Audit 5428

Federal Assistance Number - #93.493 Congressional Directives; Award Year: 8/1/2022 - 7/31/2023; Federal Identification Number: 6 GE1HS46227-01 Criteria or Specific Requirement - Procurement In accordance with 2 CFR Section 180.220, 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. Condition - Suspension and debarment checks were not formally documented for all vendors that received federal funds. Questioned Costs - None noted. Context - Two of eight vendors subject to debarment and suspension requirements in 2023 were selected for testing. The University purchased approximately $157,000 in goods from these two vendors during the fiscal year ended 2023. During our testing, it was noted the University performed the review of suspension and debarment status prior to purchase, but did not retain documentation. The University provided the formal documentation for suspension and debarment check subsequent to purchase and verified that the vendors were not suspended or disbarred. The sample was not intended to be, and was not, a statistically valid sample. Effect - Federal funds could be paid to entities that are suspended or debarred. Cause - The University’s controls to ensure suspension and debarment checks were documented on vendors receiving federal funds did not operate effectively. Identification as a Repeat Finding, if applicable - Not a repeat finding. Recommendation - Policies and procedures should be modified to ensure that suspension and debarment checks are performed with supporting documentation maintained on vendors prior to making purchases with federal funds. View of Responsible Official and Planned Corrective Actions - KCU will meet the requirements in accordance with 2 CFR Section 180.220 by documenting the review of debarment and suspension of vendors receiving Federal funds while onboarding new vendors and periodically monitoring throughout the year.

Federal Assistance Number - #93.493 Congressional Directives; Award Year: 8/1/2022 - 7/31/2023; Federal Identification Number: 6 GE1HS46227-01 Criteria or Specific Requirement - Procurement In accordance with 2 CFR Section 180.220, 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. Condition - Suspension and debarment checks were not formally documented for all vendors that received federal funds. Questioned Costs - None noted. Context - Two of eight vendors subject to debarment and suspension requirements in 2023 were selected for testing. The University purchased approximately $157,000 in goods from these two vendors during the fiscal year ended 2023. During our testing, it was noted the University performed the review of suspension and debarment status prior to purchase, but did not retain documentation. The University provided the formal documentation for suspension and debarment check subsequent to purchase and verified that the vendors were not suspended or disbarred. The sample was not intended to be, and was not, a statistically valid sample. Effect - Federal funds could be paid to entities that are suspended or debarred. Cause - The University’s controls to ensure suspension and debarment checks were documented on vendors receiving federal funds did not operate effectively. Identification as a Repeat Finding, if applicable - Not a repeat finding. Recommendation - Policies and procedures should be modified to ensure that suspension and debarment checks are performed with supporting documentation maintained on vendors prior to making purchases with federal funds. View of Responsible Official and Planned Corrective Actions - KCU will meet the requirements in accordance with 2 CFR Section 180.220 by documenting the review of debarment and suspension of vendors receiving Federal funds while onboarding new vendors and periodically monitoring throughout the year.