USFR Hot Topics/Updates

USFR Compliance Questionnaire - 1988

• 13 pages

• 17 sections

• 123 questions

USFR Compliance Questionnaire - 1988

Purchasing Compliance

1. Were competitive bidding procedures established and followed in accordance with the rules prescribed by the State Board of Education?

2. Did the district follow the guidelines governing competitive purchasing below the dollar limits for sealed bids prescribed by the Auditor General?

USFR Compliance Questionnaire - 2016In the parentheses provided in questions 8, 11, and 12, write the actual number of transactions tested. If all transactions were tested, indicate such in the “Comments” column. For question 8, at least 40

percent of the number of expenditures tested must be for construction*, and at least 40 percent of the number of expenditures tested must be for purchases made through competitive sealed proposals. If

these 40 percent thresholds cannot be met due to an inadequate population size, the audit firm must test all expenditures made for construction or made through competitive sealed proposals. (*Of the 40

percent for construction, at least one expenditure should be for construction-manager-at-risk, design-build, qualified select bidders list, or job-order-contracting, if applicable. See questions 8.b.8 and 8.c.)

1. Based upon review of 15 expenditures for the procurement of construction, materials, and services that met or exceeded the amount requiring sealed bids, as calculated by the Arizona State Board of Education

in accordance with A.R.S. §15-213, did the District follow the School District Procurement Rules (Arizona Administrative Code R7-2-1001 et seq)?

a. For purchases made through competitive sealed bidding, did the District:

1) Give adequate notice of the invitation for bids? R7-2-1022

2) Compile and maintain a list of prospective bidders? R7-2-1023

3) Issue invitations for bids at least 14 days before the time and date set for bid opening unless a shorter time was determined necessary, and did the invitation for bids include all required information, including purchase specifications? R7-2-1024

4) Stamp sealed bids with the time and date upon receipt and store bids unopened until the time and date set for bid opening? R7-2-1029

5) Award contracts to the lowest responsible and responsive bidder whose bid conformed, in all material respects, to the requirements and evaluation criteria set forth in the invitation for bids? R7-2-1031

b. For purchases made through competitive sealed proposals, did the District:

1) Determine in writing that the use of competitive sealed bids was either not practicable or advantageous to the District based on criteria in R7-2-1041?

2) Include all applicable factors in the request for proposals (RFP)? R7-2-1024(B) and R7-2-1042(A)

3) Give adequate notice of the RFP? R7-2-1042(C)

4) Compile and maintain a list of prospective bidders? R7-2-1023

5) Issue the RFP at least 14 days before the closing date and time for receipt of proposals unless a shorter time was determined necessary? R7-2-1042(B)

6) Stamp sealed proposals with the time and date upon receipt and store proposals unopened until the closing date and time for receipt of proposals? R7-2-1045

7) Award the contract to the offeror whose proposal was determined in writing to be most advantageous to the District based on the factors set forth in the RFP? R7-2-1050

8) If the District used construction-manager-at-risk, design-build, or job-order-contracting to procure construction services, did the District comply with the requirements of Title 41, Chapter 23 (until the Arizona State Board of Education adopts rules for these procurements, after which the District should comply with those rules)?

c. If the District used qualified select bidders list to procure construction services, did the District receive approval from the School Facilities Board?

d. If the District procured goods and information services using electronic, on-line bidding, did the District comply with the requirements of Title 41, Chapter 23, Article 13 and the rules adopted by the Department of Administration in implementing that article (until the Arizona State Board of Education adopts rules for these procurements, after which the District should comply with those rules)?

e. For purchases made through the Simplified School Construction Procurement Program (R7-2-1033), did the District:

1) Ensure that construction costs did not exceed the maximum amount specified in A.R.S. §15-213(A)(2)?

2) Submit solicitations to bid and all other information related to the project to all vendors included in a list maintained by the CSS?

3) Open the bids at a public opening?

4) Keep the bids confidential until the public opening?

5) Encourage competition to the maximum extent possible?

Complete questions 9 and 10 if the District acted as the lead District (i.e., obtained bids/proposals) in a purchasing cooperative.

2. Based upon review of at least two purchases in question 8 for which the District was the lead District in a procurement for a group of districts, did the lead District follow the procurement procedures required for competitive sealed bidding and competitive sealed proposals and take into consideration the estimated volume of purchases for other districts in the group? If at least two lead District purchases were not selected

in question 8, select additional purchases to obtain two and test accordingly.

3. Did the lead District prohibit other Districts (not part of the original invitation/request) from using the bid if the additional purchases would have materially changed the volume in the original invitation/request?

4. Based upon review of 15 purchases costing at least $5,000 but less than $15,000, did the District obtain and document oral price quotations from at least 3 vendors and follow the guidelines governing competitive purchasing below the dollar limits for sealed bids prescribed by the USFR?

5. Based upon review of 15 purchases costing at least $15,000 but less than the amount requiring sealed bids, as calculated by the Arizona State Board of Education in accordance with A.R.S. §15-213, did the District obtain written price quotations from at least 3 vendors and follow the guidelines governing competitive purchasing below the dollar limits for sealed bids prescribed by the USFR?

6. Based on the test work performed in questions 8, 11, and 12, did the District analyze the known requirements for an item or a collection of items that, in the aggregate, would result in the purchase of the item or items from one vendor through the use of oral quotes, written quotes, or formal competitive bids/proposals?

7. Based upon review of all emergency and sole source procurements:

a. Did the District maintain a written statement for each emergency procurement documenting the basis for the emergency, the selection of the particular contractor, and why the price paid was reasonable, and

was such statement signed by the individual authorized to initiate emergency procurements? R7-2-1057

b. Did the District retain written documentation of the Governing Board’s determination that there was only one source for required materials, service, or construction items purchased through sole source

procurement? R7-2-1053

USFR - Chart of Accounts

• New chart of accounts effective July 1, 2015

• Ensure functions properly set up for AFR reporting

• Heads of Component functions

• See definition in USFR

• Charge all direct expenses to function, i.e. purchased services, capital, travel, etc.

• No expectation to allocate indirect expenses to function, i.e. shared printer, supplies from general supply closet, etc.

USFR - Chart of Accounts

• New chart of accounts effective July 1, 2016

• Elimination of USFR Memo 185 – incorporated into COA

• Object Code 6610 – expanded to include construction supplies

• Object Code 6643 now includes a detailed listing of instructional aids• Textbook is an item adopted by the Governing Board as part of instructional program

• 6731-6739 – equipment listing modified and determination of capital item must meet all 3 questions if not listed

• Grants identify items of less than $5,000 as supply. USFR does not have a dollar threshold

USFR - Chart of Accounts

• July 1, 2016 continued

• Overall layout changed to include • Function guidance

• Bold/italics still referenced – unbolded non-italics means there is not enough detail to use that code

• Transfer options easier to identify with statute reference

USFR - Chart of Accounts

• July 1, 2016 continued

• Deleted program 300

• Bolded object codes 6532 and 6629

• Added function 2700 as allowable with object codes 6431, 6521/6522

• Added function 2340 to object code 6532

• Insurance proceeds can now be used for property, not just buildings

USFR - Chart of Accounts

• Stipends connected to position not coded to program/function of position

• 011/012/013/020 not coded to program/function of position

• New teacher in service (before school starts/supplemental not part of contract) should be coded to function 2212

• Ticket takers should be coded to bookstore operations – function 3400

• Roof repairs – should be function 2620 object 6430 – not considered capital

• Security at events – should be function 2660

• Copier maintenance – should be function 2600

USFR Compliance Questionnaire –Expenditures & Procurement #9

Does your District periodically compare invoices to awarded contracts to verify billing amounts are correct and the contract terms and conditions were being met? R7-2-1191(D)

HOPEFULLY, YES!

USFR - Procurement

Is the District required to follow procurement rules for the purchase of high school textbooks?

YES! The exemption only

applies to common school textbooks as defined in

ARS 15-721(G).

USFR - Travel Reimbursements

Has your District kept up with the changes in the travel guidelines and reimbursement rates?

• June 2015• October 2015• March 2016

Check your District’s policies!

USFR Compliance –Student attendance reporting - FTE

To report a 1.0 FTE, ALL three specific requirements must be met pursuant to A.R.S. § 15-901:

1. AT LEAST 4 courses;

2. EACH of which must meet for AT LEAST 123 hours; AND

3. AT LEAST 720 total instructional hours.

If ALL three requirements are not met, the student may not be reported as a 1.0 FTE.

USFR Compliance –Student attendance reporting - AOI

Main changes in FY15 USFRCQ were two questions added to AOI section

• Intended Full Time Equivalency Enrollment Statement

• District should re-determine FTE for each student enrolled in AOI program

Guidance in ADE’s Policies &

Procedures Manual SF-0003

USFR Compliance –Student attendance reporting - AOI• Attendance should be reported by minutes attended instead of absences

(daily logs kept).

• Instructional minutes can occur any day at any time from July 1st –June 30th

• Calculated ADM for an AOI school cannot exceed 1.0

• ADM = (Total Instructional Time in the Daily Log and Submitted to SAIS / Required Annual Instructional Time)

• Funded

• 95% of Base Support Level- Full-Time

• 85% of Base Support Level- Part-Time

USFR Compliance –Student attendance reporting - AOI

Required annual instructional hours to be used within the ADM calculation

GRADE RANGE INSTRUCTIONAL HOURS

REQUIRED

REQUIREDMINUTES

KG 346 20,760

1-3 712 42,720

4-6 890 53,400

7-8 1,068 64,080

9-12 900 54,000

USFR Compliance- Transportation• Attention on calculation of eligible students, not just eligibility in

accordance with ARS

• See ADE Policy # SF-0002 issued 7/1/14 regarding calculating eligible students

• Identify and document 25 days in the first 100 days for count

• Count students in morning and afternoon

• Divide results by two

• Add all count days, divide total by number of identified days

Maintain documentation for above and for the miles reported on the TRAN 55-1 for audit purposes

USFR Compliance –Records Management

CONSIDERATIONS

• Does your District have an individual responsible for this area?

• Compliance involves retention and disposition

• Electronic records• Guidance https://www.azlibrary.gov/sites/azlibrary.gov/files/arm-recordkeeping-

design.pdf

USFR Compliance – Conflict of Interest

PolicyFrequency of

communications to disclose

File maintained

Communication made to necessary departments and

individuals

Uniform Guidance requires