FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Child Nutrition Cluster 10.555, 10.559 7AZ300AZ3 N/A Emergency Connectivity Fund Program 32.009 N/A N/A Federal Agencies: U.S. Department of Agriculture, Federal Communications Commission Pass-Through Agencies: Arizona Department of Education, N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR ?180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR ?180.300). CONDITION The District did not initially meet the requirement to verify that covered transactions were only made to an entity that was not suspended or debarred or otherwise excluded. CAUSE Lack of record keeping due to the previous District procurement coordinator not including one of the authorized verification methods as part of the procurement process checklist. EFFECT The District was not in compliance with federal guidelines. CONTEXT For the only Emergency Connectivity Fund Program purchase and all five Child Nutrition Cluster purchases reviewed, the District did not maintain documentation that the verification was completed prior to making purchases with those vendors. Upon audit inquiry, a subsequent verification was performed, and it was determined the vendors were ultimately not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION Resources should be allocated to train employees to ensure compliance with federal requirements regarding procurement. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Child Nutrition Cluster 10.555, 10.559 7AZ300AZ3 N/A Emergency Connectivity Fund Program 32.009 N/A N/A Federal Agencies: U.S. Department of Agriculture, Federal Communications Commission Pass-Through Agencies: Arizona Department of Education, N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR ?180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR ?180.300). CONDITION The District did not initially meet the requirement to verify that covered transactions were only made to an entity that was not suspended or debarred or otherwise excluded. CAUSE Lack of record keeping due to the previous District procurement coordinator not including one of the authorized verification methods as part of the procurement process checklist. EFFECT The District was not in compliance with federal guidelines. CONTEXT For the only Emergency Connectivity Fund Program purchase and all five Child Nutrition Cluster purchases reviewed, the District did not maintain documentation that the verification was completed prior to making purchases with those vendors. Upon audit inquiry, a subsequent verification was performed, and it was determined the vendors were ultimately not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION Resources should be allocated to train employees to ensure compliance with federal requirements regarding procurement. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Child Nutrition Cluster 10.555, 10.559 7AZ300AZ3 N/A Emergency Connectivity Fund Program 32.009 N/A N/A Federal Agencies: U.S. Department of Agriculture, Federal Communications Commission Pass-Through Agencies: Arizona Department of Education, N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR ?180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR ?180.300). CONDITION The District did not initially meet the requirement to verify that covered transactions were only made to an entity that was not suspended or debarred or otherwise excluded. CAUSE Lack of record keeping due to the previous District procurement coordinator not including one of the authorized verification methods as part of the procurement process checklist. EFFECT The District was not in compliance with federal guidelines. CONTEXT For the only Emergency Connectivity Fund Program purchase and all five Child Nutrition Cluster purchases reviewed, the District did not maintain documentation that the verification was completed prior to making purchases with those vendors. Upon audit inquiry, a subsequent verification was performed, and it was determined the vendors were ultimately not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION Resources should be allocated to train employees to ensure compliance with federal requirements regarding procurement. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Child Nutrition Cluster 10.555, 10.559 7AZ300AZ3 N/A Emergency Connectivity Fund Program 32.009 N/A N/A Federal Agencies: U.S. Department of Agriculture, Federal Communications Commission Pass-Through Agencies: Arizona Department of Education, N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR ?180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR ?180.300). CONDITION The District did not initially meet the requirement to verify that covered transactions were only made to an entity that was not suspended or debarred or otherwise excluded. CAUSE Lack of record keeping due to the previous District procurement coordinator not including one of the authorized verification methods as part of the procurement process checklist. EFFECT The District was not in compliance with federal guidelines. CONTEXT For the only Emergency Connectivity Fund Program purchase and all five Child Nutrition Cluster purchases reviewed, the District did not maintain documentation that the verification was completed prior to making purchases with those vendors. Upon audit inquiry, a subsequent verification was performed, and it was determined the vendors were ultimately not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION Resources should be allocated to train employees to ensure compliance with federal requirements regarding procurement. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Child Nutrition Cluster 10.555, 10.559 7AZ300AZ3 N/A Emergency Connectivity Fund Program 32.009 N/A N/A Federal Agencies: U.S. Department of Agriculture, Federal Communications Commission Pass-Through Agencies: Arizona Department of Education, N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR ?180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR ?180.300). CONDITION The District did not initially meet the requirement to verify that covered transactions were only made to an entity that was not suspended or debarred or otherwise excluded. CAUSE Lack of record keeping due to the previous District procurement coordinator not including one of the authorized verification methods as part of the procurement process checklist. EFFECT The District was not in compliance with federal guidelines. CONTEXT For the only Emergency Connectivity Fund Program purchase and all five Child Nutrition Cluster purchases reviewed, the District did not maintain documentation that the verification was completed prior to making purchases with those vendors. Upon audit inquiry, a subsequent verification was performed, and it was determined the vendors were ultimately not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION Resources should be allocated to train employees to ensure compliance with federal requirements regarding procurement. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Child Nutrition Cluster 10.555, 10.559 7AZ300AZ3 N/A Emergency Connectivity Fund Program 32.009 N/A N/A Federal Agencies: U.S. Department of Agriculture, Federal Communications Commission Pass-Through Agencies: Arizona Department of Education, N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR ?180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR ?180.300). CONDITION The District did not initially meet the requirement to verify that covered transactions were only made to an entity that was not suspended or debarred or otherwise excluded. CAUSE Lack of record keeping due to the previous District procurement coordinator not including one of the authorized verification methods as part of the procurement process checklist. EFFECT The District was not in compliance with federal guidelines. CONTEXT For the only Emergency Connectivity Fund Program purchase and all five Child Nutrition Cluster purchases reviewed, the District did not maintain documentation that the verification was completed prior to making purchases with those vendors. Upon audit inquiry, a subsequent verification was performed, and it was determined the vendors were ultimately not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION Resources should be allocated to train employees to ensure compliance with federal requirements regarding procurement. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Child Nutrition Cluster 10.555, 10.559 7AZ300AZ3 N/A Emergency Connectivity Fund Program 32.009 N/A N/A Federal Agencies: U.S. Department of Agriculture, Federal Communications Commission Pass-Through Agencies: Arizona Department of Education, N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR ?180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR ?180.300). CONDITION The District did not initially meet the requirement to verify that covered transactions were only made to an entity that was not suspended or debarred or otherwise excluded. CAUSE Lack of record keeping due to the previous District procurement coordinator not including one of the authorized verification methods as part of the procurement process checklist. EFFECT The District was not in compliance with federal guidelines. CONTEXT For the only Emergency Connectivity Fund Program purchase and all five Child Nutrition Cluster purchases reviewed, the District did not maintain documentation that the verification was completed prior to making purchases with those vendors. Upon audit inquiry, a subsequent verification was performed, and it was determined the vendors were ultimately not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION Resources should be allocated to train employees to ensure compliance with federal requirements regarding procurement. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.
FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: No Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs: Child Nutrition Cluster 10.555, 10.559 7AZ300AZ3 N/A Emergency Connectivity Fund Program 32.009 N/A N/A Federal Agencies: U.S. Department of Agriculture, Federal Communications Commission Pass-Through Agencies: Arizona Department of Education, N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirements: Procurement, Suspension and Debarment CRITERIA Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR ?180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System of Award Management (SAM) maintained by the General Services Administration (GSA) or (2) collecting a certification from the entity, or adding a clause or condition to the covered transaction with that entity (2 CFR ?180.300). CONDITION The District did not initially meet the requirement to verify that covered transactions were only made to an entity that was not suspended or debarred or otherwise excluded. CAUSE Lack of record keeping due to the previous District procurement coordinator not including one of the authorized verification methods as part of the procurement process checklist. EFFECT The District was not in compliance with federal guidelines. CONTEXT For the only Emergency Connectivity Fund Program purchase and all five Child Nutrition Cluster purchases reviewed, the District did not maintain documentation that the verification was completed prior to making purchases with those vendors. Upon audit inquiry, a subsequent verification was performed, and it was determined the vendors were ultimately not suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION Resources should be allocated to train employees to ensure compliance with federal requirements regarding procurement. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.