The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324 (a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. Dur...
The University acknowledges the audit finding and is committed to ensuring compliance with the procurement requirements outlined in 2 CFR 200.324 (a), which mandates that recipients perform a cost or price analysis for every procurement transaction exceeding the simplified acquisition threshold. During the audit period, it was identified that 4 sampled transactions exceeding the University’s simplified acquisition threshold of $50,000 lacked documented evidence of an independent cost or price analysis prior to March 31, 2025. In April 2025, the University remediated this policy and procedure. No exceptions were identified during the remediation period, and the finding is considered remediated. In April 2025, to address this finding and strengthen compliance, the University initiated the following corrective actions. First, the University worked with leadership to update its procurement policy to increase the simplified acquisition threshold to $250,000, aligning with federal guidelines. This change ensures that the University’s procurement processes are more consistent with federal standards. Second, a new requirement was implemented, mandating that a price analysis form be completed and retained for each procurement transaction exceeding the simplified acquisition threshold. This form documents the University’s independent price analysis. Third, the University provided targeted training to procurement staff and relevant stakeholders to ensure understanding and adherence to the updated policy and the new price analysis requirement. The training emphasized the importance of maintaining contemporaneous documentation in procurement files. Finally, the University implemented enhanced internal controls to ensure that all procurement transactions exceeding the simplified acquisition threshold are reviewed and approved by designated leadership, with documented evidence of a price analysis retained in the procurement files. Primary responsibility for implementing and monitoring this corrective action plan rests with Beth Connelly, Senior Director of Procurement Operations, 216-368-6332.