Finding Text
Finding Number: 2024‐001
Repeat Finding: No
Program Name/Assistance Listing Title: Special Education Cluster
Assistance Listing Numbers: 84.027, 84.027X, 84.173, 84.173X
Federal Agency: U.S. Department of Education
Federal Award Numbers: H027A230007, H027X210007, H173A230003, H173X210003
Pass‐Through Agency: Arizona Department of Education
Questioned Costs: N/A
Type of Finding: Noncompliance, Significant Deficiency
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.
Additionally, the District should adhere to procurement methods outlined in 2 CFR §200.320.
Condition
Verification of suspension and debarment was not performed for one vendor the District utilized and
spent at least $25,000 of federal grant monies. Additionally, the District did not follow federal
guidelines for purchases exceeding the small purchases threshold.
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 federal regulations and guidelines related to suspension and
debarment or procurement. However, it was subsequently determined that the vendor utilized was
not suspended or debarred.
Context
For one of three purchases with vendors above $25,000 sampled, the District did not maintain
documentation that verification a vendor was non suspended or debarred. In addition, for three
purchases that exceeded the Federal micro‐purchase threshold, the written quotes obtained did not
allow sufficient time before the purchase was to be made to allow vendors to effectively respond.
The District only allowed 24 hours for several of the requests for quotes. Therefore, the District’s
method of procurement was not in accordance with federal guidelines. 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 procurement requirements.
Views of Responsible Officials
See Corrective Action Plan.