Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-001 ? Material Weakness, Procurement Federal Assistance Listing No. 84.425F U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 3 contracts, we noted 3 contracts for which the University did not retain documentation of their selection of qualified vendors under the simplified acquisition threshold. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable Context: 3 individual contracts ranging in amounts from $87,548 to $137,840 were purchased under the federal grant without maintaining proper documentation related to the requirements of the simplified acquisition threshold. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included with this report. Completion Date: June 2023 Contact Person: Kris Pace, Controller
Finding 2022-001 ? Significant Deficiency - Procurement Federal Assistance Listing No. 84.425F, 84.425M U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 6 expenditures, we noted 2 expenditures for which the University did not retain documentation of price or rate quotations obtained from an adequate number of qualified sources prior to the purchase or the rationale for limiting competition if such price or rate comparisons were not considered necessary. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: 2 individual expenditures ranging in amounts of $57,312 and $90,000 were purchased under the federal grant without obtaining quotes, using a competitive bid process or documenting the rationale for limiting competition. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included in their response included with this report. Completion Date: February 1, 2023 Contact Person: Robert Walla ? Procurement Director
Finding 2022-001 ? Significant Deficiency - Procurement Federal Assistance Listing No. 84.425F, 84.425M U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 6 expenditures, we noted 2 expenditures for which the University did not retain documentation of price or rate quotations obtained from an adequate number of qualified sources prior to the purchase or the rationale for limiting competition if such price or rate comparisons were not considered necessary. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: 2 individual expenditures ranging in amounts of $57,312 and $90,000 were purchased under the federal grant without obtaining quotes, using a competitive bid process or documenting the rationale for limiting competition. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included in their response included with this report. Completion Date: February 1, 2023 Contact Person: Robert Walla ? Procurement Director
Finding 2022-002 - Significant Deficiency - Procurement Federal Assistance Listing No. 84.425F, 84.425M U.S. Department Of Education ESF Section 2 - Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 6 expenditures, we noted 2 expenditures for which the University did not retain documentation of price or rate quotations obtained from an adequate number of qualified sources prior to the purchase or the rationale for limiting competition if such price or rate comparisons were not considered necessary. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: 2 individual expenditures ranging in amounts of $57,312 and $90,000 were purchased under the federal grant without obtaining quotes, using a competitive bid process or documenting the rationale for limiting competition. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included in their response included with this report. Completion Date: February 1, 2023 Contact Person: Robert Walla - Procurement Director
Finding 2022-002 - Significant Deficiency - Procurement Federal Assistance Listing No. 84.425F, 84.425M U.S. Department Of Education ESF Section 2 - Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 6 expenditures, we noted 2 expenditures for which the University did not retain documentation of price or rate quotations obtained from an adequate number of qualified sources prior to the purchase or the rationale for limiting competition if such price or rate comparisons were not considered necessary. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: 2 individual expenditures ranging in amounts of $57,312 and $90,000 were purchased under the federal grant without obtaining quotes, using a competitive bid process or documenting the rationale for limiting competition. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included in their response included with this report. Completion Date: February 1, 2023 Contact Person: Robert Walla - Procurement Director
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-003 Significant Deficiency: Procurement, Suspension and Debarment ? Compliance and Control Finding ALN 14.231 - Emergency Solutions Grant Program Federal Agency: U.S. Department of Housing and Urban Development Pass-Through Entities: City of St. Louis, St. Louis County, Missouri Housing Development Commission Criteria or Specific Requirement: 2 CFR section 200.3018 requires grantees have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. The Uniform Guidance also restricts awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in federal assistance programs. In addition, the Uniform Guidance requires that controls over compliance be properly designed, in place and operating effectively to ensure compliance with these requirements. Condition: We noted through procedures performed that property and services were purchased under federal grants using a process that did not adhere to the requirements of the Uniform Guidance. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement, suspension and debarment requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: Equipment and services totaling $27,700 and $50,000, respectively, were purchased under the federal grant without obtaining quotes or using a competitive bid process. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views of Responsible Officials: St. Patrick Center (SPC) will review its Procurement Policy to ensure its policy includes all of the procurement, suspension and debarment requirements of the Uniform Guidance. In addition, SPC will investigate and implement a control procedure that will ensure proper internal controls are in place for compliance with these Uniform Guidance requirements. For example, a checklist outlining these requirements could be completed and approved by the appropriate personnel for applicable grants to ensure adequate internal controls are in place for compliance. Also, SPC will hold a training session with all personnel involved in this process to help ensure compliance with these procurement, suspension and debarment requirements of the Uniform Guidance. New hires involved this process will also receive training on these requirements during the new hire training sessions. In addition, SPC will maintain supporting documentation to show compliance with these requirements.
Finding 2022-001 ? Material Weakness, Procurement Federal Assistance Listing No. 84.425F U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 3 contracts, we noted 3 contracts for which the University did not retain documentation of their selection of qualified vendors under the simplified acquisition threshold. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable Context: 3 individual contracts ranging in amounts from $87,548 to $137,840 were purchased under the federal grant without maintaining proper documentation related to the requirements of the simplified acquisition threshold. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included with this report. Completion Date: June 2023 Contact Person: Kris Pace, Controller
Finding 2022-001 ? Significant Deficiency - Procurement Federal Assistance Listing No. 84.425F, 84.425M U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 6 expenditures, we noted 2 expenditures for which the University did not retain documentation of price or rate quotations obtained from an adequate number of qualified sources prior to the purchase or the rationale for limiting competition if such price or rate comparisons were not considered necessary. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: 2 individual expenditures ranging in amounts of $57,312 and $90,000 were purchased under the federal grant without obtaining quotes, using a competitive bid process or documenting the rationale for limiting competition. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included in their response included with this report. Completion Date: February 1, 2023 Contact Person: Robert Walla ? Procurement Director
Finding 2022-001 ? Significant Deficiency - Procurement Federal Assistance Listing No. 84.425F, 84.425M U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 6 expenditures, we noted 2 expenditures for which the University did not retain documentation of price or rate quotations obtained from an adequate number of qualified sources prior to the purchase or the rationale for limiting competition if such price or rate comparisons were not considered necessary. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: 2 individual expenditures ranging in amounts of $57,312 and $90,000 were purchased under the federal grant without obtaining quotes, using a competitive bid process or documenting the rationale for limiting competition. Identification as a Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included in their response included with this report. Completion Date: February 1, 2023 Contact Person: Robert Walla ? Procurement Director
Finding 2022-002 - Significant Deficiency - Procurement Federal Assistance Listing No. 84.425F, 84.425M U.S. Department Of Education ESF Section 2 - Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 6 expenditures, we noted 2 expenditures for which the University did not retain documentation of price or rate quotations obtained from an adequate number of qualified sources prior to the purchase or the rationale for limiting competition if such price or rate comparisons were not considered necessary. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: 2 individual expenditures ranging in amounts of $57,312 and $90,000 were purchased under the federal grant without obtaining quotes, using a competitive bid process or documenting the rationale for limiting competition. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included in their response included with this report. Completion Date: February 1, 2023 Contact Person: Robert Walla - Procurement Director
Finding 2022-002 - Significant Deficiency - Procurement Federal Assistance Listing No. 84.425F, 84.425M U.S. Department Of Education ESF Section 2 - Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 6 expenditures, we noted 2 expenditures for which the University did not retain documentation of price or rate quotations obtained from an adequate number of qualified sources prior to the purchase or the rationale for limiting competition if such price or rate comparisons were not considered necessary. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable. Context: 2 individual expenditures ranging in amounts of $57,312 and $90,000 were purchased under the federal grant without obtaining quotes, using a competitive bid process or documenting the rationale for limiting competition. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included in their response included with this report. Completion Date: February 1, 2023 Contact Person: Robert Walla - Procurement Director