EIN: 866000393
UEI: MXSLB6SCUAR5
Data as of August 26, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on June 10, 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 December 10, 2026 (106 days from today).
What is a management decision? →During our testing for one of 2 contractors that were tested and funded under the Impact Aid program, we noted that the District did not obtain or review certified payroll reports from contractors to verify compliance with federal prevailing wage requirements. As a result, the District could not demonstrate that contractors complied with required wage provisions for the sampled projects. Cause: The District did not have established procedures to ensure that certified payroll documentation was obtained and reviewed for federally funded construction projects. District personnel were not aware that federal wage requirements applied to the project. Effect: Failure to ensure compliance with federal prevailing wage requirements may result in laborers and mechanics being paid less than required wage rates. This noncompliance could result in questioned costs, repayment of federal funds, or other sanctions by the awarding agency. Recommendation: We recommend the District implement policies and procedures to ensure effective monitoring of compliance with Federal wage rate requirements. This includes obtaining required wage determinations prior to project commencement, including wage requirements in contract documents, and collecting certified payroll reports from contractors. Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over compliance with wage rate requirements under the Davis Bacon Act.
Show full finding ▾Hide full finding ▴Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Pass-Through Agency: Direct award Grantor Number: Not applicable Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions – Wage Rate Requirements Repeat Finding: Yes. Same as finding 2024-001 and 2023-002. Criteria or Specific Requirement: Federal regulations require that contractors and subcontractors performing work on federally funded construction projects pay laborers and mechanics wages at rates not less than those prevailing on similar projects in the locality. These requirements are established under the Davis-Bacon Act and incorporated into federal grant compliance requirements under 2 CFR Part 200. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly per 29 CFR 5.5 compliance provisions. Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing for one of 2 contractors that were tested and funded under the Impact Aid program, we noted that the District did not obtain or review certified payroll reports from contractors to verify compliance with federal prevailing wage requirements. As a result, the District could not demonstrate that contractors complied with required wage provisions for the sampled projects. Cause: The District did not have established procedures to ensure that certified payroll documentation was obtained and reviewed for federally funded construction projects. District personnel were not aware that federal wage requirements applied to the project. Effect: Failure to ensure compliance with federal prevailing wage requirements may result in laborers and mechanics being paid less than required wage rates. This noncompliance could result in questioned costs, repayment of federal funds, or other sanctions by the awarding agency. Recommendation: We recommend the District implement policies and procedures to ensure effective monitoring of compliance with Federal wage rate requirements. This includes obtaining required wage determinations prior to project commencement, including wage requirements in contract documents, and collecting certified payroll reports from contractors. Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over compliance with wage rate requirements under the Davis Bacon Act.
2025-005: WAGE RATE REQUIREMENTS Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Pass-Through Agency: Direct award Grantor Number: Not applicable Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions – Wage Rate Requirements Repeat Finding: Yes. Same as finding 2024-001 and 2023-002. Criteria or Specific Requirement: Federal regulations require that contractors and subcontractors performing work on federally funded construction projects pay laborers and mechanics wages at rates not less than those prevailing on similar projects in the locality. These requirements are established under the Davis-Bacon Act and incorporated into federal grant compliance requirements under 2 CFR Part 200. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly per 29 CFR 5.5 compliance provisions. Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with guidance in “Standards for Internal Control in Federal Government” issued by the Comptroller General of the United States or the “Internal Control-Integrated Framework,” issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing for one of 2 contractors that were tested and funded under the Impact Aid program, we noted that the District did not obtain or review certified payroll reports from contractors to verify compliance with federal prevailing wage requirements. As a result, the District could not demonstrate that contractors complied with required wage provisions for the sampled projects. Corrective Action: The District will ensure wage rate requirements are maintained for all vendors as appropriate under Uniform Guidance and the provision of the Davis Bacon Act. Planned completion date for corrective action plan: For the period ending June 30, 2026. Name of the contact person responsible for corrective action: Kay Morris, Superintendent
2024-001, 2023-002
FAC accepted this audit on March 27, 2025 — management decision was due September 27, 2025.
2024-001 WAGE RATE REQUIREMENTS Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: N/A Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Condition/Context: Wage certificates were not maintained for construction projects exceeding $2,000 or other minor remodeling projects during the current year. Documentation was not maintained to support contracts included the proper wage rate clauses. Criteria: According to Federal guidelines, §7007 construction funds, as well as any §7002 or §7003(b) funds expended for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Cause: Management oversight and turnover in the federal grant department. Effect: Noncompliance and internal control weakness. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District to review its internal control procedures over wage rate requirements and construction projects to ensure the proper documentation and disclosures are entered into contracts and obtained from contractors. Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over the federal wage rate requirements. Contact Person: Barbara Baca, Business Manager
Show full finding ▾Hide full finding ▴2024-001 WAGE RATE REQUIREMENTS Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: N/A Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Condition/Context: Wage certificates were not maintained for construction projects exceeding $2,000 or other minor remodeling projects during the current year. Documentation was not maintained to support contracts included the proper wage rate clauses. Criteria: According to Federal guidelines, §7007 construction funds, as well as any §7002 or §7003(b) funds expended for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Cause: Management oversight and turnover in the federal grant department. Effect: Noncompliance and internal control weakness. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District to review its internal control procedures over wage rate requirements and construction projects to ensure the proper documentation and disclosures are entered into contracts and obtained from contractors. Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over the federal wage rate requirements. Contact Person: Barbara Baca, Business Manager
CORRECTIVE ACTION PLAN U.S. Department of Education | Arizona Department of Education Sanders Unified School District No. 18 respectfully submits the following corrective action plan for the year ended June 30, 2024. Audit period: July 1, 2023 – June 30, 2024 The findings from the schedule of findings and questioned costs are discussed below. The findings are numbered consistently with the numbers assigned in the schedule. FINDINGS— FEDERAL AWARDS FINDINGS AND QUESTIONED COSTS 2024-001 WAGE RATE REQUIREMENTS Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: N/A Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Condition/Context: Wage certificates were not maintained for construction projects exceeding $2,000 or other minor remodeling projects during the current year. Documentation was not maintained to support contracts included the proper wage rate clauses. Criteria: According to Federal guidelines, §7007 construction funds, as well as any §7002 or §7003(b) funds expended for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Corrective Action: The District will ensure the proper wage rate language is included in all contracts for construction and minor remodeling projects exceeding $2,000. In addition, wage rate certifications will be received when necessary and reviewed to ensure they adhere to wage rate requirements. Planned completion date for corrective action plan: For the period ending June 30, 2025. Name of the contact person responsible for corrective action: Barbara Baca, Business Manager
FAC accepted this audit on April 2, 2024 — management decision was due October 2, 2024.
2023-001 EQUIPMENT AND REAL PROPERTY MANAGEMENT Program: Education Stabilization Fund – ESSER III Federal Assistance Listing Number: 84.425U Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESIII-111119-01A Questioned Costs: $16,552 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: F. Equipment and Real Property Management Condition/Context: During our testing of equipment assets, it was noted that one asset was not authorized by the SEA prior to the purchase being made. Criteria: The Uniform Guidance compliance supplement. Cause: Management oversight and turnover in the federal grant department. Effect: Noncompliance and internal control weakness. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District to review its internal control procedures over federal programs to ensure capital equipment items are approved by the SEA prior to the purchase being made. Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over capital equipment purchases out of the ESSER grants to ensure the SEA approves the activity before disbursements are made. Contact Person: Barbara Baca, Business Manager
Show full finding ▾Hide full finding ▴2023-001 EQUIPMENT AND REAL PROPERTY MANAGEMENT Program: Education Stabilization Fund – ESSER III Federal Assistance Listing Number: 84.425U Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESIII-111119-01A Questioned Costs: $16,552 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: F. Equipment and Real Property Management Condition/Context: During our testing of equipment assets, it was noted that one asset was not authorized by the SEA prior to the purchase being made. Criteria: The Uniform Guidance compliance supplement. Cause: Management oversight and turnover in the federal grant department. Effect: Noncompliance and internal control weakness. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District to review its internal control procedures over federal programs to ensure capital equipment items are approved by the SEA prior to the purchase being made. Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over capital equipment purchases out of the ESSER grants to ensure the SEA approves the activity before disbursements are made. Contact Person: Barbara Baca, Business Manager
2023-001 EQUIPMENT AND REAL PROPERTY MANAGEMENT Program: Education Stabilization Fund – ESSER III Federal Assistance Listing Number: 84.425U Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 21FESIII-111119-01A Questioned Costs: $16,552.20 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: F. Equipment and Real Property Management Condition/Context: During our testing of equipment assets, it was noted that one asset was not authorized by the SEA prior to the purchase being made. Corrective Action: The District will ensure all real property and equipment purchases are approved by the SEA before purchase. Planned completion date for corrective action plan: For the period ending June 30, 2024. Name of the contact person responsible for corrective action: Barbara Baca, Business Manager
2023-002 WAGE RATE REQUIREMENTS Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: N/A Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Condition/Context: Wage certificates were not maintained for construction projects exceeding $2,000 or other minor remodeling projects during the current year. Documentation was not maintained to support contracts included the proper wage rate clauses. Criteria: According to Federal guidelines, §7007 construction funds, as well as any §7002 or §7003(b) funds expended for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Cause: Management oversight and turnover in the federal grant department. Effect: Noncompliance and internal control weakness. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District to review its internal control procedures over wage rate requirements and construction projects to ensure the proper documentation and disclosures are entered into contracts and obtained from contractors. Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over the federal wage rate requirements. Contact Person: Barbara Baca, Business Manager
Show full finding ▾Hide full finding ▴2023-002 WAGE RATE REQUIREMENTS Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: N/A Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Condition/Context: Wage certificates were not maintained for construction projects exceeding $2,000 or other minor remodeling projects during the current year. Documentation was not maintained to support contracts included the proper wage rate clauses. Criteria: According to Federal guidelines, §7007 construction funds, as well as any §7002 or §7003(b) funds expended for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Cause: Management oversight and turnover in the federal grant department. Effect: Noncompliance and internal control weakness. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District to review its internal control procedures over wage rate requirements and construction projects to ensure the proper documentation and disclosures are entered into contracts and obtained from contractors. Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over the federal wage rate requirements. Contact Person: Barbara Baca, Business Manager
Program: Impact Aid Federal Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Questioned Costs: N/A Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions Condition/Context: Wage certificates were not maintained for construction projects exceeding $2,000 or other minor remodeling projects during the current year. Documentation was not maintained to support contracts included the proper wage rate clauses. Criteria: According to Federal guidelines, §7007 construction funds, as well as any §7002 or §7003(b) funds expended for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Corrective Action: The District will ensure the proper wage rate language is included in all contracts for construction and minor remodeling projects exceeding $2,000. In addition, wage rate certifications will be received when necessary and reviewed to ensure they adhere to wage rate requirements. Planned completion date for corrective action plan: For the period ending June 30, 2024. Name of the contact person responsible for corrective action: Barbara Baca, Business Manage
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