Finding Text
Assistance
Listing
Numbers:
Federal Award
Numbers:
Questioned
Costs:
Special Education Cluster
84.027A,
84.027X,
84.173A,
84.173X
H027A220007,
H027X210007,
H173A220003,
H173X210003
None
Coronavirus State and Local Fiscal Recovery Funds
21.027
GFRT‐21‐1074 GR‐ARPA‐
100Day‐HIGLEYUSD‐
052022‐119 and GRARPA‐
ASL‐HIGLEY‐145
Federal Agency(ies): Arizona Department of Education, Arizona Governor’s Office
Pass‐Through Agency(ies): 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. “Covered transactions” include 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. All non‐procurement
transactions entered into by a pass‐through entity (i.e., subawards to subrecipients), irrespective of
award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR
§180.215.
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
The District only performed procedures to verify vendors were not suspended or debarred for
contracts that were in excess of $100,000.
Effect
The District was not in compliance with federal guidelines. Context
For one Special Education Cluster purchase and four Coronavirus State and Local Recovery Fund
purchases reviewed, the District did not maintain documentation that a suspension and debarment
verification check was completed for purchases in excess of $25,000 but less than $100,000. Upon
audit inquiry, a subsequent verification check was performed, and it was determined that the vendors
were ultimately not suspended or debarred. The sample was not intended to be, and was not, a
statistically valid sample.
Recommendation
The District should update procurement policies to align with federal rules to verify vendors are not
suspended or debarred. In addition, we recommend resources be allocated to train employees to
ensure compliance with federal requirements regarding procurement.
Views of Responsible Officials
See Corrective Action Plan.