Audit 25951

Finding 2022-001 ? Significant Deficiency - Procurement Federal Assistance Listing No. 84.425F, 84.425M U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 6 expenditures, we noted 2 expenditures for which the University did not retain documentation of price or rate quotations obtained from an adequate number of qualified sources prior to the purchase or the rationale for limiting competition if such price or rate comparisons were not considered necessary. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: 2 individual expenditures ranging in amounts of $57,312 and $90,000 were purchased under the federal grant without obtaining quotes, using a competitive bid process or documenting the rationale for limiting competition. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included in their response included with this report. Completion Date: February 1, 2023 Contact Person: Robert Walla ? Procurement Director

Finding 2022-001 ? Significant Deficiency - Procurement Federal Assistance Listing No. 84.425F, 84.425M U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 6 expenditures, we noted 2 expenditures for which the University did not retain documentation of price or rate quotations obtained from an adequate number of qualified sources prior to the purchase or the rationale for limiting competition if such price or rate comparisons were not considered necessary. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: 2 individual expenditures ranging in amounts of $57,312 and $90,000 were purchased under the federal grant without obtaining quotes, using a competitive bid process or documenting the rationale for limiting competition. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included in their response included with this report. Completion Date: February 1, 2023 Contact Person: Robert Walla ? Procurement Director

Finding 2022-001 ? Significant Deficiency - Procurement Federal Assistance Listing No. 84.425F, 84.425M U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 6 expenditures, we noted 2 expenditures for which the University did not retain documentation of price or rate quotations obtained from an adequate number of qualified sources prior to the purchase or the rationale for limiting competition if such price or rate comparisons were not considered necessary. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: 2 individual expenditures ranging in amounts of $57,312 and $90,000 were purchased under the federal grant without obtaining quotes, using a competitive bid process or documenting the rationale for limiting competition. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included in their response included with this report. Completion Date: February 1, 2023 Contact Person: Robert Walla ? Procurement Director

Finding 2022-001 ? Significant Deficiency - Procurement Federal Assistance Listing No. 84.425F, 84.425M U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 6 expenditures, we noted 2 expenditures for which the University did not retain documentation of price or rate quotations obtained from an adequate number of qualified sources prior to the purchase or the rationale for limiting competition if such price or rate comparisons were not considered necessary. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: 2 individual expenditures ranging in amounts of $57,312 and $90,000 were purchased under the federal grant without obtaining quotes, using a competitive bid process or documenting the rationale for limiting competition. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included in their response included with this report. Completion Date: February 1, 2023 Contact Person: Robert Walla ? Procurement Director