LITTLEFIELD SCHOOL DISTRICT #9

2025-005: FEDERAL PROCUREMENT PROCEDURES Program: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: I. Procurement, Suspension, and Debarment

Condition: During testing of procurement activities within the Child Nutrition Cluster, we selected three purchases for review. For all three purchases tested, the District did not perform and document the procurement procedures required under federal regulations to obtain written price quotations. Specifically, the District was unable to provide evidence demonstrating that applicable procurement requirements, including obtaining and documenting competition as required by federal procurement standards, were followed prior to making the purchases.

Criteria or Specific Requirement: Title 2 CFR §200.318 through §200.327 requires non-federal entities expending federal awards to establish and follow documented procurement procedures that reflect applicable federal, state, and local laws and regulations. These procedures must ensure full and open competition and maintain sufficient records to detail the history of the procurement, including the rationale for the method of procurement, contractor selection, and the basis for contract pricing.

Cause: District personnel responsible for procurement and federal program administration did not consistently apply and document procurement procedures for purchases charged to the Child Nutrition Cluster. The District did not maintain documentation to support that three written quotes were maintained to support the purchases or that other applicable methods of procurement were utilized (cooperative purchases, RFP’s, etc.) Additionally, management's monitoring controls were not sufficient to ensure compliance with federal procurement requirements prior to the expenditure of federal funds.

Effect: Failure to follow and document required procurement procedures increases the risk that purchases may not be made in accordance with federal requirements, potentially limiting competition and resulting in questioned costs, repayment of federal funds, or other sanctions from grantor agencies.

Repeat Finding: No.

Recommendation: We recommend the District strengthen internal controls over procurement compliance by implementing procedures to ensure all purchases made with federal funds are reviewed for compliance with applicable procurement requirements before purchases are finalized, maintaining documentation supporting the procurement method utilized, solicitation of bids or quotes when required, vendor selection, and price determination.

Views of Responsible Officials: The District concurs with this recommendation. See the corrective action plan in a separately published document.

2025-006: STUDENT MEAL APPLICATIONS Program: Child Nutrition Cluster Federal Assistance Listing Number: 10.553, 10.555, 10.559 Federal Agency: U.S. Department of Agriculture Pass-Through Agency: Arizona Department of Education Grantor Number: ADE ED09-0001 Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: E. Eligibility

Condition: During our testing of eligibility determinations under the Child Nutrition Cluster, we selected 40 student meal applications for review. Of the 40 applications tested, two applications were incorrectly classified based on the information provided on the applications. Specifically, one application was approved as free when it should have been approved as reduced, and one application was approved as reduced when it should have been approved as paid based on applicable eligibility guidelines.

Criteria or Specific Requirement: Program regulations and guidance require school food authorities to accurately determine and document student eligibility for free, reduced-price, and paid meal benefits. District personnel are required to maintain documentation supporting eligibility determinations and retain records sufficient to demonstrate compliance with federal program requirements.

Cause: The District's procedures and monitoring controls over the review, approval, and retention of meal eligibility applications were not operating effectively. Specifically, management did not ensure that eligibility determinations were consistently reviewed for accuracy.

Effect: Incorrect eligibility determinations may result in students receiving meal benefits inconsistent with federal program requirements and may impact reimbursement claims submitted under the Child Nutrition Cluster programs.

Repeat Finding: No.

Recommendation: We recommend the District strengthen internal controls over eligibility determinations by: Establishing formal review procedures to ensure meal applications are approved in accordance with current USDA eligibility guidelines; implementing a secondary review process for eligibility determinations prior to final approval; maintaining complete and organized records supporting all eligibility determinations in accordance with federal record retention requirements; providing periodic training to personnel responsible for processing and approving meal applications.

Views of Responsible Officials: The District concurs with this recommendation. See the corrective action plan in a separately published document.

2025-007: REPORTING REQUIREMENTS Program: Public Safety Partnership and Community Policing Grants Federal Assistance Listing Number: 16.710 Federal Agency: U.S. Department of Justice Pass-Through Agency: Direct award Grantor Number: 15JCOPS-24-GG-03437-SSIX Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: L. Reporting

Condition: The District did not prepare and submit the required Federal Financial Report (SF-425) associated with its COPS School Violence Prevention Program (SVPP) grant. During audit testing, the District was unable to provide evidence that the SF-425 had been completed or submitted to the grantor. Additionally, the District could not provide supporting documentation demonstrating that a final financial report, reimbursement request, or other required grant closeout reporting had been prepared and submitted in accordance with the grant terms and conditions. The District lacked adequate internal controls to ensure required federal reports were identified, prepared, reviewed, retained, and submitted timely.

Criteria or Specific Requirement: The terms and conditions of the COPS School Violence Prevention Program grant require recipients to prepare and submit financial and performance reports, including the Federal Financial Report (SF-425), as required by the grant award. Additionally, 2 CFR § 200.303 requires non-Federal entities to establish and maintain effective internal control over Federal awards that provides reasonable assurance of compliance with Federal statutes, regulations, and the terms and conditions of Federal awards.

Cause: The District did not have sufficient procedures in place to identify, track, prepare, retain, and monitor grant reporting requirements. Responsibilities for grant reporting and retention of supporting documentation have not been formally established or monitored.

Effect: As a result of the control deficiency, the District could not demonstrate compliance with federal reporting requirements for the SVPP grant. The absence of completed reports and supporting documentation limited the District's ability to demonstrate that required financial information had been accurately reported to the grantor. Failure to submit and retain required reporting documentation may impair the federal awarding agency's ability to monitor grant expenditures and program performance and could result in increased oversight, delayed reimbursements, or other administrative actions.

Repeat Finding: No.

Recommendation: The District should establish and implement procedures to ensure all federal reporting requirements are identified, prepared, reviewed, submitted, and retained in accordance with grant requirements. Procedures should include maintaining a grant compliance calendar, assigning responsibility for report preparation and submission, documenting supervisory review, and retaining evidence of submission and supporting documentation for all required reports and reimbursement requests.

Views of Responsible Officials: The District concurs with this recommendation. See the corrective action plan in a separately published document.