Audit 301190

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the HEERF Program, for payroll and non-payroll expenditures, management did not provide sufficient support to justify the allocation of these costs to the program. Consequently, we were unable to audit the allowability of these costs. Context: For payroll-related expenditures, we selected a non-statistical sample of 6 payroll items representing $26,078, all of which did not have documentation of the justification supporting the allocation. Total payroll expenditures for the program were $110,525. Management estimated the time each departments’ employees spent on allowable COVID-related activities; however, the documentation of the calculation and allocation related to the rationale, basis and final allocations were not provided. For nonpayroll expenditures, we selected a non-statistical sample of 8 items representing $181,428, of which, 5 items representing $97,367 did not have documented justification supporting their allowability. Total nonpayroll expenditures for the program were $367,323. Management did not consistently document the justification supporting the allocation of costs to the program. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures to administer the program were not developed and therefore not all supporting justifications were documented. Effect: Expenditures could be disbursed for unallowable costs. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2022-001. Recommendations: The HEERF Program has ended for the University. We recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to demonstrate compliance with its policies and procedures. Views of responsible officials: For payroll-related expenditures, management reviewed the duties of individuals and estimated the percentage of their time allocable to the program based upon knowledge of office functions, job duties, and additional demands and tasks related to the COVID-19 pandemic. This review and discussions within the management team resulted in the amounts allocated to the HEERF program; the percentage allocations assigned were documented in the calculations used to support the payroll activity recorded during the fiscal year ended June 30, 2023. For non-payroll related expenditures, documented policies were not developed for the HEERF program expenditures and as a result supporting justifications were not consistently documented or maintained. For all expenditures associated with the HEERF program, when documentation was not obtained or maintained, management was basing decisions on all regulations available at the time and decisions made did not violate the intent of the program. The HEERF awards were fully expended as of June 30, 2022 for the Student Portion and as of September 30, 2022 for the Institutional Portion. Should similar programs become available in the future, management will develop, in advance of expending funds, documented policies and procedures to administer the program and will maintain documentation demonstrating compliance with program requirements and related institutional policy and procedure.

Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For one quarterly report, the supporting documentation maintained did not agree to the information included in the report. Additionally, the Annual Report for 2022 was not prepared. Context: For quarterly reporting, we selected a non-statistical sample of two Quarterly Reporting Forms for testing, noting that for one report, discrepancies between the supporting documentation and the information in the report existed in 3 out of 6 lines of data. For annual reporting, management indicated that they did not believe they were required to prepare the Annual Report for 2022 as all program funds were expended prior to December 31, 2022. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, it was necessary to gather information from various sources within the University. However, the turnover of staff resulted in a lack of retention of this information in a manner conducive to easy retrieval, compilation and reconciliation with reported amounts. Effect: The Quarterly Reporting Forms that were completed may contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to submit the Annual Report for 2022. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2022-002. Recommendations: As the HEERF Program has ended for the University, we recommend that if similar programs become available in the future, management should develop well-documented policies and procedures. These should be detailed enough to ensure that essential knowledge and information for report preparation, including information sources, can withstand significant staff turnover. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and the Office of Financial Aid endeavor to follow all applicable reporting regulations and guidance mandated for federally funded grant and contract programs. The HEERF awards were fully expended as of June 30, 2022 for the Student Portion and as of September 30, 2022 for the Institutional Portion. Should similar programs become available in the future, management will develop, in advance of expending funds, documented policies and procedures to administer the program and will maintain documentation demonstrating compliance with program requirements and related institutional policy and procedure.

Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed timely for one entity. Context: The University entered into covered transactions with five entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed timely for one entity. The procurement occurred in September 2022, however, the verification that the entity was not suspended or debarred was not performed until August 2023. We reviewed the subsequent verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform required verification procedures could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and perform the required procurement procedures in a timely manner. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the departments to ensure that the required procedure for verification of Suspension and Debarment is conducted timely. The Office of Sponsored Projects will strengthen its procedures so that verification from SAM is obtained prior to confirming procurement, as is required by existing policy. The Principal Investigator will work collaboratively with the Office of Sponsored Projects to ensure that the documentation is obtained in a timely manner. The Manager for Grants and Contracts will timely check SAM.gov for Suspension and Debarment and will maintain the documentation as required. The Assistant Vice President overseeing the Office of Sponsored Projects will review the documentation and ensure compliance with this requirement.

Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the HEERF Program, for payroll and non-payroll expenditures, management did not provide sufficient support to justify the allocation of these costs to the program. Consequently, we were unable to audit the allowability of these costs. Context: For payroll-related expenditures, we selected a non-statistical sample of 6 payroll items representing $26,078, all of which did not have documentation of the justification supporting the allocation. Total payroll expenditures for the program were $110,525. Management estimated the time each departments’ employees spent on allowable COVID-related activities; however, the documentation of the calculation and allocation related to the rationale, basis and final allocations were not provided. For nonpayroll expenditures, we selected a non-statistical sample of 8 items representing $181,428, of which, 5 items representing $97,367 did not have documented justification supporting their allowability. Total nonpayroll expenditures for the program were $367,323. Management did not consistently document the justification supporting the allocation of costs to the program. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures to administer the program were not developed and therefore not all supporting justifications were documented. Effect: Expenditures could be disbursed for unallowable costs. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2022-001. Recommendations: The HEERF Program has ended for the University. We recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to demonstrate compliance with its policies and procedures. Views of responsible officials: For payroll-related expenditures, management reviewed the duties of individuals and estimated the percentage of their time allocable to the program based upon knowledge of office functions, job duties, and additional demands and tasks related to the COVID-19 pandemic. This review and discussions within the management team resulted in the amounts allocated to the HEERF program; the percentage allocations assigned were documented in the calculations used to support the payroll activity recorded during the fiscal year ended June 30, 2023. For non-payroll related expenditures, documented policies were not developed for the HEERF program expenditures and as a result supporting justifications were not consistently documented or maintained. For all expenditures associated with the HEERF program, when documentation was not obtained or maintained, management was basing decisions on all regulations available at the time and decisions made did not violate the intent of the program. The HEERF awards were fully expended as of June 30, 2022 for the Student Portion and as of September 30, 2022 for the Institutional Portion. Should similar programs become available in the future, management will develop, in advance of expending funds, documented policies and procedures to administer the program and will maintain documentation demonstrating compliance with program requirements and related institutional policy and procedure.

Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For one quarterly report, the supporting documentation maintained did not agree to the information included in the report. Additionally, the Annual Report for 2022 was not prepared. Context: For quarterly reporting, we selected a non-statistical sample of two Quarterly Reporting Forms for testing, noting that for one report, discrepancies between the supporting documentation and the information in the report existed in 3 out of 6 lines of data. For annual reporting, management indicated that they did not believe they were required to prepare the Annual Report for 2022 as all program funds were expended prior to December 31, 2022. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, it was necessary to gather information from various sources within the University. However, the turnover of staff resulted in a lack of retention of this information in a manner conducive to easy retrieval, compilation and reconciliation with reported amounts. Effect: The Quarterly Reporting Forms that were completed may contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to submit the Annual Report for 2022. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2022-002. Recommendations: As the HEERF Program has ended for the University, we recommend that if similar programs become available in the future, management should develop well-documented policies and procedures. These should be detailed enough to ensure that essential knowledge and information for report preparation, including information sources, can withstand significant staff turnover. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and the Office of Financial Aid endeavor to follow all applicable reporting regulations and guidance mandated for federally funded grant and contract programs. The HEERF awards were fully expended as of June 30, 2022 for the Student Portion and as of September 30, 2022 for the Institutional Portion. Should similar programs become available in the future, management will develop, in advance of expending funds, documented policies and procedures to administer the program and will maintain documentation demonstrating compliance with program requirements and related institutional policy and procedure.

Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed timely for one entity. Context: The University entered into covered transactions with five entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed timely for one entity. The procurement occurred in September 2022, however, the verification that the entity was not suspended or debarred was not performed until August 2023. We reviewed the subsequent verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform required verification procedures could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and perform the required procurement procedures in a timely manner. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the departments to ensure that the required procedure for verification of Suspension and Debarment is conducted timely. The Office of Sponsored Projects will strengthen its procedures so that verification from SAM is obtained prior to confirming procurement, as is required by existing policy. The Principal Investigator will work collaboratively with the Office of Sponsored Projects to ensure that the documentation is obtained in a timely manner. The Manager for Grants and Contracts will timely check SAM.gov for Suspension and Debarment and will maintain the documentation as required. The Assistant Vice President overseeing the Office of Sponsored Projects will review the documentation and ensure compliance with this requirement.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the HEERF Program, for payroll and non-payroll expenditures, management did not provide sufficient support to justify the allocation of these costs to the program. Consequently, we were unable to audit the allowability of these costs. Context: For payroll-related expenditures, we selected a non-statistical sample of 6 payroll items representing $26,078, all of which did not have documentation of the justification supporting the allocation. Total payroll expenditures for the program were $110,525. Management estimated the time each departments’ employees spent on allowable COVID-related activities; however, the documentation of the calculation and allocation related to the rationale, basis and final allocations were not provided. For nonpayroll expenditures, we selected a non-statistical sample of 8 items representing $181,428, of which, 5 items representing $97,367 did not have documented justification supporting their allowability. Total nonpayroll expenditures for the program were $367,323. Management did not consistently document the justification supporting the allocation of costs to the program. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures to administer the program were not developed and therefore not all supporting justifications were documented. Effect: Expenditures could be disbursed for unallowable costs. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2022-001. Recommendations: The HEERF Program has ended for the University. We recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to demonstrate compliance with its policies and procedures. Views of responsible officials: For payroll-related expenditures, management reviewed the duties of individuals and estimated the percentage of their time allocable to the program based upon knowledge of office functions, job duties, and additional demands and tasks related to the COVID-19 pandemic. This review and discussions within the management team resulted in the amounts allocated to the HEERF program; the percentage allocations assigned were documented in the calculations used to support the payroll activity recorded during the fiscal year ended June 30, 2023. For non-payroll related expenditures, documented policies were not developed for the HEERF program expenditures and as a result supporting justifications were not consistently documented or maintained. For all expenditures associated with the HEERF program, when documentation was not obtained or maintained, management was basing decisions on all regulations available at the time and decisions made did not violate the intent of the program. The HEERF awards were fully expended as of June 30, 2022 for the Student Portion and as of September 30, 2022 for the Institutional Portion. Should similar programs become available in the future, management will develop, in advance of expending funds, documented policies and procedures to administer the program and will maintain documentation demonstrating compliance with program requirements and related institutional policy and procedure.

Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For one quarterly report, the supporting documentation maintained did not agree to the information included in the report. Additionally, the Annual Report for 2022 was not prepared. Context: For quarterly reporting, we selected a non-statistical sample of two Quarterly Reporting Forms for testing, noting that for one report, discrepancies between the supporting documentation and the information in the report existed in 3 out of 6 lines of data. For annual reporting, management indicated that they did not believe they were required to prepare the Annual Report for 2022 as all program funds were expended prior to December 31, 2022. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, it was necessary to gather information from various sources within the University. However, the turnover of staff resulted in a lack of retention of this information in a manner conducive to easy retrieval, compilation and reconciliation with reported amounts. Effect: The Quarterly Reporting Forms that were completed may contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to submit the Annual Report for 2022. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2022-002. Recommendations: As the HEERF Program has ended for the University, we recommend that if similar programs become available in the future, management should develop well-documented policies and procedures. These should be detailed enough to ensure that essential knowledge and information for report preparation, including information sources, can withstand significant staff turnover. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and the Office of Financial Aid endeavor to follow all applicable reporting regulations and guidance mandated for federally funded grant and contract programs. The HEERF awards were fully expended as of June 30, 2022 for the Student Portion and as of September 30, 2022 for the Institutional Portion. Should similar programs become available in the future, management will develop, in advance of expending funds, documented policies and procedures to administer the program and will maintain documentation demonstrating compliance with program requirements and related institutional policy and procedure.

Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed timely for one entity. Context: The University entered into covered transactions with five entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed timely for one entity. The procurement occurred in September 2022, however, the verification that the entity was not suspended or debarred was not performed until August 2023. We reviewed the subsequent verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform required verification procedures could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and perform the required procurement procedures in a timely manner. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the departments to ensure that the required procedure for verification of Suspension and Debarment is conducted timely. The Office of Sponsored Projects will strengthen its procedures so that verification from SAM is obtained prior to confirming procurement, as is required by existing policy. The Principal Investigator will work collaboratively with the Office of Sponsored Projects to ensure that the documentation is obtained in a timely manner. The Manager for Grants and Contracts will timely check SAM.gov for Suspension and Debarment and will maintain the documentation as required. The Assistant Vice President overseeing the Office of Sponsored Projects will review the documentation and ensure compliance with this requirement.

Criteria: 2 CFR 200.303(a) requires the non-Federal entity to establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: During our testing of the HEERF Program, for payroll and non-payroll expenditures, management did not provide sufficient support to justify the allocation of these costs to the program. Consequently, we were unable to audit the allowability of these costs. Context: For payroll-related expenditures, we selected a non-statistical sample of 6 payroll items representing $26,078, all of which did not have documentation of the justification supporting the allocation. Total payroll expenditures for the program were $110,525. Management estimated the time each departments’ employees spent on allowable COVID-related activities; however, the documentation of the calculation and allocation related to the rationale, basis and final allocations were not provided. For nonpayroll expenditures, we selected a non-statistical sample of 8 items representing $181,428, of which, 5 items representing $97,367 did not have documented justification supporting their allowability. Total nonpayroll expenditures for the program were $367,323. Management did not consistently document the justification supporting the allocation of costs to the program. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, documented policies and procedures to administer the program were not developed and therefore not all supporting justifications were documented. Effect: Expenditures could be disbursed for unallowable costs. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2022-001. Recommendations: The HEERF Program has ended for the University. We recommend that should similar programs become available in the future, that management develop documented policies and procedures to administer the program and that management maintain documentation to demonstrate compliance with its policies and procedures. Views of responsible officials: For payroll-related expenditures, management reviewed the duties of individuals and estimated the percentage of their time allocable to the program based upon knowledge of office functions, job duties, and additional demands and tasks related to the COVID-19 pandemic. This review and discussions within the management team resulted in the amounts allocated to the HEERF program; the percentage allocations assigned were documented in the calculations used to support the payroll activity recorded during the fiscal year ended June 30, 2023. For non-payroll related expenditures, documented policies were not developed for the HEERF program expenditures and as a result supporting justifications were not consistently documented or maintained. For all expenditures associated with the HEERF program, when documentation was not obtained or maintained, management was basing decisions on all regulations available at the time and decisions made did not violate the intent of the program. The HEERF awards were fully expended as of June 30, 2022 for the Student Portion and as of September 30, 2022 for the Institutional Portion. Should similar programs become available in the future, management will develop, in advance of expending funds, documented policies and procedures to administer the program and will maintain documentation demonstrating compliance with program requirements and related institutional policy and procedure.

Criteria: There are three components to reporting for HEERF: 1) public reporting on the (a)(1) Student Aid; 2) public reporting on the (a)(1) Institutional Portion (a)(2) and (a)(3) subprograms (Quarterly Reporting Form), as applicable; and 3) the annual report (Annual Report). The Coronavirus Aid, Relief, and Economic Security (CARES) Act 18004(e) and the Coronavirus Response and Relief Supplemental Appropriations Act (CRRSAA) 314(e) requires an institution receiving funds under HEERF I and HEERF II to submit a report to the secretary, at such time in such a manner as the secretary may require. While American Rescue Plan (ARP) does not explicitly identify procedures by which institutions must report on their uses of HEERF grant funds, ED exercises this reporting authority under 2 CFR section 200.328 and 2 CFR section 200.329. Condition: For one quarterly report, the supporting documentation maintained did not agree to the information included in the report. Additionally, the Annual Report for 2022 was not prepared. Context: For quarterly reporting, we selected a non-statistical sample of two Quarterly Reporting Forms for testing, noting that for one report, discrepancies between the supporting documentation and the information in the report existed in 3 out of 6 lines of data. For annual reporting, management indicated that they did not believe they were required to prepare the Annual Report for 2022 as all program funds were expended prior to December 31, 2022. Cause: Management indicated that due to the urgency in ensuring funds were distributed as quickly as possible, it was necessary to gather information from various sources within the University. However, the turnover of staff resulted in a lack of retention of this information in a manner conducive to easy retrieval, compilation and reconciliation with reported amounts. Effect: The Quarterly Reporting Forms that were completed may contain inaccurate or incomplete data. In addition, the University was not compliant with the requirement to submit the Annual Report for 2022. Questioned Costs: None Identification of a repeat finding: This is a repeat finding of 2022-002. Recommendations: As the HEERF Program has ended for the University, we recommend that if similar programs become available in the future, management should develop well-documented policies and procedures. These should be detailed enough to ensure that essential knowledge and information for report preparation, including information sources, can withstand significant staff turnover. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) and the Office of Financial Aid endeavor to follow all applicable reporting regulations and guidance mandated for federally funded grant and contract programs. The HEERF awards were fully expended as of June 30, 2022 for the Student Portion and as of September 30, 2022 for the Institutional Portion. Should similar programs become available in the future, management will develop, in advance of expending funds, documented policies and procedures to administer the program and will maintain documentation demonstrating compliance with program requirements and related institutional policy and procedure.

Criteria: 2 CFR 180.300 requires the non-Federal entity to verify that a person (defined as any individual, corporation, association, unit of government, or legal entity, however organized) they are entering into a covered transaction with is not suspended or debarred by: (a) checking SAM Exclusions; or (b) collecting a certification from that person; or (c) adding a clause or condition to the covered transaction with that person. Condition: Verification that an entity was not suspended or debarred was not performed timely for one entity. Context: The University entered into covered transactions with five entities during the fiscal year. We selected a non-statistical sample of two entities for testing, noting verification that the entity was not suspended or debarred was not performed timely for one entity. The procurement occurred in September 2022, however, the verification that the entity was not suspended or debarred was not performed until August 2023. We reviewed the subsequent verification and noted the entity did not have any exclusion records, indicating they were not suspended or debarred. Cause: Although the University has established policies and procedures in place over the procurement and suspension and debarment process, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform required verification procedures could result in noncompliance with the procurement and suspension and debarment requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and perform the required procurement procedures in a timely manner. Views of responsible officials: The HPU Office of Sponsored Projects will work collaboratively with the departments to ensure that the required procedure for verification of Suspension and Debarment is conducted timely. The Office of Sponsored Projects will strengthen its procedures so that verification from SAM is obtained prior to confirming procurement, as is required by existing policy. The Principal Investigator will work collaboratively with the Office of Sponsored Projects to ensure that the documentation is obtained in a timely manner. The Manager for Grants and Contracts will timely check SAM.gov for Suspension and Debarment and will maintain the documentation as required. The Assistant Vice President overseeing the Office of Sponsored Projects will review the documentation and ensure compliance with this requirement.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.

Criteria: 2 CFR 200.313(d)(2) requires the non-Federal entity take a physical inventory of property and reconcile the results with the property records at least once every two years. 2 CFR 200.313(d)(1) requires “property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property…” Condition: The University did not complete a full physical inventory as required and did not complete a reconciliation of the results to its property records. Additionally, the University did not have a fixed asset tag on 3 equipment items. Context: The University’s Fixed Asset Policy and related procedures require a periodic inventory of property and equipment. In addition, each equipment item is required to have a unique identifier or a fixed asset tag. The University instructed its departments, via an organization-wide communication dated May 3, 2023, to complete an inventory of their property and equipment by May 31, 2023. We noted that a physical inventory was completed for 12 out of 21 departments during the fiscal year ended June 30, 2023. Additionally, a physical inventory for two departments was completed subsequent to June 30, 2023. We further noted that one equipment item acquired with federal awards was transferred to another university, however, the item was improperly included in the University’s property records as of June 30, 2023. In addition, we also selected a non-statistical sample of 5 equipment items to observe and noted 3 items that did not have a unique identifier and were not properly tagged. Cause: Although the University has policies and procedures in place over the physical inventory of property and fixed asset tagging, there was a lack of diligence in complying with the policies and procedures. Effect: Failure to perform physical inventory of property and reconcile the results with the property records at least once every two years and failure to properly tag equipment items resulted in noncompliance with the equipment and real property management requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University be more diligent in complying with its established policies and procedures for the physical inventory ensuring all departments timely complete the physical inventory and reconcile the results with its property records. The University should also be more diligent in ensuring its equipment items all have unique identifiers or are properly tagged. Views of responsible officials: The HPU Business Office will initiate and ensure the completion and reconciliation of the physical inventory of all fixed assets which were acquired using federal funds at least every two years, to include the tagging of items in accordance with the university’s inventory and fixedasset related policy.

Criteria: 2 CFR 200.320 requires the non-Federal entity to have and use documented procurement procedures that are consistent with the standards outlined in that section. If small purchase procedures are used, 2 CFR 200.320(a)(2) requires price or rate quotations must be obtained from an adequate number of qualified sources. For acquisitions exceeding the simplified acquisition threshold, the non-federal entity must use one of the methods prescribed by 2 CFR 200.320(b) or (c): the sealed bid method; the competitive proposals method; or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c)). The University has adopted a Procurement Policy for Purchases Using Federal Funds that complies with the applicable procurement requirements. If purchases are over the micro-purchase threshold of $10,000, a Vendor Justification Form (VJF) must be completed and documentation maintained to support the selection of a vendor. For procurements above the micro-purchase threshold, the VJF requires a minimum of two bids; three preferred, for competitive purchase/bid procurements or documentation supporting noncompetitive purchase/bid procurements. Condition: Procurement documentation for one vendor was not prepared, failing to support compliance with the regulations above and the University’s procurement policy. Context: We selected a non-statistical sample of three procurements out of a population of fourteen vendors with total expenditures exceeding the micro-purchase threshold during the fiscal year. For one selection, the University’s VJF documenting and approving the small purchase procurement was not prepared. Cause: Despite having established procurement policies and procedures, there was a misunderstanding regarding their application in this particular instance. Management believed that having the vendor explicitly specified in the approved grant application exempted the University from following its procurement policy. Effect: Failure to properly perform the procedures required under the procurement process resulted in noncompliance with the procurement requirement. Questioned Costs: None Identification of a repeat finding: N/A. Recommendations: We recommend the University follow their procurement policies and procedures for purchases using federal funds and maintain evidence that the required procurement procedures were completed. Views of responsible officials: The HPU Office of Sponsored Projects (OSP) will strengthen its internal control to ensure that the procurement policy for purchases using federal funds is followed and that the documents required for procurement are completed and maintained, including in circumstances where the vendor was explicitly identified in an approved grant application. The Vendor Justification Form will be enforced for all purchases meeting the specific threshold amount when procuring using federal funds.