Williams Unified School District No. 2

Finding Number: 2025‐001 Repeat Finding: No Program Name/Assistance Listing Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Agency: Department of Treasury Federal Award Number: WCG2023‐‐00008 Pass‐Through Agency: Water Infrastructure Finance Authority of Arizona Questioned Costs: N/A Type of Finding: Significant Deficiency Compliance Requirement: Procurement and Suspension and Debarment Criteria Non‐federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR §§200.318 through 200.326. Subrecipients must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. 2 CFR §§200.214 requires that vendors are checked to ensure they are not suspended or debarred from receiving federal funds. Condition The District did not follow Federal and State regulations governing procurement. Cause The District did not have policies and procedures in place to verify a vendor was not suspended or debarred. Effect The District was not in compliance with Federal and State regulations governing procurement. Context The sample was not intended to be, and was not, a statistically valid sample. For two vendors reviewed for suspension and debarment check requirements, the District did not maintain verification that the vendor was not suspended or debarred. Upon review of the vendors, neither were suspended or debarred. Recommendation The District should implement policies and procedures over procurement, specifically suspension and debarment, to ensure goods and services are procured through vendors who are not suspended or debarred, so that federal monies exceeding the formal procurement threshold are used appropriately. Views of Responsible Officials See Corrective Action Plan.

Finding Number: 2024‐001 Repeat Finding: Yes, 2023‐001 Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Numbers: S425D210038, S425U210038, S425W210003 Pass‐Through Agency: Arizona Department of Education Questioned Costs: N/A Type of Finding: Noncompliance, Material Weakness Compliance Requirement: Reporting Criteria ESSER, GEER, and EANS grantees must submit an annual performance report with data on expenditures, planned expenditures, subrecipients, and uses of funds, including for mandatory reservations. LEAs/subrecipients submit data to the SEA/Governor for the SEA/Governor’s report. Annual reports are due each spring for the previous reporting period under OMB No. 1810‐0749. Condition District procedures were not in place to ensure all federal requirements were followed. Cause The District’s internal controls and procedures were not always followed to ensure that all applicable reports were submitted to the SEA. Staff turnover contributed to the deficiency. Effect The District was not in compliance with federal requirements related to special reporting. Context The District did not submit the LEA Uses of ESSER I, II, & III – Use of Funds Detail report to the Arizona Department of Education as required. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should ensure that all special reports are submitted to the Arizona Department of Education in a timely manner, and that adequate supporting documentation is maintained. Views of Responsible Officials See Corrective Action Plan.

Findings and Questioned Costs Related to Federal Awards Finding Number: 2023‐001 Repeat Finding: No Program Name/Assistance Listing Title: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Agency: U.S. Department of Education Federal Award Number: S425D210038, S425U210038, S425W210003 Pass‐Through Agency: Arizona Department of Education Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Reporting Criteria Education Stabilization Fund grantees must submit an annual performance report to the SEA/Governor for the SEA’s/Governor’s report under OMB No. 1810‐0749. Condition Total amount expended per the LEA Uses of Elementary and Secondary School Emergency Relief (ESSER) I, II, & III ‐ Use of Funds Detail report could not be agreed to the District’s accounting records. Cause Fiscal year 2023 was the first year that this reporting requirement was in effect and there was a lot of confusion from ADE that led to misreporting. Effect The District did not comply with the reporting requirements of the grant. Context The amounts reported on the LEA Uses of ESSER I, II, & III – Use of Funds Detail report cannot be agreed to general ledger expenditures. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should monitor and ensure amounts expended per the LEA Uses of ESSER I, II, & III – Use of Funds Detail report agree to the District’s accounting records. Views of Responsible Officials See Corrective Action Plan.