2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.
2022-007 Failure to Comply with Equipment and Real Property Management Guidelines Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 Criteria: The terms of the program and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires a ?physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and ?property records must be maintained that include a description of the property, a serial number, the source of funding for the property (including the FAIN), who holds the title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, ...? Condition: The College has a list of capital assets, but it does not include all the requirements as noted above. Furthermore, the College has not completed an inventory of capital assets since 2019. Effect of Condition: The College?s system of internal control did not identify the issues noted above and as a result the College did not comply with the requirements. Cause: A lack of oversight by personnel over the federal program led to noncompliance with the requirement of the Uniform Guidance pertaining to the inventory of the fixed assets and the requirements of the asset listing. Questioned Costs: None Recommendation: Finance and management should be familiar with all aspects of the Equipment and Real Property Management guidelines and ensure that the College follows policies in place that meet the requirements of the Uniform Guidance. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to perform a capital asset inventory and update the capital asset listing that meets all the requirements.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.
2022-007 Failure to Comply with Equipment and Real Property Management Guidelines Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 Criteria: The terms of the program and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires a ?physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and ?property records must be maintained that include a description of the property, a serial number, the source of funding for the property (including the FAIN), who holds the title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, ...? Condition: The College has a list of capital assets, but it does not include all the requirements as noted above. Furthermore, the College has not completed an inventory of capital assets since 2019. Effect of Condition: The College?s system of internal control did not identify the issues noted above and as a result the College did not comply with the requirements. Cause: A lack of oversight by personnel over the federal program led to noncompliance with the requirement of the Uniform Guidance pertaining to the inventory of the fixed assets and the requirements of the asset listing. Questioned Costs: None Recommendation: Finance and management should be familiar with all aspects of the Equipment and Real Property Management guidelines and ensure that the College follows policies in place that meet the requirements of the Uniform Guidance. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to perform a capital asset inventory and update the capital asset listing that meets all the requirements.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.
2022-007 Failure to Comply with Equipment and Real Property Management Guidelines Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 Criteria: The terms of the program and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires a ?physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and ?property records must be maintained that include a description of the property, a serial number, the source of funding for the property (including the FAIN), who holds the title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, ...? Condition: The College has a list of capital assets, but it does not include all the requirements as noted above. Furthermore, the College has not completed an inventory of capital assets since 2019. Effect of Condition: The College?s system of internal control did not identify the issues noted above and as a result the College did not comply with the requirements. Cause: A lack of oversight by personnel over the federal program led to noncompliance with the requirement of the Uniform Guidance pertaining to the inventory of the fixed assets and the requirements of the asset listing. Questioned Costs: None Recommendation: Finance and management should be familiar with all aspects of the Equipment and Real Property Management guidelines and ensure that the College follows policies in place that meet the requirements of the Uniform Guidance. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to perform a capital asset inventory and update the capital asset listing that meets all the requirements.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.
2022-007 Failure to Comply with Equipment and Real Property Management Guidelines Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 Criteria: The terms of the program and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires a ?physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and ?property records must be maintained that include a description of the property, a serial number, the source of funding for the property (including the FAIN), who holds the title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, ...? Condition: The College has a list of capital assets, but it does not include all the requirements as noted above. Furthermore, the College has not completed an inventory of capital assets since 2019. Effect of Condition: The College?s system of internal control did not identify the issues noted above and as a result the College did not comply with the requirements. Cause: A lack of oversight by personnel over the federal program led to noncompliance with the requirement of the Uniform Guidance pertaining to the inventory of the fixed assets and the requirements of the asset listing. Questioned Costs: None Recommendation: Finance and management should be familiar with all aspects of the Equipment and Real Property Management guidelines and ensure that the College follows policies in place that meet the requirements of the Uniform Guidance. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to perform a capital asset inventory and update the capital asset listing that meets all the requirements.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.
2022-007 Failure to Comply with Equipment and Real Property Management Guidelines Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 Criteria: The terms of the program and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires a ?physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and ?property records must be maintained that include a description of the property, a serial number, the source of funding for the property (including the FAIN), who holds the title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, ...? Condition: The College has a list of capital assets, but it does not include all the requirements as noted above. Furthermore, the College has not completed an inventory of capital assets since 2019. Effect of Condition: The College?s system of internal control did not identify the issues noted above and as a result the College did not comply with the requirements. Cause: A lack of oversight by personnel over the federal program led to noncompliance with the requirement of the Uniform Guidance pertaining to the inventory of the fixed assets and the requirements of the asset listing. Questioned Costs: None Recommendation: Finance and management should be familiar with all aspects of the Equipment and Real Property Management guidelines and ensure that the College follows policies in place that meet the requirements of the Uniform Guidance. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to perform a capital asset inventory and update the capital asset listing that meets all the requirements.
2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.
2022-006 Failure to Comply with Suspension and Debarment Requirements Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: Internal controls should be in place to ensure that every contract includes any clauses required by Federal statutes and executive orders and their implementing regulations. The Uniform Guidance states that non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Condition and Context: During our testing of procurement, suspension, and debarment for covered transactions, we noted the College could not provide documentation for the requirement regarding testing of certain vendors for inclusion on the federal suspended or debarred list. For the current year, the College entered into one (1) covered transaction totaling $74,455 for HEERF and entered into five (5) covered transactions for $613,437. Cause: The College failed to test/document the vendor prior to awarding the contract; however, during our testing of all covered transactions, there were no parties noted on the excluded parties listing. Effects: Not performing a verification check for covered transactions, by checking the Excluded Parties List System (EPLS), collecting a certification from the vendor, or adding a clause or condition to the covered transaction with the vendor could result in federal funds being used to pay a vendor who has been suspended or debarred. Questioned Costs: None Recommendation: We recommend the College review the Uniform Guidance for the purchasing requirements and take necessary steps in the future to ensure compliance. Auditee?s Response: Pursuant to U.S. Department of Education procurement policy, the College will review the listing of suspended or debarred parties before engaging in contracts that exceed the statutory amounts and the policy will be updated accordingly.
2022-007 Failure to Comply with Equipment and Real Property Management Guidelines Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 Criteria: The terms of the program and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires a ?physical inventory of the property must be taken and the results reconciled with the property records at least once every two years? and ?property records must be maintained that include a description of the property, a serial number, the source of funding for the property (including the FAIN), who holds the title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, ...? Condition: The College has a list of capital assets, but it does not include all the requirements as noted above. Furthermore, the College has not completed an inventory of capital assets since 2019. Effect of Condition: The College?s system of internal control did not identify the issues noted above and as a result the College did not comply with the requirements. Cause: A lack of oversight by personnel over the federal program led to noncompliance with the requirement of the Uniform Guidance pertaining to the inventory of the fixed assets and the requirements of the asset listing. Questioned Costs: None Recommendation: Finance and management should be familiar with all aspects of the Equipment and Real Property Management guidelines and ensure that the College follows policies in place that meet the requirements of the Uniform Guidance. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to perform a capital asset inventory and update the capital asset listing that meets all the requirements.