View of Responsible Official
Manhattan College acknowledges finding 2024-001 (Procurement and Suspension and Debarment) presented in the June 30, 2024 single audit report. Although the College provided evidence to the auditors that the vendors noted in the review were not suspended or debarred from...
View of Responsible Official
Manhattan College acknowledges finding 2024-001 (Procurement and Suspension and Debarment) presented in the June 30, 2024 single audit report. Although the College provided evidence to the auditors that the vendors noted in the review were not suspended or debarred from federal programs at the time of the transaction and are currently in good standing, and the finding does not give rise to any questioned costs, we agree that controls and policies should be improved. We have implemented a series of corrective actions, identified below, to address the finding and prevent future recurrence. We are committed to ensuring that all necessary steps are taken and procedures implemented to improve our processes and maintain full compliance moving forward.
Corrective Action Plan:
Immediate Action:
A review of all fiscal 2024 and 2025 non-personnel expenses charged to federal grants will be performed to confirm that none of the vendors utilized are suspended or debarred.
Process Improvement:
The following procedures are in the process of being integrated into the procurement process:
• Upon vendor setup, the College Procurement Team will research that the company is not suspended or debarred from participating in procurement with federal agencies and document performance of the procedure.
• The College’s purchase orders will include, as part of the terms and conditions with the vendor, a phrase that upon acceptance of a purchase order the vendor is certifying that they are not suspended or debarred and require that the vendor disclose to the College if such status changes.
• The College will include in its general contract terms a certification from the contracting party that they are not suspended or debarred upon contract signing and require disclosure if such status changes in the future.
• The Procurement Team will verify that vendors utilized for research and development grants are not suspended or debarred before placing orders.
The grants administration compliance guidelines will be updated to incorporate guidance for principal investigators and other grant personnel in the selection of vendors and other grant partners to evaluate that such are not suspended or debarred.
The Accounting and Reporting Supervisor will confirm that vendors are not suspended or disbarred before invoices are processed for payment against a grant.
Training and Communication:
All College personnel (principal investigators, accounting, procurement, etc.) involved in the execution, implementation, compliance, reporting, management and administration of grants will be trained in the new procurement procedures.
Expected Completion Date:
• Immediate Action: Within sixty (60) days (target date May 31, 2025)
• Procurement Process Improvement: Within ninety (90) days (target date June 30, 2025)
• Grant Guidance Revisions: Within sixty (60) days (target date May 31, 2025)
• Invoice Processing for grants: Immediate
• Training: Within sixty (60) days (target date May 31, 2025)
Responsible Parties:
Controller and Deputy Controller will oversee the corrective action plan and ensure the necessary steps are implemented. The Director of Procurement, Accounting & Reporting Supervisor, and Director of Grants Administration will design and execute the new procedures and training. The Director of Internal Audit will assist in monitoring compliance and assess effectiveness.
Follow-up:
A review will be conducted after 6 months by the College’s internal auditor to independently assess the effectiveness of the corrective actions and ensure the new procedure is functioning as intended. In addition, the Suspension and Debarment Policy will be included in the College’s policy library.