Is a district required to perform due diligence related to purchases made through a cooperative?
Yes. School districts are responsible for ensuring that procurements, whether done independently or through a cooperative purchasing agreement, are done in accordance with School District Procurement Rules. The appropriate amount and complexity of due diligence to be performed by a district will vary based on the procuring entity with which the district is participating. A.R.S. 15-213(F) requires school districts and school purchasing cooperatives, in connection with any audit conducted by a certified public accountant, to have a systematic review of purchasing practices. Our Office has prescribed guidelines for performing these reviews as part of the USFR Compliance Questionnaire (for school districts) and the Procurement Compliance Questionnaire (for cooperatives). A cooperative or lead district that has had such a review within the past year may not warrant the same amount or complexity of due diligence as an entity that has not undergone a review. Further, an entity that had no fin
