Finding 59326 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2022-12-20

AI Summary

  • Core Issue: The District failed to verify if vendors were suspended or debarred for contracts over $25,000 using federal funds.
  • Impacted Requirements: Non-compliance with federal procurement rules, specifically regarding suspension and debarment checks.
  • Recommended Follow-Up: Establish and enforce policies to ensure all vendors are checked against suspension and debarment lists before contracting.

Finding Text

Finding Number: 2022-001 Repeat Finding: No Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Agency: Department of Treasury Federal Award Number: GRFT-21-1101 Pass-Through Agency: Arizona Governor?s Office 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. CONDITION Verification of suspension and debarment was not performed for all vendors with whom the District spent at least $25,000 using federal grant monies. CAUSE The District did not have policies and procedures in place to ensure vendors were not suspended or debarred. EFFECT The District was not in compliance with the requirements set forth by the federal government. However, it was determined that the vendors in question were not suspended or debarred. CONTEXT For two of four vendors reviewed with purchases in excess of $25,000, the District did not verify if the vendor was suspended or debarred. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The District should implement policies and procedures to ensure compliance with Federal requirements regarding suspension and debarment. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

Corrective Action Plan

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Program Name/Assistance Listing Title: COVID-19 Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Contact Person: Elaine Armienti, Business Manager Anticipated Completion Date: November 1, 2022 Planned Corrective Action: The District has implemented a policy for verification of suspension and debarment for all vendors with whom the District spends at least $25,000 using federal grant monies. Vendors with an initial purchase exceeding $25,000 using federal dollars are confirmed before a purchase order is issued. On a bi-monthly basis, a vendor total report is run to determine if any vendors are approaching the $25,000 limit. Vendors are confirmed to not be suspended or debarred before any purchase order change orders are executed and before additional purchases can be made. The Procurement Accountant researches vendors using Sam.Gov to determine compliance and documents that the vendor is in compliance. The Director of Business Services reviews and confirms the documentation.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 635768 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.559 Summer Food Service Program for Children $750,497
84.425 Covid-19 - Education Stabilization Fund $433,375
84.027 Special Education_grants to States $356,589
32.009 Covid-19 - Emergency Connectivity Fund Program $321,264
84.027 Covid-19 - Special Education_grants to States $67,129
21.027 Covid-19 - Coronavirus State and Local Fiscal Recovery Funds $63,612
84.010 Title I Grants to Local Educational Agencies $42,919
84.367 Supporting Effective Instruction State Grants $22,374
84.048 Career and Technical Education -- Basic Grants to States $16,231
84.424 Student Support and Academic Enrichment Program $10,179
10.555 National School Lunch Program $9,877
84.173 Special Education_preschool Grants $7,772