Finding 2024-001: Procurement, Suspension and Debarment
Corrective Action:
Management agrees with the finding.
In fiscal year 2024 the Laboratory charged a federal sponsored award for a procurement
item, which exceeded the Laboratory’s micro-purchase threshold, without maintaining
the proper documen...
Finding 2024-001: Procurement, Suspension and Debarment
Corrective Action:
Management agrees with the finding.
In fiscal year 2024 the Laboratory charged a federal sponsored award for a procurement
item, which exceeded the Laboratory’s micro-purchase threshold, without maintaining
the proper documentation as required by Laboratory procurement policy. In fiscal 2025
this item was identified by the Laboratory’s Internal Audit and Sponsored Programs
Accounting Offices as part of their routine review program. The transaction cost was
removed by Laboratory Management from the federal award within 90 days of the item's
discovery; however, because the item was identified and adjusted in 2025, the fiscal year
2024 Schedule of Expenditures of Federal Awards (SEFA) was overstated.
To ensure compliance with the Laboratory’s procurement policies the Laboratory has
implemented and/or will implement certain corrective actions as detailed below, in line
with the recommendation:
Corrective Actions Previously Implemented:
1. The Laboratory’s Internal Audit and Sponsored Program Accounting Offices will
continue to conduct regular reviews of procurement items to ensure that
documentation complies with Laboratory Procurement Methods Policy and
Procedure, to ensure compliance with Laboratory policy, designed to ensure
compliance with 2 CFR Sections 200.317 through 200.327. The audit focus will
continue to be on 100% of sponsored award procurement transactions in the small
purchase threshold.
2. The Laboratory Information Technology department, in collaboration with the
Laboratory’s Procurement Office Director, enhanced certain systemgenerated
reporting to allow for easier identification by Procurement Office
personnel of charges to sponsored awards.
Corrective Actions to be Implemented:
1. The Laboratory’s Sponsored Programs Accounting Office, in collaboration with
its Procurement Office, will provide an annual re-education to Laboratory
administrative research personnel concerning Laboratory Procurement Policies,
designed to ensure compliance with 2 CFR Sections 200.317 through 200.327.
2. The Sponsored Programs Accounting Office will provide re-training
for administrative staff to reinforce the Laboratory Procurement Method Policies
and Procedure.
3. The Director of Procurement will streamline access and visibility of the
Procurement Methods Policy and Procedure on the Laboratory’s internal website.
Management intends for the re-education of administrative research personnel and retraining
for administrative staff to be concluded by the end of the third quarter and/or
early fourth quarter of 2025. Management intends to provide for streamlined access
and visibility of Laboratory Procurement Methods Policy and Procedure on its
internal website prior to the end of 2025.
Names of contact person(s) responsible for corrective action:
Gerard Langlais, Corporate Controller