Finding 618406 (2022-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-02-06

AI Summary

  • Core Issue: The District failed to verify that vendors were not suspended or debarred before making purchases, violating federal compliance requirements.
  • Impacted Requirements: Non-federal entities must ensure compliance with procurement regulations, specifically verifying vendor eligibility as outlined in 2 CFR §180.
  • Recommended Follow-Up: Provide training for staff on procurement processes to ensure adherence to federal guidelines and improve record-keeping practices.

Finding Text

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.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 41964 2022-001
    Significant Deficiency
  • 41965 2022-001
    Significant Deficiency
  • 41966 2022-001
    Significant Deficiency
  • 41967 2022-001
    Significant Deficiency
  • 618407 2022-001
    Significant Deficiency
  • 618408 2022-001
    Significant Deficiency
  • 618409 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.559 Summer Food Service Program for Children $4.39M
84.027 Special Education_grants to States $1.30M
32.009 Covid-19 Emergency Connectivity Fund Program $1.16M
84.010 Title I Grants to Local Educational Agencies $650,922
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $563,577
84.048 Career and Technical Education-Basic Grants to States $337,247
10.555 National School Lunch Program $182,008
10.555 Covid-19 National School Lunch Program $102,655
84.367 Supporting Effective Instruction State Grants $98,616
84.424 Student Support and Academic Enrichment Program $56,732
12.357 Rotc Language and Culture Training Grants $28,225
84.196 Education for Homeless Children and Youth $9,899
84.365 English Language Acquisition State Grants $9,844
93.778 Medical Assistance Program $8,307
84.027 Covid-19 Special Education_grants to States $3,452
10.649 Covid-19 Pandemic Ebt Food Benefits $3,063
84.425 Covid-19 Education Stabilization Fund $2,094