Audit 37636

Condition: The University is not in compliance with procurement standards under the Uniform Guidance as follows: ? Thresholds for micro-purchases (not to exceed $10,000), small purchases (not to exceed $250,000) and simplified acquisition were not included in the University?s documented procurement procedures ? The University does not have a written standard of conduct that bars any employee or officer from participating in the selection, award, or administration of a contract supported by a federal award if the employee or officer has a direct or indirect financial or other interest in or a tangible personal benefit from a firm considered for a contract ? There is no documentation that vendors were checked against the suspended and debarred vendor list Criteria: The University is required to be in compliance with procurement standards. Cause: Procurement standards were adopted during the current fiscal year but the grant expenditures tested occurred prior to implementation Effect: The University is not in compliance with procurement standards. Recommendation: Ensure that the University is in compliance with all Uniform Guidance standards related to this grant. Views of Responsible Officials and Planned Corrective Actions: Cumberland University has adopted Federal Procurement Guidelines for all qualifying Federal Grants going forward.

Condition: The University is not in compliance with procurement standards under the Uniform Guidance as follows: ? Thresholds for micro-purchases (not to exceed $10,000), small purchases (not to exceed $250,000) and simplified acquisition were not included in the University?s documented procurement procedures ? The University does not have a written standard of conduct that bars any employee or officer from participating in the selection, award, or administration of a contract supported by a federal award if the employee or officer has a direct or indirect financial or other interest in or a tangible personal benefit from a firm considered for a contract ? There is no documentation that vendors were checked against the suspended and debarred vendor list Criteria: The University is required to be in compliance with procurement standards. Cause: Procurement standards were adopted during the current fiscal year but the grant expenditures tested occurred prior to implementation Effect: The University is not in compliance with procurement standards. Recommendation: Ensure that the University is in compliance with all Uniform Guidance standards related to this grant. Views of Responsible Officials and Planned Corrective Actions: Cumberland University has adopted Federal Procurement Guidelines for all qualifying Federal Grants going forward.

Condition: The University is not in compliance with procurement standards under the Uniform Guidance as follows: ? Thresholds for micro-purchases (not to exceed $10,000), small purchases (not to exceed $250,000) and simplified acquisition were not included in the University?s documented procurement procedures ? The University does not have a written standard of conduct that bars any employee or officer from participating in the selection, award, or administration of a contract supported by a federal award if the employee or officer has a direct or indirect financial or other interest in or a tangible personal benefit from a firm considered for a contract ? There is no documentation that vendors were checked against the suspended and debarred vendor list Criteria: The University is required to be in compliance with procurement standards. Cause: Procurement standards were adopted during the current fiscal year but the grant expenditures tested occurred prior to implementation Effect: The University is not in compliance with procurement standards. Recommendation: Ensure that the University is in compliance with all Uniform Guidance standards related to this grant. Views of Responsible Officials and Planned Corrective Actions: Cumberland University has adopted Federal Procurement Guidelines for all qualifying Federal Grants going forward.

Condition: The University is not in compliance with procurement standards under the Uniform Guidance as follows: ? Thresholds for micro-purchases (not to exceed $10,000), small purchases (not to exceed $250,000) and simplified acquisition were not included in the University?s documented procurement procedures ? The University does not have a written standard of conduct that bars any employee or officer from participating in the selection, award, or administration of a contract supported by a federal award if the employee or officer has a direct or indirect financial or other interest in or a tangible personal benefit from a firm considered for a contract ? There is no documentation that vendors were checked against the suspended and debarred vendor list Criteria: The University is required to be in compliance with procurement standards. Cause: Procurement standards were adopted during the current fiscal year but the grant expenditures tested occurred prior to implementation Effect: The University is not in compliance with procurement standards. Recommendation: Ensure that the University is in compliance with all Uniform Guidance standards related to this grant. Views of Responsible Officials and Planned Corrective Actions: Cumberland University has adopted Federal Procurement Guidelines for all qualifying Federal Grants going forward.