Florence Unified School District No. 1

2024-001 ELIGIBILITY OVER TITLE I

Program: Title I Federal Assistance Listing Number: 84.010 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 24FT1TTI-411467-01A Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: E. Eligibility

Condition/Context: During our testing of school eligibility and funding, we discovered the District did not maintain records that agreed to the low-income student counts as reported to the Arizona Department of Education to properly allocate Title I funding by poverty level.

Criteria or Specific Requirement: The Uniform Guidance compliance supplement.

Cause: Management oversight and turnover in the federal grant department.

Effect: Noncompliance and internal control weakness.

Repeat Finding: Same as finding 2023-003.

Recommendation: We recommend the District to review its internal control procedures of federal programs to ensure documentation is maintained to support the allocation of Title I funding based on the poverty level of individual school sites.

Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over federal program reporting

2024-002: PROVISIONS OF THE DAVIS-BACON ACT

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-111467-01A Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: N. Special Tests and Provisions

Condition/Context: During our testing of two of 2 contractors, we noted the District did not have adequate internal controls designed to ensure contractors were in compliance with applicable Davis-Bacon Wage Rate requirements. The District did not retain documentation supporting indication of certified payrolls being submitted in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund.

Criteria or Specific Requirement: The Davis-Bacon Act requires that laborers and mechanics employes by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. 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).

Cause: The District’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors were monitored for compliance.

Effect: Noncompliance and internal control weakness.

Repeat Finding: No.

Recommendation: We recommend the District implement policies and procedures to ensure effective monitoring of compliance with Davis-Bacon wage requirements.

Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over capital asset and property control.

2023-003 ELIGIBILITY OVER TITLE I Program: Title I Federal Assistance Listing Number: 84.010 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 23FT1TTI-311467-01A Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: E. Eligibility Condition/Context: During our testing of school eligibility and funding, we discovered the District did not maintain records that agreed to the low-income student counts as reported to the Arizona Department of Education to properly allocate Title I funding by poverty level. 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 of federal programs to ensure documentation is maintained to support the allocation of Title I funding based on the poverty level of individual school sites. Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over federal program reporting. Contact Person: Beverly Myers, Chief Financial Operations Officer

2023-004 ELIGIBILITY OVER NATIONAL SCHOOL LUNCH PROGRAM Program: National School Lunch Program Federal Assistance Listing Number: 10.553 and 10.555 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 7AZ300AZ3 Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: E. Eligibility Condition/Context: During our testing of participant eligibility, it was determined that one of 25 applications were not properly classified as free, reduced, or paid based on income eligibility. The application in question was recorded as reduced, when it should have been classified as free. 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 the national school lunch program application process to ensure applications are reviewed for eligibility based on income factors and those eligibility determinations are being reviewed. Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over the national school lunch program individual application process. Contact Person: Beverly Myers, Chief Financial Operations Officer