Finding 518749 (2024-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-01-10

AI Summary

  • Core Issue: The District failed to follow required procurement standards for federal awards, leading to noncompliance.
  • Impacted Requirements: Noncompliance with procurement regulations outlined in 2 CFR §§200.318-326, affecting federal, state, and board policies.
  • Recommended Follow-Up: Ensure that all multi-year purchases over the formal threshold are procured according to established policies and regulations.

Finding Text

Findings and Questioned Costs Related to Federal Awards Finding Number: 2024‐001 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 Treasury Federal Award Number: ERMT‐21‐2016 Pass‐Through Agency: Arizona Governor’s Office Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §§200.318 through 200.326. Subrecipients must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Condition The District did not follow Federal, State, and Board policies and regulations governing procurement. Cause The District’s review procedures over each transaction did not operate as designed. Effect The District was not in compliance with Federal, State, and Board policies and regulations governing procurement. Context The District procured a multi‐year professional development support services contract in the amount of $111,200 using quotations rather than issuing a formal procurement. The sample was not intended to be, and was not, a statistically valid sample. Recommendation Approvers of requisitions should ensure multi‐year purchases exceeding the formal procurement threshold are appropriately procured in accordance with Federal, State and Board policies and regulations. Views of Responsible Officials See Corrective Action Plan.

Corrective Action Plan

Findings and Questioned Costs Related to Federal Awards Finding Number: 2024‐001 Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Cheryl Burt, Director of Purchasing; Courtney Pina, Executive Director of Finance Anticipated Completion Date: Ongoing Planned Corrective Action: Issue Identified – The District failed to follow Federal, State, and Board policies and regulations governing procurement when procuring a multi‐year professional development support services contract for $111,200. Instead of issuing a formal procurement process, the District used quotes, which did not meet compliance requirements under 2 CFR §§200.318–200.326. Actions Taken to Address the Finding 1. Immediate Remedial Actions o Contract Review: Conducted a thorough review of the contract in question and determined steps to ensure compliance with applicable policies. o Internal Notification: Informed all relevant staff and departments about the compliance violation to prevent similar issues in the future. 2. Policy Review and Alignment o Procurement Policy Review: Conducted a comprehensive review of internal procurement policies to ensure alignment with federal requirements outlined in 2 CFR §§200.318–200.326, as well as applicable state and board requirements. o Threshold Verification: Confirmed that all documented thresholds for procurement types (e.g., formal procurement, quotes) are clearly stated in district policies to ensure consistency and compliance. Actions Planned to Prevent Future Occurrences 1. Training and Awareness o Staff Training: Implement mandatory training for staff involved in procurement processes to ensure familiarity with federal, state, and board regulations. Training sessions will emphasize formal procurement thresholds and the procedures for multi‐year contracts. o Annual Refresher Training: Conduct annual training sessions to maintain staff awareness of procurement requirements and reinforce adherence. 2. Strengthening Internal Controls o Requisition Review: Implement an enhanced approval process requiring multiple levels of review for all procurement transactions exceeding $50,000 to ensure compliance before purchase. o Checklist Requirement: Provide approvers with a compliance checklist verifying adherence to federal, state, and board procurement requirements before approving requisitions. 3. Ongoing Monitoring o Quarterly Audits: Schedule quarterly internal audits of procurement transactions to verify compliance with established policies and identify any gaps early.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1095191 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $3.29M
84.425 Education Stabilization Fund $3.29M
84.027 Special Education_grants to States $1.09M
21.027 Coronavirus State and Local Fiscal Recovery Funds $970,578
84.010 Title I Grants to Local Educational Agencies $879,998
10.553 School Breakfast Program $428,098
84.367 Supporting Effective Instruction State Grant $230,657
84.377 School Improvement Grants $191,355
84.365 English Language Acquisition State Grants $118,975
10.559 Summer Food Service Program for Children $90,044
84.424 Student Support and Academic Enrichment Program $46,644
84.173 Special Education_preschool Grants $15,997
93.778 Medical Assistance Program $12,381
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $4,792