EIN: 860208371
UEI: DGVVZL5ZXJD3
Audited by: CliftonLarsonAllen
Oversight agency: 84 [Department of Education]
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Data as of August 31, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 23, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by September 23, 2026 (21 days from today).
What is a management decision? →FAC accepted this audit on March 25, 2025 — management decision was due September 25, 2025.
FAC accepted this audit on March 22, 2024 — management decision was due September 22, 2024.
FAC accepted this audit on February 15, 2023 — management decision was due August 15, 2023.
FAC accepted this audit on March 28, 2022 — management decision was due September 28, 2022.
FAC accepted this audit on March 30, 2021 — management decision was due September 30, 2021.
Assistance Listings number and name: COVID-19 84.425 Education Stabilization Fund Award number and year: P425F200928, July 1, 2019 through June 30, 2020 Federal agency: U.S. Department of Education Compliance requirements: Procurement and Suspension and Debarment Questioned costs: None Condition?The District used another government?s or a purchasing cooperative?s contracts for 7 purchases totaling $169,961 of Education Stabilization Fund program goods and services during fiscal year 2020. For all 7 purchases, the District failed to perform and document due diligence procedures to verify that the other government or purchasing cooperative used purchasing policies that were consistent with the District?s. We verified that the other government or purchasing cooperative followed purchasing policies that were consistent with the District?s for the 7 purchases. Effect?The District did not comply with federal regulations, which increases the risk that the District may have used a contract that was not procured using policies that were consistent with the District?s and may not have been the most advantageous to the District. Cause?The District?s procurement policies did not address the need to perform and document due diligence procedures when using another government?s or a purchasing cooperative?s contracts, such as verifying that the other entity used procurement policies that were consistent with the District?s and documenting the rationale for the procurement method and contract type used. Criteria?Federal regulation requires the District to have and use its own documented procurement policies and procedures that reflect applicable federal and State laws and regulations when procuring program goods and services. [2 CFR ?200.318(a)] Federal regulation also requires the District to maintain records sufficient that document in detail the history of the procurement, including the rationale for the procurement method, such as due diligence performed, and contract type used. [2 CFR ?200.318(i)] Lastly, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms. (2 CFR ?200.303) Recommendations?The District should: 1. Improve its existing procurement policies to address the need to perform and document due diligence procedures when using another government?s or purchasing cooperative?s contracts, such as verifying that the other entity used policies that were consistent with the District?s and documenting in its procurement files the rationale for the procurement method and contract type used. 2. Perform due diligence procedures prior to using a vendor contract awarded by an outside procuring entity, such as another government or a purchasing cooperative. The District should use its judgment in determining the appropriate amount and complexity of due diligence required before using a procuring entity?s contract. The District may perform due diligence on a sample of the procuring entity?s contracts if that sample provides reasonable assurance that the entity?s procurement practices comply with the District's purchasing policies. The District should document the due diligence procedures performed and their results in its procurement files. The County?s responsible officials? views and planned corrective action are in its corrective action plan included at the end of this report.
Show full finding ▾Hide full finding ▴Assistance Listings number and name: COVID-19 84.425 Education Stabilization Fund Award number and year: P425F200928, July 1, 2019 through June 30, 2020 Federal agency: U.S. Department of Education Compliance requirements: Procurement and Suspension and Debarment Questioned costs: None Condition?The District used another government?s or a purchasing cooperative?s contracts for 7 purchases totaling $169,961 of Education Stabilization Fund program goods and services during fiscal year 2020. For all 7 purchases, the District failed to perform and document due diligence procedures to verify that the other government or purchasing cooperative used purchasing policies that were consistent with the District?s. We verified that the other government or purchasing cooperative followed purchasing policies that were consistent with the District?s for the 7 purchases. Effect?The District did not comply with federal regulations, which increases the risk that the District may have used a contract that was not procured using policies that were consistent with the District?s and may not have been the most advantageous to the District. Cause?The District?s procurement policies did not address the need to perform and document due diligence procedures when using another government?s or a purchasing cooperative?s contracts, such as verifying that the other entity used procurement policies that were consistent with the District?s and documenting the rationale for the procurement method and contract type used. Criteria?Federal regulation requires the District to have and use its own documented procurement policies and procedures that reflect applicable federal and State laws and regulations when procuring program goods and services. [2 CFR ?200.318(a)] Federal regulation also requires the District to maintain records sufficient that document in detail the history of the procurement, including the rationale for the procurement method, such as due diligence performed, and contract type used. [2 CFR ?200.318(i)] Lastly, federal regulation requires establishing and maintaining effective internal control over federal awards that provides reasonable assurance that federal programs are being managed in compliance with all applicable laws, regulations, and award terms. (2 CFR ?200.303) Recommendations?The District should: 1. Improve its existing procurement policies to address the need to perform and document due diligence procedures when using another government?s or purchasing cooperative?s contracts, such as verifying that the other entity used policies that were consistent with the District?s and documenting in its procurement files the rationale for the procurement method and contract type used. 2. Perform due diligence procedures prior to using a vendor contract awarded by an outside procuring entity, such as another government or a purchasing cooperative. The District should use its judgment in determining the appropriate amount and complexity of due diligence required before using a procuring entity?s contract. The District may perform due diligence on a sample of the procuring entity?s contracts if that sample provides reasonable assurance that the entity?s procurement practices comply with the District's purchasing policies. The District should document the due diligence procedures performed and their results in its procurement files. The County?s responsible officials? views and planned corrective action are in its corrective action plan included at the end of this report.
Assistance Listings number and program name: COVID-19 84.425F Education Stabilization Fund Contact person: Frank D?Angelo, Director of Business Services Anticipated completion date: April 16, 2021 Corrective Action: As discussed during the audit, the District currently performs due diligence before using cooperative contracts, however, specific documentation is not maintained. The current process for performing due diligence entails the use of a guidance sheet to check against the contracts to ensure compliancy. There is also a preliminary review of any cooperative before entering membership. As noted above, the auditors found that the other government and purchasing cooperatives reviewed did follow purchasing policies that were consistent with the District. The District will continue with its due diligence process but to further verify compliancy will update procedures specific to documenting the steps and rationale for cooperative contract review ensuring the cooperative entity is using procurement policies consistent with those of the District and any additional requirements as set forth by a grant.
FAC accepted this audit on February 4, 2020 — management decision was due August 4, 2020.
FAC accepted this audit on January 27, 2019 — management decision was due July 27, 2019.
FAC accepted this audit on January 29, 2018 — management decision was due July 29, 2018.
FAC accepted this audit on January 25, 2017 — management decision was due July 25, 2017.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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