2023-008 – Procurement, Above Simple Acquisition (Significant Deficiency in Internal Controls over Compliance)
Recommendation: We recommend the College strengthen controls to ensure purchasing policies and procedures are being followed and train staff in the purchasing department to comply with all...
2023-008 – Procurement, Above Simple Acquisition (Significant Deficiency in Internal Controls over Compliance)
Recommendation: We recommend the College strengthen controls to ensure purchasing policies and procedures are being followed and train staff in the purchasing department to comply with all relevant federal procurement requirements.
Action Taken: The 2022-2023 fiscal year was entirely encompassed by the separation Memorandum of Understanding (MOU) of March 2022 and then the final release settlement in December 2023.
It is important to note that Southeast New Mexico College was a newly established independent community college, having formally separated from New Mexico State University (NMSU) as of April 2022. During this transition period, many administrative processes, including federal grant compliance procedures, were in the process of being developed, transitioned, and implemented independently from NMSU systems. As a result, certain policies, procedures, and documentation processes were not yet fully established or operational at the time of the audit.
During the audit period, the College operated under procurement policies and procedures inherited from New Mexico State University (NMSU), as the College had recently separated from NMSU. The procedures were followed in good faith. Two College employees successfully completed Certified Procurement Officer (CPO) training in July 2021 and were recertified in March 2024. Another employee became certified in February 2024, and the College is having two additional employees participate in fiscal year 2025. This training demonstrates the College’s commitment to compliance and proper procurement practices.
Unfortunately, due to the untimely receipt of the completed audit report, the College did not have the opportunity to review and begin addressing several of the findings until well after the end of the audit period. While the College is committed to corrective action, the delayed delivery of the audit limited the ability to implement corrective measures earlier. The College is working proactively to ensure that these issues are resolved going forward.
Corrective Action Taken / Planned:
• Policy and Procedure Revision
o The institution will revise its procurement policies and procedures to explicitly address purchases exceeding the Simplified Acquisition Threshold, incorporating:
Public solicitation and competitive bidding requirements
Cost or price analysis requirements per 2 CFR §200.324
Documentation of bid evaluations, vendor selection, and contract award
Use of federally compliant contract clauses (per 200.327 and Appendix II).
• Training
o Procurement, finance, and grant management staff will be trained on updated procedures, including:
Competitive procurement processes
Cost/price analysis methods
Documentation requirements
• Procurement Checklist:
o A standardized procurement checklist will be developed and required for all procurements above the Simplified Acquisition Threshold to ensure all federal steps are documented and reviewed.
• Pre-Award Review Process
o For all purchases above the Simplified Acquisition Threshold, the institution will implement a review and approval process involving procurement leadership and the grants compliance office before contract award.
• Monitoring:
o Annual internal monitoring will be conducted by the Procurement Office or Grants Compliance Office to ensure ongoing compliance with federal procurement requirements.
Due Date of Completion: August 31, 2025
Responsible Official: Carolyn Kasdorf, Vice President for Business and Finance (or appropriate official), Karla Volpi, Dean of Business and Finance, Rebecca Silva, Director of Finance, Lisa Ryan, Restricted Funds Manager