Audit 395352

Federal Program: Higher Education Institutional Aid (Title III) Assistance Listing Number: 84.031 Compliance Requirement: Procurement, Suspension and Debarment Criteria: Per 2 CFR § 180.220 and 2 CFR § 200.318, non-federal entities are required to have written procurement policies and procedures governing the acquisition of goods and services funded by federal awards. Furthermore, a non-federal entity is prohibited from contracting with or making subawards to parties that are suspended or debarred. Recipients must verify that the entity is not excluded or disqualified by checking the System for Award Management (SAM.gov), collecting a certification from the entity, or adding a clause or condition to the contract. Condition: During our test of 51 procurement transactions, we noted that for 12 contracts (exceeding the $25,000 threshold), the College could not provide documentation that a suspension and debarment check had been performed via SAM.gov prior to the award. Additionally, the contracts did not include a provision requiring the contractor to certify their eligibility. Cause: Management had not implemented a formal, documented process requiring staff to perform and retain evidence of SAM.gov checks for all covered transactions. Staff involved in the procurement process were unaware of the specific documentation requirements under the Uniform Guidance. Effect: The College entered into contracts with vendors without verifying their eligibility to receive federal funds. While our subsequent search of SAM.gov revealed that the vendors involved were not actually suspended or debarred, the College was in violation of federal compliance requirements. Questioned Costs: None (since the vendors were not actually excluded). Recommendation: Management should draft and adopt a formal procurement manual. For every federally funded purchase exceeding the micro-purchase threshold, staff must print and file a SAM.gov "Exclusion Search" result prior to executing the contract. Views of Responsible Officials: Management agrees with the finding. We are currently implementing a new procurement checklist that requires a printed copy of the SAM.gov search result to be attached to the purchase order packet. Staff training on federal procurement requirements will be required.