Finding Text
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.