Criteria or Specific Requirement: The UG subsections 200.317 through 200.326 address procurement standards within the Uniform Guidance. These standards require certain elements to be included in a written procurement policy. Condition: During our testing, we noted certain elements of the College?s procurement policy did not specifically address all requirements in CRF subsections 200.317 through 200.326. Required elements not included were: ? UG ?200.318, item (d): The non-Federal entity's procedures must avoid acquisition of unnecessary or duplicative items. ? UG ?200.321 Contracting with small and minority businesses, women's business enterprises, and labor surplus area firms, item (a): The non-Federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. Questioned Costs: None Context: During testing, it was noted the College?s procurement policy did not include all required elements under federal regulations. Cause: The College did not ensure its procurement policies were up to date with federal regulations. This was reported to the College in the prior year, but was not brought to the College?s attention until after the fiscal year. Effect: The College was not in compliance with procurement regulations. Repeat Finding: Yes, see 2021-002 Recommendation: We recommend the College review its existing written procurement policies to ensure the written policies are in compliance with federal regulations. Views of Responsible Officials: Management agrees with finding.
Criteria or Specific Requirement: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: We sampled five covered transactions that lacked documentation supporting that the vendor was not suspended or debarred. Questioned Costs: None Context: Of the five covered transactions tested, all lacked documentation supporting that the College verified the vendor was not suspended or debarred prior to entering into the covered transactions. Cause: Management did not retain evidence demonstrating they verified the vendors were not suspended or debarred prior to entering into the covered transaction. Similar instances of noncompliance were reported in the prior year audit, but was not brought to the College?s attention until after the fiscal year. Effect: By not retaining evidence that Management verified vendors were not suspended or debarred, management may erroneously enter into a covered transaction with vendors that were suspended or debarred. Repeat Finding: Yes, see 2021-003 Recommendation: We recommend Management adopt a policy to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the GSA website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. Views of responsible officials: Management agrees with finding.
Criteria or Specific Requirement: Reasonable direct administrative costs and indirect costs at an institution?s approved negotiated indirect cost rate may be charged against Assistance Listing 84.425F (the Institutional portion). All such costs must be reasonable and necessary and conform to Cost Principles described in 2 CFR Part 200 Subpart E of the Uniform Guidance. Further, in accordance with the College?s cognizant agency approved indirect cost rate, the approved rate should be applied to its Modified Total Direct Costs (MTDC) base. This MTDC base should exclude equipment, capital expenditures, among other things. Condition: During our testing, we noted certain costs that were charged as supplies when they should have been recognized as capital assets/ equipment purchases. As a result, the indirect costs were calculated incorrectly by including these costs in the MTDC base. The MTDC should have excluded equipment and capital expenditures. As a result, $298,372 of indirect costs were incorrectly calculated and charged to the award. Questioned Costs: $298,372 Context: During testing, it was noted the College did not follow the proper steps and the College?s capital asset policy. Thus, these costs were expenses as supplies rather than as capital items. Cause: The College did not appropriately record expenditures in accordance with its capital asset policy and therefore erroneously calculated its indirect costs that were charged to the grant. Effect: The College had questioned costs of $298,372. Repeat Finding: No Recommendation: We recommend the College review its existing policies around calculating its MTDC and recording capital expenditures to ensure it is in compliance with federal regulations. Views of responsible officials: Management agrees with finding.
Criteria or Specific Requirement: The UG subsections 200.317 through 200.326 address procurement standards within the Uniform Guidance. These standards require certain elements to be included in a written procurement policy. Condition: During our testing, we noted certain elements of the College?s procurement policy did not specifically address all requirements in CRF subsections 200.317 through 200.326. Required elements not included were: ? UG ?200.318, item (d): The non-Federal entity's procedures must avoid acquisition of unnecessary or duplicative items. ? UG ?200.321 Contracting with small and minority businesses, women's business enterprises, and labor surplus area firms, item (a): The non-Federal entity must take all necessary affirmative steps to assure that minority businesses, women's business enterprises, and labor surplus area firms are used when possible. Questioned Costs: None Context: During testing, it was noted the College?s procurement policy did not include all required elements under federal regulations. Cause: The College did not ensure its procurement policies were up to date with federal regulations. This was reported to the College in the prior year, but was not brought to the College?s attention until after the fiscal year. Effect: The College was not in compliance with procurement regulations. Repeat Finding: Yes, see 2021-002 Recommendation: We recommend the College review its existing written procurement policies to ensure the written policies are in compliance with federal regulations. Views of Responsible Officials: Management agrees with finding.
Criteria or Specific Requirement: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at https://www.beta.sam.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: We sampled five covered transactions that lacked documentation supporting that the vendor was not suspended or debarred. Questioned Costs: None Context: Of the five covered transactions tested, all lacked documentation supporting that the College verified the vendor was not suspended or debarred prior to entering into the covered transactions. Cause: Management did not retain evidence demonstrating they verified the vendors were not suspended or debarred prior to entering into the covered transaction. Similar instances of noncompliance were reported in the prior year audit, but was not brought to the College?s attention until after the fiscal year. Effect: By not retaining evidence that Management verified vendors were not suspended or debarred, management may erroneously enter into a covered transaction with vendors that were suspended or debarred. Repeat Finding: Yes, see 2021-003 Recommendation: We recommend Management adopt a policy to ensure evidence of compliance to suspension and debarment regulations are maintained. This can include maintaining evidence that management reviewed the GSA website, maintaining a certification from the vendor, or including a clause in a contract with vendors that they are not suspended or debarred. Views of responsible officials: Management agrees with finding.
Criteria or Specific Requirement: Reasonable direct administrative costs and indirect costs at an institution?s approved negotiated indirect cost rate may be charged against Assistance Listing 84.425F (the Institutional portion). All such costs must be reasonable and necessary and conform to Cost Principles described in 2 CFR Part 200 Subpart E of the Uniform Guidance. Further, in accordance with the College?s cognizant agency approved indirect cost rate, the approved rate should be applied to its Modified Total Direct Costs (MTDC) base. This MTDC base should exclude equipment, capital expenditures, among other things. Condition: During our testing, we noted certain costs that were charged as supplies when they should have been recognized as capital assets/ equipment purchases. As a result, the indirect costs were calculated incorrectly by including these costs in the MTDC base. The MTDC should have excluded equipment and capital expenditures. As a result, $298,372 of indirect costs were incorrectly calculated and charged to the award. Questioned Costs: $298,372 Context: During testing, it was noted the College did not follow the proper steps and the College?s capital asset policy. Thus, these costs were expenses as supplies rather than as capital items. Cause: The College did not appropriately record expenditures in accordance with its capital asset policy and therefore erroneously calculated its indirect costs that were charged to the grant. Effect: The College had questioned costs of $298,372. Repeat Finding: No Recommendation: We recommend the College review its existing policies around calculating its MTDC and recording capital expenditures to ensure it is in compliance with federal regulations. Views of responsible officials: Management agrees with finding.