeited after the close of the fiscal year. Audit
adjustments were necessary to properly state the grant activity on the District’s Schedule of
Expenditures of Federal Awards (SEFA). Due to the manner in which the District moved expenditures,
the auditors could not determine if costs moved between grants complied with relevant Federal
statutes, regulations, and the terms and conditions of the Federal award.Context
The District was not timely managing and revising grant agreements with the Arizona Department of
Education throughout the fiscal year. As a result, material adjustment to the grant activity of four
entitlement grants was posted during the completion report process in February 2024. The District
moved unallowed costs in total from each grant to the American Rescue Plan ‐ Elementary and
Secondary School Emergency Relief (ARP ESSER) grant without identifying specific transactions or
positions to ensure allowability under the ARP ESSER grant. Activity moved en‐masse to the ARP
ESSER grant was as follows:
$1,299,850 from Title I Grants to Local Educational Agencies (ALN 84.010)
$120,986 from Supporting Effective Instruction State Grants (ALN 84.367)
$41,547 from Student Support and Academic Enrichment Program (ALN 84.424)
$8,345,868 from Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN
84.425D)
Additionally, the District did not have controls in place to ensure costs were not charged to inactive
grant funds. As a result, the following grants had transactions recorded to them that were not
associated with an active grant agreement:
Title I Grants to Local Educational Agencies (ALN 84.010) ‐ $48,491
Supporting Effective Instruction State Grants (ALN 84.367) ‐ $45,152
Student Support and Academic Enrichment Program (ALN 84.424) ‐ $29,979
Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN 84.425D) ‐ $10,867
Governor’s Emergency Education Relief (GEER) Fund (ALN 84.425C) ‐ $4,206
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
the State’s grants management enterprise to ensure grant budgets are not overexpended going
forward. The District should also have more consistent and timely oversight of grants by higher level
management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Title I Grants to Local Educational Agencies 84.010 S010A220003 $48,491
Supporting Effective Instruction State Grants 84.367 S367A220049 $41,547
Student Support and Academic Enrichment Program 84.424 S424A210003 $29,979
Education Stabilization Fund 84.425C N/A $4,206
Education Stabilization Fund 84.425D S425D200038 $10,867
Education Stabilization Fund 84.425U S425U210038 $9,812,251
Federal Agency: U.S. Department of Education
Pass‐Through Agency: Arizona Department of Education
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Activities allowed or unallowed, Allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not maintain effective internal control over activities allowed or unallowed and
allowable costs/cost principles for several grants.
Cause
The District’s grant budgets were not approved until well after the beginning of each grant’s period
of performance. Additionally, the District did not verify actual spending was within approved budgets,
and, therefore, did not submit for budget revisions in a timely manner.
Effect
Costs were disallowed or entitlement funding was forfeited after the close of the fiscal year. Audit
adjustments were necessary to properly state the grant activity on the District’s Schedule of
Expenditures of Federal Awards (SEFA). Due to the manner in which the District moved expenditures,
the auditors could not determine if costs moved between grants complied with relevant Federal
statutes, regulations, and the terms and conditions of the Federal award.Context
The District was not timely managing and revising grant agreements with the Arizona Department of
Education throughout the fiscal year. As a result, material adjustment to the grant activity of four
entitlement grants was posted during the completion report process in February 2024. The District
moved unallowed costs in total from each grant to the American Rescue Plan ‐ Elementary and
Secondary School Emergency Relief (ARP ESSER) grant without identifying specific transactions or
positions to ensure allowability under the ARP ESSER grant. Activity moved en‐masse to the ARP
ESSER grant was as follows:
$1,299,850 from Title I Grants to Local Educational Agencies (ALN 84.010)
$120,986 from Supporting Effective Instruction State Grants (ALN 84.367)
$41,547 from Student Support and Academic Enrichment Program (ALN 84.424)
$8,345,868 from Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN
84.425D)
Additionally, the District did not have controls in place to ensure costs were not charged to inactive
grant funds. As a result, the following grants had transactions recorded to them that were not
associated with an active grant agreement:
Title I Grants to Local Educational Agencies (ALN 84.010) ‐ $48,491
Supporting Effective Instruction State Grants (ALN 84.367) ‐ $45,152
Student Support and Academic Enrichment Program (ALN 84.424) ‐ $29,979
Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN 84.425D) ‐ $10,867
Governor’s Emergency Education Relief (GEER) Fund (ALN 84.425C) ‐ $4,206
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
the State’s grants management enterprise to ensure grant budgets are not overexpended going
forward. The District should also have more consistent and timely oversight of grants by higher level
management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Title I Grants to Local Educational Agencies 84.010 S010A220003 $48,491
Supporting Effective Instruction State Grants 84.367 S367A220049 $41,547
Student Support and Academic Enrichment Program 84.424 S424A210003 $29,979
Education Stabilization Fund 84.425C N/A $4,206
Education Stabilization Fund 84.425D S425D200038 $10,867
Education Stabilization Fund 84.425U S425U210038 $9,812,251
Federal Agency: U.S. Department of Education
Pass‐Through Agency: Arizona Department of Education
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Activities allowed or unallowed, Allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not maintain effective internal control over activities allowed or unallowed and
allowable costs/cost principles for several grants.
Cause
The District’s grant budgets were not approved until well after the beginning of each grant’s period
of performance. Additionally, the District did not verify actual spending was within approved budgets,
and, therefore, did not submit for budget revisions in a timely manner.
Effect
Costs were disallowed or entitlement funding was forfeited after the close of the fiscal year. Audit
adjustments were necessary to properly state the grant activity on the District’s Schedule of
Expenditures of Federal Awards (SEFA). Due to the manner in which the District moved expenditures,
the auditors could not determine if costs moved between grants complied with relevant Federal
statutes, regulations, and the terms and conditions of the Federal award.Context
The District was not timely managing and revising grant agreements with the Arizona Department of
Education throughout the fiscal year. As a result, material adjustment to the grant activity of four
entitlement grants was posted during the completion report process in February 2024. The District
moved unallowed costs in total from each grant to the American Rescue Plan ‐ Elementary and
Secondary School Emergency Relief (ARP ESSER) grant without identifying specific transactions or
positions to ensure allowability under the ARP ESSER grant. Activity moved en‐masse to the ARP
ESSER grant was as follows:
$1,299,850 from Title I Grants to Local Educational Agencies (ALN 84.010)
$120,986 from Supporting Effective Instruction State Grants (ALN 84.367)
$41,547 from Student Support and Academic Enrichment Program (ALN 84.424)
$8,345,868 from Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN
84.425D)
Additionally, the District did not have controls in place to ensure costs were not charged to inactive
grant funds. As a result, the following grants had transactions recorded to them that were not
associated with an active grant agreement:
Title I Grants to Local Educational Agencies (ALN 84.010) ‐ $48,491
Supporting Effective Instruction State Grants (ALN 84.367) ‐ $45,152
Student Support and Academic Enrichment Program (ALN 84.424) ‐ $29,979
Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN 84.425D) ‐ $10,867
Governor’s Emergency Education Relief (GEER) Fund (ALN 84.425C) ‐ $4,206
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
the State’s grants management enterprise to ensure grant budgets are not overexpended going
forward. The District should also have more consistent and timely oversight of grants by higher level
management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Title I Grants to Local Educational Agencies 84.010 S010A220003 $48,491
Supporting Effective Instruction State Grants 84.367 S367A220049 $41,547
Student Support and Academic Enrichment Program 84.424 S424A210003 $29,979
Education Stabilization Fund 84.425C N/A $4,206
Education Stabilization Fund 84.425D S425D200038 $10,867
Education Stabilization Fund 84.425U S425U210038 $9,812,251
Federal Agency: U.S. Department of Education
Pass‐Through Agency: Arizona Department of Education
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Activities allowed or unallowed, Allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not maintain effective internal control over activities allowed or unallowed and
allowable costs/cost principles for several grants.
Cause
The District’s grant budgets were not approved until well after the beginning of each grant’s period
of performance. Additionally, the District did not verify actual spending was within approved budgets,
and, therefore, did not submit for budget revisions in a timely manner.
Effect
Costs were disallowed or entitlement funding was forfeited after the close of the fiscal year. Audit
adjustments were necessary to properly state the grant activity on the District’s Schedule of
Expenditures of Federal Awards (SEFA). Due to the manner in which the District moved expenditures,
the auditors could not determine if costs moved between grants complied with relevant Federal
statutes, regulations, and the terms and conditions of the Federal award.Context
The District was not timely managing and revising grant agreements with the Arizona Department of
Education throughout the fiscal year. As a result, material adjustment to the grant activity of four
entitlement grants was posted during the completion report process in February 2024. The District
moved unallowed costs in total from each grant to the American Rescue Plan ‐ Elementary and
Secondary School Emergency Relief (ARP ESSER) grant without identifying specific transactions or
positions to ensure allowability under the ARP ESSER grant. Activity moved en‐masse to the ARP
ESSER grant was as follows:
$1,299,850 from Title I Grants to Local Educational Agencies (ALN 84.010)
$120,986 from Supporting Effective Instruction State Grants (ALN 84.367)
$41,547 from Student Support and Academic Enrichment Program (ALN 84.424)
$8,345,868 from Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN
84.425D)
Additionally, the District did not have controls in place to ensure costs were not charged to inactive
grant funds. As a result, the following grants had transactions recorded to them that were not
associated with an active grant agreement:
Title I Grants to Local Educational Agencies (ALN 84.010) ‐ $48,491
Supporting Effective Instruction State Grants (ALN 84.367) ‐ $45,152
Student Support and Academic Enrichment Program (ALN 84.424) ‐ $29,979
Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN 84.425D) ‐ $10,867
Governor’s Emergency Education Relief (GEER) Fund (ALN 84.425C) ‐ $4,206
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
the State’s grants management enterprise to ensure grant budgets are not overexpended going
forward. The District should also have more consistent and timely oversight of grants by higher level
management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐002
Repeat Finding: No
Program Name/Assistance Listing Title: Education Stabilization Fund
Assistance Listing Number: 84.425
Federal Agency: U.S. Department of Education
Federal Award Number: S425U210038
Pass‐Through Agency: Arizona Department of Education
Questioned Costs: N/A
Type of Finding: Noncompliance, Material Weakness
Compliance Requirement: Reporting
Criteria
Districts that received Education Stabilization Fund funding were required by the Arizona Department
of Education to complete the “LEA Uses of ESSER I, II, & III – Use of Funds Detail” report by April 21,
2023. The report was based on fiscal year 2021‐22 financial information and full‐time equivalency
(FTE) information.
Condition
Inadequate internal controls existed over the Education Stabilization Fund reporting processes.
Cause
The District did not develop nor implement strong internal controls over reporting due lack of training
for individuals with reporting responsibilities.
Effect
The District is at risk of reporting inaccurate information.
Context
The District was unable to provide supporting documentation for the allocation of expenditures to
the four categories listed in the report and the FTE information as of September 30, 2022.
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should develop or implement strong internal controls over reporting to reduce the risk
of reporting inaccurate information.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐003
Repeat Finding: Yes, 2022‐001
Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Education
Federal Award Number: GR‐ARPA‐ASL‐ISAACSD‐161, GR‐ARPA‐SEP‐ISAACSD‐37
Pass‐Through Agency: Arizona Governor’s Office
Questioned Costs: N/A
Type of Finding: Material Weakness, Noncompliance
Compliance Requirement: Activities allowed or unallowed, allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not have adequate internal controls in place to ensure eligible expenditures for the
Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program were not reimbursed by other
federal grants.
Cause
The District lacked internal controls over grants management. The District consistently had initial
grant budgets approved well after the beginning of each grant’s period of performance. Additionally,
the District was not reviewing actual spending to approved budgets, and, therefore, did not submit
for budget revisions or reimbursements in a timely manner.
Effect
The District did not ensure the grant expenditures were properly reported on the Schedule of
Expenditures of Federal Awards, resulting in the need for the single audit report to be reissued.
Context
The District requested reimbursement in early calendar year 2024 for SLFRF grant expenditures, of
which $1,723,915 were recorded within the Education Stabilization Fund (ESF). Journal entries to
move the expenditures to the SLFRF grant fund were not performed until early calendar year 2025.
The result is that the District was reimbursed for the same costs from both the ESF and SLFRF
programs. However, the District later performed journal entries, in early calendar year 2025, to move
additional eligible expenditures for the ESF that replaced the expenditures reimbursed by the SLFRF
program.
The sample was not intended to be, and was not, a statistically valid sample.Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
should implement controls to ensure expenditures are not submitted for reimbursement under
multiple federal grants. The District should also have more consistent and timely oversight of grants
by higher level management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐003
Repeat Finding: Yes, 2022‐001
Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Education
Federal Award Number: GR‐ARPA‐ASL‐ISAACSD‐161, GR‐ARPA‐SEP‐ISAACSD‐37
Pass‐Through Agency: Arizona Governor’s Office
Questioned Costs: N/A
Type of Finding: Material Weakness, Noncompliance
Compliance Requirement: Activities allowed or unallowed, allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not have adequate internal controls in place to ensure eligible expenditures for the
Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program were not reimbursed by other
federal grants.
Cause
The District lacked internal controls over grants management. The District consistently had initial
grant budgets approved well after the beginning of each grant’s period of performance. Additionally,
the District was not reviewing actual spending to approved budgets, and, therefore, did not submit
for budget revisions or reimbursements in a timely manner.
Effect
The District did not ensure the grant expenditures were properly reported on the Schedule of
Expenditures of Federal Awards, resulting in the need for the single audit report to be reissued.
Context
The District requested reimbursement in early calendar year 2024 for SLFRF grant expenditures, of
which $1,723,915 were recorded within the Education Stabilization Fund (ESF). Journal entries to
move the expenditures to the SLFRF grant fund were not performed until early calendar year 2025.
The result is that the District was reimbursed for the same costs from both the ESF and SLFRF
programs. However, the District later performed journal entries, in early calendar year 2025, to move
additional eligible expenditures for the ESF that replaced the expenditures reimbursed by the SLFRF
program.
The sample was not intended to be, and was not, a statistically valid sample.Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
should implement controls to ensure expenditures are not submitted for reimbursement under
multiple federal grants. The District should also have more consistent and timely oversight of grants
by higher level management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐004
Repeat Finding: No
Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Education
Federal Award Number: GR‐ARPA‐ASL‐ISAACSD‐161, GR‐ARPA‐SEP‐ISAACSD‐37
Pass‐Through Agency: Arizona Governor’s Office
Questioned Costs: N/A
Type of Finding: Significant Deficiency, Noncompliance
Compliance Requirement: 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 documentation was not maintained for vendors with which
the District spent at least $25,000 of federal grant monies.
Cause
The District has not implemented consistent internal controls over suspension and debarment due
to turnover in the Purchasing Department.
Effect
The District was not in compliance with the requirements set forth by the federal government.
However, it was subsequently determined that the three vendors sampled were not suspended or
debarred.
Context
For three vendors that the District utilized for the program, the District did not 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: 2023‐004
Repeat Finding: No
Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Education
Federal Award Number: GR‐ARPA‐ASL‐ISAACSD‐161, GR‐ARPA‐SEP‐ISAACSD‐37
Pass‐Through Agency: Arizona Governor’s Office
Questioned Costs: N/A
Type of Finding: Significant Deficiency, Noncompliance
Compliance Requirement: 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 documentation was not maintained for vendors with which
the District spent at least $25,000 of federal grant monies.
Cause
The District has not implemented consistent internal controls over suspension and debarment due
to turnover in the Purchasing Department.
Effect
The District was not in compliance with the requirements set forth by the federal government.
However, it was subsequently determined that the three vendors sampled were not suspended or
debarred.
Context
For three vendors that the District utilized for the program, the District did not 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: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Title I Grants to Local Educational Agencies 84.010 S010A220003 $48,491
Supporting Effective Instruction State Grants 84.367 S367A220049 $41,547
Student Support and Academic Enrichment Program 84.424 S424A210003 $29,979
Education Stabilization Fund 84.425C N/A $4,206
Education Stabilization Fund 84.425D S425D200038 $10,867
Education Stabilization Fund 84.425U S425U210038 $9,812,251
Federal Agency: U.S. Department of Education
Pass‐Through Agency: Arizona Department of Education
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Activities allowed or unallowed, Allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not maintain effective internal control over activities allowed or unallowed and
allowable costs/cost principles for several grants.
Cause
The District’s grant budgets were not approved until well after the beginning of each grant’s period
of performance. Additionally, the District did not verify actual spending was within approved budgets,
and, therefore, did not submit for budget revisions in a timely manner.
Effect
Costs were disallowed or entitlement funding was forfeited after the close of the fiscal year. Audit
adjustments were necessary to properly state the grant activity on the District’s Schedule of
Expenditures of Federal Awards (SEFA). Due to the manner in which the District moved expenditures,
the auditors could not determine if costs moved between grants complied with relevant Federal
statutes, regulations, and the terms and conditions of the Federal award.Context
The District was not timely managing and revising grant agreements with the Arizona Department of
Education throughout the fiscal year. As a result, material adjustment to the grant activity of four
entitlement grants was posted during the completion report process in February 2024. The District
moved unallowed costs in total from each grant to the American Rescue Plan ‐ Elementary and
Secondary School Emergency Relief (ARP ESSER) grant without identifying specific transactions or
positions to ensure allowability under the ARP ESSER grant. Activity moved en‐masse to the ARP
ESSER grant was as follows:
$1,299,850 from Title I Grants to Local Educational Agencies (ALN 84.010)
$120,986 from Supporting Effective Instruction State Grants (ALN 84.367)
$41,547 from Student Support and Academic Enrichment Program (ALN 84.424)
$8,345,868 from Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN
84.425D)
Additionally, the District did not have controls in place to ensure costs were not charged to inactive
grant funds. As a result, the following grants had transactions recorded to them that were not
associated with an active grant agreement:
Title I Grants to Local Educational Agencies (ALN 84.010) ‐ $48,491
Supporting Effective Instruction State Grants (ALN 84.367) ‐ $45,152
Student Support and Academic Enrichment Program (ALN 84.424) ‐ $29,979
Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN 84.425D) ‐ $10,867
Governor’s Emergency Education Relief (GEER) Fund (ALN 84.425C) ‐ $4,206
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
the State’s grants management enterprise to ensure grant budgets are not overexpended going
forward. The District should also have more consistent and timely oversight of grants by higher level
management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Title I Grants to Local Educational Agencies 84.010 S010A220003 $48,491
Supporting Effective Instruction State Grants 84.367 S367A220049 $41,547
Student Support and Academic Enrichment Program 84.424 S424A210003 $29,979
Education Stabilization Fund 84.425C N/A $4,206
Education Stabilization Fund 84.425D S425D200038 $10,867
Education Stabilization Fund 84.425U S425U210038 $9,812,251
Federal Agency: U.S. Department of Education
Pass‐Through Agency: Arizona Department of Education
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Activities allowed or unallowed, Allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not maintain effective internal control over activities allowed or unallowed and
allowable costs/cost principles for several grants.
Cause
The District’s grant budgets were not approved until well after the beginning of each grant’s period
of performance. Additionally, the District did not verify actual spending was within approved budgets,
and, therefore, did not submit for budget revisions in a timely manner.
Effect
Costs were disallowed or entitlement funding was forfeited after the close of the fiscal year. Audit
adjustments were necessary to properly state the grant activity on the District’s Schedule of
Expenditures of Federal Awards (SEFA). Due to the manner in which the District moved expenditures,
the auditors could not determine if costs moved between grants complied with relevant Federal
statutes, regulations, and the terms and conditions of the Federal award.Context
The District was not timely managing and revising grant agreements with the Arizona Department of
Education throughout the fiscal year. As a result, material adjustment to the grant activity of four
entitlement grants was posted during the completion report process in February 2024. The District
moved unallowed costs in total from each grant to the American Rescue Plan ‐ Elementary and
Secondary School Emergency Relief (ARP ESSER) grant without identifying specific transactions or
positions to ensure allowability under the ARP ESSER grant. Activity moved en‐masse to the ARP
ESSER grant was as follows:
$1,299,850 from Title I Grants to Local Educational Agencies (ALN 84.010)
$120,986 from Supporting Effective Instruction State Grants (ALN 84.367)
$41,547 from Student Support and Academic Enrichment Program (ALN 84.424)
$8,345,868 from Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN
84.425D)
Additionally, the District did not have controls in place to ensure costs were not charged to inactive
grant funds. As a result, the following grants had transactions recorded to them that were not
associated with an active grant agreement:
Title I Grants to Local Educational Agencies (ALN 84.010) ‐ $48,491
Supporting Effective Instruction State Grants (ALN 84.367) ‐ $45,152
Student Support and Academic Enrichment Program (ALN 84.424) ‐ $29,979
Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN 84.425D) ‐ $10,867
Governor’s Emergency Education Relief (GEER) Fund (ALN 84.425C) ‐ $4,206
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
the State’s grants management enterprise to ensure grant budgets are not overexpended going
forward. The District should also have more consistent and timely oversight of grants by higher level
management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Title I Grants to Local Educational Agencies 84.010 S010A220003 $48,491
Supporting Effective Instruction State Grants 84.367 S367A220049 $41,547
Student Support and Academic Enrichment Program 84.424 S424A210003 $29,979
Education Stabilization Fund 84.425C N/A $4,206
Education Stabilization Fund 84.425D S425D200038 $10,867
Education Stabilization Fund 84.425U S425U210038 $9,812,251
Federal Agency: U.S. Department of Education
Pass‐Through Agency: Arizona Department of Education
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Activities allowed or unallowed, Allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not maintain effective internal control over activities allowed or unallowed and
allowable costs/cost principles for several grants.
Cause
The District’s grant budgets were not approved until well after the beginning of each grant’s period
of performance. Additionally, the District did not verify actual spending was within approved budgets,
and, therefore, did not submit for budget revisions in a timely manner.
Effect
Costs were disallowed or entitlement funding was forfeited after the close of the fiscal year. Audit
adjustments were necessary to properly state the grant activity on the District’s Schedule of
Expenditures of Federal Awards (SEFA). Due to the manner in which the District moved expenditures,
the auditors could not determine if costs moved between grants complied with relevant Federal
statutes, regulations, and the terms and conditions of the Federal award.Context
The District was not timely managing and revising grant agreements with the Arizona Department of
Education throughout the fiscal year. As a result, material adjustment to the grant activity of four
entitlement grants was posted during the completion report process in February 2024. The District
moved unallowed costs in total from each grant to the American Rescue Plan ‐ Elementary and
Secondary School Emergency Relief (ARP ESSER) grant without identifying specific transactions or
positions to ensure allowability under the ARP ESSER grant. Activity moved en‐masse to the ARP
ESSER grant was as follows:
$1,299,850 from Title I Grants to Local Educational Agencies (ALN 84.010)
$120,986 from Supporting Effective Instruction State Grants (ALN 84.367)
$41,547 from Student Support and Academic Enrichment Program (ALN 84.424)
$8,345,868 from Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN
84.425D)
Additionally, the District did not have controls in place to ensure costs were not charged to inactive
grant funds. As a result, the following grants had transactions recorded to them that were not
associated with an active grant agreement:
Title I Grants to Local Educational Agencies (ALN 84.010) ‐ $48,491
Supporting Effective Instruction State Grants (ALN 84.367) ‐ $45,152
Student Support and Academic Enrichment Program (ALN 84.424) ‐ $29,979
Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN 84.425D) ‐ $10,867
Governor’s Emergency Education Relief (GEER) Fund (ALN 84.425C) ‐ $4,206
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
the State’s grants management enterprise to ensure grant budgets are not overexpended going
forward. The District should also have more consistent and timely oversight of grants by higher level
management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Title I Grants to Local Educational Agencies 84.010 S010A220003 $48,491
Supporting Effective Instruction State Grants 84.367 S367A220049 $41,547
Student Support and Academic Enrichment Program 84.424 S424A210003 $29,979
Education Stabilization Fund 84.425C N/A $4,206
Education Stabilization Fund 84.425D S425D200038 $10,867
Education Stabilization Fund 84.425U S425U210038 $9,812,251
Federal Agency: U.S. Department of Education
Pass‐Through Agency: Arizona Department of Education
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Activities allowed or unallowed, Allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not maintain effective internal control over activities allowed or unallowed and
allowable costs/cost principles for several grants.
Cause
The District’s grant budgets were not approved until well after the beginning of each grant’s period
of performance. Additionally, the District did not verify actual spending was within approved budgets,
and, therefore, did not submit for budget revisions in a timely manner.
Effect
Costs were disallowed or entitlement funding was forfeited after the close of the fiscal year. Audit
adjustments were necessary to properly state the grant activity on the District’s Schedule of
Expenditures of Federal Awards (SEFA). Due to the manner in which the District moved expenditures,
the auditors could not determine if costs moved between grants complied with relevant Federal
statutes, regulations, and the terms and conditions of the Federal award.Context
The District was not timely managing and revising grant agreements with the Arizona Department of
Education throughout the fiscal year. As a result, material adjustment to the grant activity of four
entitlement grants was posted during the completion report process in February 2024. The District
moved unallowed costs in total from each grant to the American Rescue Plan ‐ Elementary and
Secondary School Emergency Relief (ARP ESSER) grant without identifying specific transactions or
positions to ensure allowability under the ARP ESSER grant. Activity moved en‐masse to the ARP
ESSER grant was as follows:
$1,299,850 from Title I Grants to Local Educational Agencies (ALN 84.010)
$120,986 from Supporting Effective Instruction State Grants (ALN 84.367)
$41,547 from Student Support and Academic Enrichment Program (ALN 84.424)
$8,345,868 from Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN
84.425D)
Additionally, the District did not have controls in place to ensure costs were not charged to inactive
grant funds. As a result, the following grants had transactions recorded to them that were not
associated with an active grant agreement:
Title I Grants to Local Educational Agencies (ALN 84.010) ‐ $48,491
Supporting Effective Instruction State Grants (ALN 84.367) ‐ $45,152
Student Support and Academic Enrichment Program (ALN 84.424) ‐ $29,979
Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN 84.425D) ‐ $10,867
Governor’s Emergency Education Relief (GEER) Fund (ALN 84.425C) ‐ $4,206
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
the State’s grants management enterprise to ensure grant budgets are not overexpended going
forward. The District should also have more consistent and timely oversight of grants by higher level
management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Title I Grants to Local Educational Agencies 84.010 S010A220003 $48,491
Supporting Effective Instruction State Grants 84.367 S367A220049 $41,547
Student Support and Academic Enrichment Program 84.424 S424A210003 $29,979
Education Stabilization Fund 84.425C N/A $4,206
Education Stabilization Fund 84.425D S425D200038 $10,867
Education Stabilization Fund 84.425U S425U210038 $9,812,251
Federal Agency: U.S. Department of Education
Pass‐Through Agency: Arizona Department of Education
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Activities allowed or unallowed, Allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not maintain effective internal control over activities allowed or unallowed and
allowable costs/cost principles for several grants.
Cause
The District’s grant budgets were not approved until well after the beginning of each grant’s period
of performance. Additionally, the District did not verify actual spending was within approved budgets,
and, therefore, did not submit for budget revisions in a timely manner.
Effect
Costs were disallowed or entitlement funding was forfeited after the close of the fiscal year. Audit
adjustments were necessary to properly state the grant activity on the District’s Schedule of
Expenditures of Federal Awards (SEFA). Due to the manner in which the District moved expenditures,
the auditors could not determine if costs moved between grants complied with relevant Federal
statutes, regulations, and the terms and conditions of the Federal award.Context
The District was not timely managing and revising grant agreements with the Arizona Department of
Education throughout the fiscal year. As a result, material adjustment to the grant activity of four
entitlement grants was posted during the completion report process in February 2024. The District
moved unallowed costs in total from each grant to the American Rescue Plan ‐ Elementary and
Secondary School Emergency Relief (ARP ESSER) grant without identifying specific transactions or
positions to ensure allowability under the ARP ESSER grant. Activity moved en‐masse to the ARP
ESSER grant was as follows:
$1,299,850 from Title I Grants to Local Educational Agencies (ALN 84.010)
$120,986 from Supporting Effective Instruction State Grants (ALN 84.367)
$41,547 from Student Support and Academic Enrichment Program (ALN 84.424)
$8,345,868 from Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN
84.425D)
Additionally, the District did not have controls in place to ensure costs were not charged to inactive
grant funds. As a result, the following grants had transactions recorded to them that were not
associated with an active grant agreement:
Title I Grants to Local Educational Agencies (ALN 84.010) ‐ $48,491
Supporting Effective Instruction State Grants (ALN 84.367) ‐ $45,152
Student Support and Academic Enrichment Program (ALN 84.424) ‐ $29,979
Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN 84.425D) ‐ $10,867
Governor’s Emergency Education Relief (GEER) Fund (ALN 84.425C) ‐ $4,206
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
the State’s grants management enterprise to ensure grant budgets are not overexpended going
forward. The District should also have more consistent and timely oversight of grants by higher level
management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐001
Repeat Finding: No
Program Names/Assistance Listing Titles:
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Title I Grants to Local Educational Agencies 84.010 S010A220003 $48,491
Supporting Effective Instruction State Grants 84.367 S367A220049 $41,547
Student Support and Academic Enrichment Program 84.424 S424A210003 $29,979
Education Stabilization Fund 84.425C N/A $4,206
Education Stabilization Fund 84.425D S425D200038 $10,867
Education Stabilization Fund 84.425U S425U210038 $9,812,251
Federal Agency: U.S. Department of Education
Pass‐Through Agency: Arizona Department of Education
Type of Finding: Noncompliance, Material Weakness
Compliance Requirements: Activities allowed or unallowed, Allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not maintain effective internal control over activities allowed or unallowed and
allowable costs/cost principles for several grants.
Cause
The District’s grant budgets were not approved until well after the beginning of each grant’s period
of performance. Additionally, the District did not verify actual spending was within approved budgets,
and, therefore, did not submit for budget revisions in a timely manner.
Effect
Costs were disallowed or entitlement funding was forfeited after the close of the fiscal year. Audit
adjustments were necessary to properly state the grant activity on the District’s Schedule of
Expenditures of Federal Awards (SEFA). Due to the manner in which the District moved expenditures,
the auditors could not determine if costs moved between grants complied with relevant Federal
statutes, regulations, and the terms and conditions of the Federal award.Context
The District was not timely managing and revising grant agreements with the Arizona Department of
Education throughout the fiscal year. As a result, material adjustment to the grant activity of four
entitlement grants was posted during the completion report process in February 2024. The District
moved unallowed costs in total from each grant to the American Rescue Plan ‐ Elementary and
Secondary School Emergency Relief (ARP ESSER) grant without identifying specific transactions or
positions to ensure allowability under the ARP ESSER grant. Activity moved en‐masse to the ARP
ESSER grant was as follows:
$1,299,850 from Title I Grants to Local Educational Agencies (ALN 84.010)
$120,986 from Supporting Effective Instruction State Grants (ALN 84.367)
$41,547 from Student Support and Academic Enrichment Program (ALN 84.424)
$8,345,868 from Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN
84.425D)
Additionally, the District did not have controls in place to ensure costs were not charged to inactive
grant funds. As a result, the following grants had transactions recorded to them that were not
associated with an active grant agreement:
Title I Grants to Local Educational Agencies (ALN 84.010) ‐ $48,491
Supporting Effective Instruction State Grants (ALN 84.367) ‐ $45,152
Student Support and Academic Enrichment Program (ALN 84.424) ‐ $29,979
Elementary and Secondary School Emergency Relief (ESSER) Fund (ALN 84.425D) ‐ $10,867
Governor’s Emergency Education Relief (GEER) Fund (ALN 84.425C) ‐ $4,206
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
the State’s grants management enterprise to ensure grant budgets are not overexpended going
forward. The District should also have more consistent and timely oversight of grants by higher level
management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐002
Repeat Finding: No
Program Name/Assistance Listing Title: Education Stabilization Fund
Assistance Listing Number: 84.425
Federal Agency: U.S. Department of Education
Federal Award Number: S425U210038
Pass‐Through Agency: Arizona Department of Education
Questioned Costs: N/A
Type of Finding: Noncompliance, Material Weakness
Compliance Requirement: Reporting
Criteria
Districts that received Education Stabilization Fund funding were required by the Arizona Department
of Education to complete the “LEA Uses of ESSER I, II, & III – Use of Funds Detail” report by April 21,
2023. The report was based on fiscal year 2021‐22 financial information and full‐time equivalency
(FTE) information.
Condition
Inadequate internal controls existed over the Education Stabilization Fund reporting processes.
Cause
The District did not develop nor implement strong internal controls over reporting due lack of training
for individuals with reporting responsibilities.
Effect
The District is at risk of reporting inaccurate information.
Context
The District was unable to provide supporting documentation for the allocation of expenditures to
the four categories listed in the report and the FTE information as of September 30, 2022.
The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should develop or implement strong internal controls over reporting to reduce the risk
of reporting inaccurate information.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐003
Repeat Finding: Yes, 2022‐001
Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Education
Federal Award Number: GR‐ARPA‐ASL‐ISAACSD‐161, GR‐ARPA‐SEP‐ISAACSD‐37
Pass‐Through Agency: Arizona Governor’s Office
Questioned Costs: N/A
Type of Finding: Material Weakness, Noncompliance
Compliance Requirement: Activities allowed or unallowed, allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not have adequate internal controls in place to ensure eligible expenditures for the
Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program were not reimbursed by other
federal grants.
Cause
The District lacked internal controls over grants management. The District consistently had initial
grant budgets approved well after the beginning of each grant’s period of performance. Additionally,
the District was not reviewing actual spending to approved budgets, and, therefore, did not submit
for budget revisions or reimbursements in a timely manner.
Effect
The District did not ensure the grant expenditures were properly reported on the Schedule of
Expenditures of Federal Awards, resulting in the need for the single audit report to be reissued.
Context
The District requested reimbursement in early calendar year 2024 for SLFRF grant expenditures, of
which $1,723,915 were recorded within the Education Stabilization Fund (ESF). Journal entries to
move the expenditures to the SLFRF grant fund were not performed until early calendar year 2025.
The result is that the District was reimbursed for the same costs from both the ESF and SLFRF
programs. However, the District later performed journal entries, in early calendar year 2025, to move
additional eligible expenditures for the ESF that replaced the expenditures reimbursed by the SLFRF
program.
The sample was not intended to be, and was not, a statistically valid sample.Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
should implement controls to ensure expenditures are not submitted for reimbursement under
multiple federal grants. The District should also have more consistent and timely oversight of grants
by higher level management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐003
Repeat Finding: Yes, 2022‐001
Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Education
Federal Award Number: GR‐ARPA‐ASL‐ISAACSD‐161, GR‐ARPA‐SEP‐ISAACSD‐37
Pass‐Through Agency: Arizona Governor’s Office
Questioned Costs: N/A
Type of Finding: Material Weakness, Noncompliance
Compliance Requirement: Activities allowed or unallowed, allowable costs/cost principles
Criteria
In accordance with 2 CFR Part 200.303, the District is responsible for the establishing and maintaining
effective internal control over the Federal award that provides reasonable assurance that the non‐
Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and
the terms and conditions of the Federal award.
Condition
The District did not have adequate internal controls in place to ensure eligible expenditures for the
Coronavirus State and Local Fiscal Recovery Funds (SLFRF) program were not reimbursed by other
federal grants.
Cause
The District lacked internal controls over grants management. The District consistently had initial
grant budgets approved well after the beginning of each grant’s period of performance. Additionally,
the District was not reviewing actual spending to approved budgets, and, therefore, did not submit
for budget revisions or reimbursements in a timely manner.
Effect
The District did not ensure the grant expenditures were properly reported on the Schedule of
Expenditures of Federal Awards, resulting in the need for the single audit report to be reissued.
Context
The District requested reimbursement in early calendar year 2024 for SLFRF grant expenditures, of
which $1,723,915 were recorded within the Education Stabilization Fund (ESF). Journal entries to
move the expenditures to the SLFRF grant fund were not performed until early calendar year 2025.
The result is that the District was reimbursed for the same costs from both the ESF and SLFRF
programs. However, the District later performed journal entries, in early calendar year 2025, to move
additional eligible expenditures for the ESF that replaced the expenditures reimbursed by the SLFRF
program.
The sample was not intended to be, and was not, a statistically valid sample.Recommendation
The District should provide training for those with grants management responsibilities. In particular,
the District should provide training on the relationship between the District’s accounting records and
should implement controls to ensure expenditures are not submitted for reimbursement under
multiple federal grants. The District should also have more consistent and timely oversight of grants
by higher level management.
Views of Responsible Officials
See Corrective Action Plan.
Finding Number: 2023‐004
Repeat Finding: No
Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Education
Federal Award Number: GR‐ARPA‐ASL‐ISAACSD‐161, GR‐ARPA‐SEP‐ISAACSD‐37
Pass‐Through Agency: Arizona Governor’s Office
Questioned Costs: N/A
Type of Finding: Significant Deficiency, Noncompliance
Compliance Requirement: 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 documentation was not maintained for vendors with which
the District spent at least $25,000 of federal grant monies.
Cause
The District has not implemented consistent internal controls over suspension and debarment due
to turnover in the Purchasing Department.
Effect
The District was not in compliance with the requirements set forth by the federal government.
However, it was subsequently determined that the three vendors sampled were not suspended or
debarred.
Context
For three vendors that the District utilized for the program, the District did not 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: 2023‐004
Repeat Finding: No
Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds
Assistance Listing Number: 21.027
Federal Agency: U.S. Department of Education
Federal Award Number: GR‐ARPA‐ASL‐ISAACSD‐161, GR‐ARPA‐SEP‐ISAACSD‐37
Pass‐Through Agency: Arizona Governor’s Office
Questioned Costs: N/A
Type of Finding: Significant Deficiency, Noncompliance
Compliance Requirement: 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 documentation was not maintained for vendors with which
the District spent at least $25,000 of federal grant monies.
Cause
The District has not implemented consistent internal controls over suspension and debarment due
to turnover in the Purchasing Department.
Effect
The District was not in compliance with the requirements set forth by the federal government.
However, it was subsequently determined that the three vendors sampled were not suspended or
debarred.
Context
For three vendors that the District utilized for the program, the District did not 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.