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.
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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 10 out of 25 sampled transactions exceeding the University’s simplified
acquisition threshold of $50,000 lacked documented evidence of an independent cost or price analysis. This was due to
the University’s existing policy not requiring such documentation for transactions meeting the simplified acquisition
threshold.
To address this finding and strengthen compliance, the University has initiated the following corrective actions. First, the
University is working with leadership to update its procurement policy to increase the simplified acquisition threshold to
$250,000, aligning with federal guidelines. This change will ensure that the University’s procurement processes are more
consistent with federal standards. Second, a new requirement will be implemented, mandating that a cost or price analysis
form be completed and retained for each procurement transaction exceeding the simplified acquisition threshold. This
form will document the University’s independent cost or price analysis. Third, the University will provide targeted
training to procurement staff and relevant stakeholders to ensure understanding and adherence to the updated policy and
the new cost or price analysis requirement. This training will emphasize the importance of maintaining contemporaneous
documentation in procurement files. Finally, the University will implement 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 cost or price analysis retained in the procurement files. The University
anticipates having documentation and protocols finalized and implemented by April 2025. Once in place, all FY25 to date
will be reviewed to ensure compliance with the updated policy.
These corrective actions underscore the University’s commitment to maintaining the accuracy, integrity, and compliance
of its procurement processes. While no questioned costs were identified, the steps outlined above will help ensure ongoing
compliance with federal procurement requirements.
Primary responsibility for implementing and monitoring this corrective action plan rests with Ashley Frantz, Chief
Procurement Officer, 216-368-2595.