Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: 04/15/2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Finding 2022-005: Procurement Federal Program: Research and Development Cluster (Education and Human Resources) Assistance Listing Number and Title: 47.076 STEM Education Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1821462 (7/1/2018 – 6/30/2024), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024), 2141745 (5/1/2022 – 4/30/2027), 2212807 (7/1/2022 – 6/30/2026) Federal Program: Research and Development Cluster (Mathematical and Physical Sciences) Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024) Federal Program: Research and Development Cluster (Science) Assistance Listing Number and Title: 43.001 Science Name of Federal Agency, Pass Through Entity: National Aeronautics and Space Administration: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC21K1560 (6/28/2021 – 6/27/2022 pass through entity Temple University of the Commonwealth System of Higher Education), 80NSSC22K1071 (5/23/2022 – 5/22/2023) Significant Deficiency in Internal Controls Over Compliance, Other matters Federal Programs: Research and Development Cluster: All Grants Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code. Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented. Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness. Questioned Costs: None noted. Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature. Identification as a Repeat Finding, if Applicable: 2021-005. Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation. Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices. Management will be responsible for proper documentation and confirmation that all policies and procedures are followed. Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented. Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds. Anticipated Completion Date: November 2024 Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO
Assistance Listing, Federal Agency, and Program Name 93.224, 93.527; COVID 19: Health Center Program Cluster Federal Award Identification Number and Year H80CS24134, H8ECS37956, H8FCS40356, and H8GCS48255 2022 Pass through Entity N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria In accordance with 2 CFR sections 200.318 200.326, the Organization must maintain and use documented procedures for procurement transactions that are consistent with State, local, and tribal laws and regulations and the standards identified in CFR sections 200.317 through 200.327. The Organization must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Additionally, in accorance with 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6, the Organization must verify that the person with whom you intend to do business is not excluded or disqualified. Condition Policies and procedures in place over procurement, suspension, and debarment are not in conformance with Uniform Guidance. Additionally, the Organization did not procure in accordance with the regulations, including maintaining records sufficient to detail the history of each procurement transaction nor did they comply with suspension and debarement rules. Questioned Costs $1,121,985 Identification of How Questioned Costs Were Computed Questioned costs resulted from the Organization not maintaining or using the required procurement procedures over non payroll expenditures. Total non payroll expenditures included on the SEFA total $1,121,985. Context For all four contracts selected for testing, there were no records manintained to support procurement method, contract selection, or verification the entity was not suspended or disbared. Upon further procedures, we identified that the Organization did not follow any procurement guidelines in procuring all non payroll transactions. Cause and Effect There are no procurement, suspension, and debarement policies in place. As a result, no procedures are being completed over these compliance categories and thus the Organization did not comply with the related compliance requirements. Recommendation We recommend the Organization implement written policies and procedures over procurement, suspension, and debarement that conform with Uniform Guidance and follow those policies. Views of Responsible Officials and Planned Corrective Actions The Organization will implement written policies and procedures over procurement, suspension, and debarement that conform with Uniform Guidance.
Assistance Listing, Federal Agency, and Program Name 93.224, 93.527; COVID 19: Health Center Program Cluster Federal Award Identification Number and Year H80CS24134, H8ECS37956, H8FCS40356, and H8GCS48255 2022 Pass through Entity N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria In accordance with 2 CFR sections 200.318 200.326, the Organization must maintain and use documented procedures for procurement transactions that are consistent with State, local, and tribal laws and regulations and the standards identified in CFR sections 200.317 through 200.327. The Organization must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Additionally, in accorance with 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6, the Organization must verify that the person with whom you intend to do business is not excluded or disqualified. Condition Policies and procedures in place over procurement, suspension, and debarment are not in conformance with Uniform Guidance. Additionally, the Organization did not procure in accordance with the regulations, including maintaining records sufficient to detail the history of each procurement transaction nor did they comply with suspension and debarement rules. Questioned Costs $1,121,985 Identification of How Questioned Costs Were Computed Questioned costs resulted from the Organization not maintaining or using the required procurement procedures over non payroll expenditures. Total non payroll expenditures included on the SEFA total $1,121,985. Context For all four contracts selected for testing, there were no records manintained to support procurement method, contract selection, or verification the entity was not suspended or disbared. Upon further procedures, we identified that the Organization did not follow any procurement guidelines in procuring all non payroll transactions. Cause and Effect There are no procurement, suspension, and debarement policies in place. As a result, no procedures are being completed over these compliance categories and thus the Organization did not comply with the related compliance requirements. Recommendation We recommend the Organization implement written policies and procedures over procurement, suspension, and debarement that conform with Uniform Guidance and follow those policies. Views of Responsible Officials and Planned Corrective Actions The Organization will implement written policies and procedures over procurement, suspension, and debarement that conform with Uniform Guidance.
Assistance Listing, Federal Agency, and Program Name 93.224, 93.527; COVID 19: Health Center Program Cluster Federal Award Identification Number and Year H80CS24134, H8ECS37956, H8FCS40356, and H8GCS48255 2022 Pass through Entity N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria In accordance with 2 CFR sections 200.318 200.326, the Organization must maintain and use documented procedures for procurement transactions that are consistent with State, local, and tribal laws and regulations and the standards identified in CFR sections 200.317 through 200.327. The Organization must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Additionally, in accorance with 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6, the Organization must verify that the person with whom you intend to do business is not excluded or disqualified. Condition Policies and procedures in place over procurement, suspension, and debarment are not in conformance with Uniform Guidance. Additionally, the Organization did not procure in accordance with the regulations, including maintaining records sufficient to detail the history of each procurement transaction nor did they comply with suspension and debarement rules. Questioned Costs $1,121,985 Identification of How Questioned Costs Were Computed Questioned costs resulted from the Organization not maintaining or using the required procurement procedures over non payroll expenditures. Total non payroll expenditures included on the SEFA total $1,121,985. Context For all four contracts selected for testing, there were no records manintained to support procurement method, contract selection, or verification the entity was not suspended or disbared. Upon further procedures, we identified that the Organization did not follow any procurement guidelines in procuring all non payroll transactions. Cause and Effect There are no procurement, suspension, and debarement policies in place. As a result, no procedures are being completed over these compliance categories and thus the Organization did not comply with the related compliance requirements. Recommendation We recommend the Organization implement written policies and procedures over procurement, suspension, and debarement that conform with Uniform Guidance and follow those policies. Views of Responsible Officials and Planned Corrective Actions The Organization will implement written policies and procedures over procurement, suspension, and debarement that conform with Uniform Guidance.
Assistance Listing, Federal Agency, and Program Name 93.224, 93.527; COVID 19: Health Center Program Cluster Federal Award Identification Number and Year H80CS24134, H8ECS37956, H8FCS40356, and H8GCS48255 2022 Pass through Entity N/A Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria In accordance with 2 CFR sections 200.318 200.326, the Organization must maintain and use documented procedures for procurement transactions that are consistent with State, local, and tribal laws and regulations and the standards identified in CFR sections 200.317 through 200.327. The Organization must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Additionally, in accorance with 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209 6, the Organization must verify that the person with whom you intend to do business is not excluded or disqualified. Condition Policies and procedures in place over procurement, suspension, and debarment are not in conformance with Uniform Guidance. Additionally, the Organization did not procure in accordance with the regulations, including maintaining records sufficient to detail the history of each procurement transaction nor did they comply with suspension and debarement rules. Questioned Costs $1,121,985 Identification of How Questioned Costs Were Computed Questioned costs resulted from the Organization not maintaining or using the required procurement procedures over non payroll expenditures. Total non payroll expenditures included on the SEFA total $1,121,985. Context For all four contracts selected for testing, there were no records manintained to support procurement method, contract selection, or verification the entity was not suspended or disbared. Upon further procedures, we identified that the Organization did not follow any procurement guidelines in procuring all non payroll transactions. Cause and Effect There are no procurement, suspension, and debarement policies in place. As a result, no procedures are being completed over these compliance categories and thus the Organization did not comply with the related compliance requirements. Recommendation We recommend the Organization implement written policies and procedures over procurement, suspension, and debarement that conform with Uniform Guidance and follow those policies. Views of Responsible Officials and Planned Corrective Actions The Organization will implement written policies and procedures over procurement, suspension, and debarement that conform with Uniform Guidance.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-006 PROCUREMENT, SUSPENSION AND DEBARMENT Material Weakness Criteria The requirements for this compliance requirement are contained in 2 CFR sections 200.317- 200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5, 52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18- 18; and the terms and conditions of the federal award. There is a requirement to verify that contractors in covered transactions or any of its vendors are not federally debarred, suspended, or excluded. A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the primary tier, between a federal agency and a person or a lower tier between a participant in a covered transaction and another person. Condition The auditor noted that CUAHSI failed to maintain and provide the proper records and support to document their review of vendor files for covered transactions. Such failure led to noncompliance with the procurement, suspension and debarment policies in accordance with the UG for the year ended December 31, 2022. CUAHSI did not complete the verification of its 2022 vendors until 2024. Based on our testing, no contractors in covered transactions were deemed to be federally debarred, suspended or excluded.Cause & Context CUAHSI has a policy in place to meet the procurement requirements but there was no evidence of compliance with that policy. Effect As a result of noncompliance, there could be possible repayment of funds and / or possible suspension or debarment. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-007. Recommendation CUAHSI should ensure that, to the extent practicable, the use of a competitive procurement process in compliance with 2 CFR section 200/317. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-006 PROCUREMENT, SUSPENSION AND DEBARMENT Material Weakness Criteria The requirements for this compliance requirement are contained in 2 CFR sections 200.317- 200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5, 52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18- 18; and the terms and conditions of the federal award. There is a requirement to verify that contractors in covered transactions or any of its vendors are not federally debarred, suspended, or excluded. A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the primary tier, between a federal agency and a person or a lower tier between a participant in a covered transaction and another person. Condition The auditor noted that CUAHSI failed to maintain and provide the proper records and support to document their review of vendor files for covered transactions. Such failure led to noncompliance with the procurement, suspension and debarment policies in accordance with the UG for the year ended December 31, 2022. CUAHSI did not complete the verification of its 2022 vendors until 2024. Based on our testing, no contractors in covered transactions were deemed to be federally debarred, suspended or excluded.Cause & Context CUAHSI has a policy in place to meet the procurement requirements but there was no evidence of compliance with that policy. Effect As a result of noncompliance, there could be possible repayment of funds and / or possible suspension or debarment. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-007. Recommendation CUAHSI should ensure that, to the extent practicable, the use of a competitive procurement process in compliance with 2 CFR section 200/317. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-006 PROCUREMENT, SUSPENSION AND DEBARMENT Material Weakness Criteria The requirements for this compliance requirement are contained in 2 CFR sections 200.317- 200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5, 52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18- 18; and the terms and conditions of the federal award. There is a requirement to verify that contractors in covered transactions or any of its vendors are not federally debarred, suspended, or excluded. A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the primary tier, between a federal agency and a person or a lower tier between a participant in a covered transaction and another person. Condition The auditor noted that CUAHSI failed to maintain and provide the proper records and support to document their review of vendor files for covered transactions. Such failure led to noncompliance with the procurement, suspension and debarment policies in accordance with the UG for the year ended December 31, 2022. CUAHSI did not complete the verification of its 2022 vendors until 2024. Based on our testing, no contractors in covered transactions were deemed to be federally debarred, suspended or excluded.Cause & Context CUAHSI has a policy in place to meet the procurement requirements but there was no evidence of compliance with that policy. Effect As a result of noncompliance, there could be possible repayment of funds and / or possible suspension or debarment. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-007. Recommendation CUAHSI should ensure that, to the extent practicable, the use of a competitive procurement process in compliance with 2 CFR section 200/317. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Federal agency name: U.S. National Science Foundation Federal program title: Geosciences, Computer and Information Science and Engineering & Office of Cyber Infrastructure AL No.: 47.050, 47.070, 47.079 & 47.080 Federal Award Identification No. & Award Period: EAR-1849458 (06/01/2019 -05/31/2024), EAR-2012893 (10/01/2020 – 08/31/2025), OAC-1931278 (10/1/2019 – 09/30/2022), OAC- 1829744 (09/01/2018 – 08/31/2023), OAC-1835592 (01/01/2009 – 12/31/2022), OAC-1835818 (10/01/2018 – 09/30/2022), OAC-2103780 (10/01/2021 – 09/30/2026), OAC-2118329 (10/01/2021 – 09/30/2026),OISE-1855654 (05/15/2019 – 12/31/2023) & OAC-1664061 (10/01/17 – 09/30/2022) Pass Through Entity: Utah State University MW2022-006 PROCUREMENT, SUSPENSION AND DEBARMENT Material Weakness Criteria The requirements for this compliance requirement are contained in 2 CFR sections 200.317- 200.326; 48 CFR parts 03, 15, 44, and the clauses at 48 CRF sections 52.244-2, 52.244-5, 52.203-13, 52.203-16 and 52.215-12; agency FAR supplements; 2 CFR part 180; OMB M-18- 18; and the terms and conditions of the federal award. There is a requirement to verify that contractors in covered transactions or any of its vendors are not federally debarred, suspended, or excluded. A covered transaction is a nonprocurement or procurement transaction in excess of $25,000 that is subject to the prohibitions noted in 2 CFR part 180. The covered transaction may be at the primary tier, between a federal agency and a person or a lower tier between a participant in a covered transaction and another person. Condition The auditor noted that CUAHSI failed to maintain and provide the proper records and support to document their review of vendor files for covered transactions. Such failure led to noncompliance with the procurement, suspension and debarment policies in accordance with the UG for the year ended December 31, 2022. CUAHSI did not complete the verification of its 2022 vendors until 2024. Based on our testing, no contractors in covered transactions were deemed to be federally debarred, suspended or excluded.Cause & Context CUAHSI has a policy in place to meet the procurement requirements but there was no evidence of compliance with that policy. Effect As a result of noncompliance, there could be possible repayment of funds and / or possible suspension or debarment. Questioned Costs None Prior Year Audit Finding Yes, previously reported as MW2021-007. Recommendation CUAHSI should ensure that, to the extent practicable, the use of a competitive procurement process in compliance with 2 CFR section 200/317. View of Responsible Official and Planned Corrective Action See accompanying Corrective Action Plan.
Non-Federal entities other than States, including those operating Federal programs as subrecipients of States, must follow the procurement standards set out at 2 CFR 200.317 - 200.327. They must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR Part 200. A non-Federal entity must: 1. Meet the general procurement standards in 2 CFR 200.318, which include oversight of contractors’ performance, maintaining written standards of conduct for employees involved in contracting, awarding contracts only to responsible contractors, and maintaining records to document history of procurements. 2. Conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR 200.319. 3. Use the micro-purchase and small purchase methods only for procurements that meet the applicable criteria under 2 CFR 200.320(a)(1) and (2). Under the micro-purchase method, the aggregate dollar amount does not exceed $10,000 ($2,000 in the case of acquisition for construction subject to the Wage Rate Requirements (Davis-Bacon Act)). Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold ($250,000). Micro-purchases may be awarded without soliciting competitive quotations if the non-Federal entity considers the price to be reasonable (2 CFR 200.320(a)). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources (2 CFR 200.320(b)). 4. For acquisitions exceeding the simplified acquisition threshold, the non-Federal entity must use one of the following procurement methods: the sealed bid method if the acquisition meets the criteria in 2 CFR 200.320(b); the competitive proposals method under the conditions specified in 2 CFR 200.320(b)(2); or the noncompetitive proposals method (i.e., solicit a proposal from only one source) but only when one or more of four circumstances are met, in accordance with 2 CFR 200.320(c). 5. Perform a cost or price analysis in connection with every procurement action in excess of the simplified acquisition threshold, including contract modifications (2 CFR 200.323(a)). The cost plus a percentage of cost and percentage of construction cost methods of contracting must not be used (2 CFR 200.323(b)). 6. Ensure that every purchase order or other contract includes applicable provisions required by 2 CFR 200.326. These provisions are described in Appendix II to 2 CFR Part 200, “Contract Provisions for Non-Federal Entity Contracts Under Federal Awards.” Although the Village contracted with a consultant to assist the Village with compliance with various procurement compliance requirements, the Village does not have any formal policies in place regarding procurement requirements. We recommend that the Village adopt formal policies and procedures that address procurement requirements.
Management’s Response: The Home will update its purchasing policy to ensure the procurement standards in 2 CFR 200.317 – 200.326 are incorporated.
FINDING 2022-005 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): FY 2022 Pass-Through Entity: Department of the Treasury Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context The City had not properly designed or implemented a system of internal controls, which would include appropriate segregation of duties, that would likely be effective in preventing, or detecting and correcting, noncompliance. Federal regulations allow for informal procurement methods when the value of the procurement for property or services does not exceed the simplified acquisition threshold, which is customarily set at $250,000. However, Indiana Code 5-22-8 has a more restrictive threshold of $150,000 or less for when small purchase procedures may be used. Indiana Code provides that the proper purchasing method would be the bidding process, unless the purchase meets certain other qualifications. INDIANA STATE BOARD OF ACCOUNTS 22 CITY OF MUNCIE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Six vendors fell within the simplified acquisition threshold. All six vendors were selected for testing. For three of the vendors tested, there were no requests for proposals received and no documentation to support the history of the procurement, including the rationale for the method of procurement, nor selection of the contract. In addition, there was no documentation that a cost or price analysis was performed for the three contracts. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318 states in part: "(a) The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in §§ 200.317 through 200.327. . . . (i) The non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. . . ." 2 CFR 200.324(a) states: "The non-Federal entity must perform a cost or price analysis in connection with every procurement action in excess of the Simplified Acquisition Threshold including contract modifications. The method and degree of analysis is dependent on the facts surrounding the particular procurement situation, but as a starting point, the non-Federal entity must make independent estimates before receiving bids or proposals." 2 CFR 200.320 states in part: "The non-Federal entity must have and use document procurement procedures, consistent with the standards of this section and §§ 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. . . . INDIANA STATE BOARD OF ACCOUNTS 23 CITY OF MUNCIE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) (b) Formal procurement methods. When the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with § 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) Sealed bids. A procurement method in which bids are publicly solicited and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid, conforming with all the material terms and conditions of the invitation for bids, is the lowest in price. The sealed bids method is the preferred method for procuring construction, if the conditions. (i) In order for sealed bidding to be feasible, the following conditions should be present: (A) A complete, adequate, and realistic specification or purchase description is available; (B) Two or more responsible bidders are willing and able to compete effectively for the business; and (C) The procurement lends itself to a firm fixed price contract and the selection of the successful bidder can be made principally on the basis of price. (ii) If sealed bids are used, the following requirements apply: (A) Bids must be solicited from an adequate number of qualified sources, providing them sufficient response time prior to the date set for opening the bids, for local, and tribal governments, the invitation for bids must be publicly advertised; (B) The invitation for bids, which will include any specifications and pertinent attachments, must define the items or services in order for the bidder to properly respond; (C) All bids will be opened at the time and place prescribed in the invitation for bids, and for local and tribal governments, the bids must be opened publicly; (D) A firm fixed price contract award will be made in writing to the lowest responsive and responsible bidder. Where specified in bidding documents, factors such as discounts, transportation cost, and life cycle costs must be considered in determining which bid is lowest. Payment discounts will only be used to determine the low bid when prior experience indicates that such discounts are usually taken advantage of; and (E) Any or all bids may be rejected if there is a sound documented reason. . . ." INDIANA STATE BOARD OF ACCOUNTS 24 CITY OF MUNCIE SCHEDULE OF FINDINGS AND QUESTIONED COSTS (Continued) Cause The system of internal controls as established by the City was not properly implemented to ensure that goods and services that exceeded the simplified acquisition threshold were properly procured. A proper system of internal controls was not designed by management of the City. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the City's management statements of what should be done to effect internal controls, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, proper procurement procedures were not adhered to for all vendors. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the City establish a proper system of internal controls, and develop policies and procedures to ensure proper procurement procedures are adhered to for all purchases of good and services paid with federal awards. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
2022-001 U.S. Department of Housing and Urban Development Federal Financial Assistance Listing #14.134 Mortgage Insurance Rental Housing Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria: 2 CRF 200.303(a) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. The non-Federal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327 which also requires documentation to be retained to detail the history of procurements. In addition, as outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contactor registry. Condition: The Project does not have a written procurement policy which conforms to Uniform Guidance as outlined above. During the year, management entered into transactions over the micropurchase threshold with eight vendors. Documentation was unable to be provided to support procurement compliance for seven vendors. In addition, there was one vendor with expenditures in excess of $25,000 and the Project did not verify the vendor against the central contractor registry prior to entering into the transaction or on a periodic basis to ensure that the vendor was not suspended or debarred. Cause: Management does not have a written procurement policy in accordance with Uniform Guidance. Certain procedures were in place; however, without a written policy to follow, the auditors were unable to determine if the procedures for procurement, suspension, and debarment compliance for the vendors was adequate. Effect: Inadequate controls over this area of compliance result in a reasonable possibility that the Project would not have the required documentation in place and would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: We were unable to determine known questioned costs. During the year, management entered into transactions over the micropurchase threshold with eight vendors totaling approximately $92,000. Context/Sampling: No sampling was used. Procurement requirements were applicable to 8 transactions (all transactions were reviewed and tested) and suspension and debarment requirements were applicable to one vendor. Repeat Finding from Prior Year: No Recommendation: We recommend management review the procurement policy requirements under Uniform Guidance and adopt a procurement policy in accordance with Uniform Guidance requirements. In addition, we also recommend management implement formal procedures over procurement, suspension and debarment in accordance with that policy and retain sufficient documentation to support the process was followed. Views of Responsible Officials: Management agrees with the finding and recommendation.
FINDING 2022-001 Subject: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds - Procurement and Suspension and Debarment Federal Agency: Department of the Treasury Federal Program: COVID-19 - Coronavirus State and Local Fiscal Recovery Funds Assistance Listings Number: 21.027 Federal Award Number and Year (or Other Identifying Number): SLFRP2971 Compliance Requirement: Procurement and Suspension and Debarment Audit Findings: Material Weakness, Modified Opinion Condition and Context An effective internal control system was not in place at the County to ensure compliance with the requirements related to the grant agreement and the Procurement and Suspension and Debarment compliance requirement. Procurement The County's purchasing policy did not reflect applicable state laws and regulations. In addition, the policy did not include procedures to avoid acquisition of unnecessary or duplicative items, or procedures to ensure that all solicitations incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured. Suspension and Debarment Prior to entering into subawards and covered transactions with State and Local Fiscal Recovery Funds (SLFRF) award funds, recipients are required to verify that such contractors and subrecipients are not suspended, debarred, or otherwise excluded. "Covered transactions" include, but are not limited to, contracts for goods and services awarded under a nonprocurement transaction (i.e., grant agreement) that are expected to equal or exceed $25,000. The verification is to be done by checking the Excluded Parties List System (EPLS), collecting a certification from that person, or adding a clause or condition to the covered transaction with that person. Upon inquiry of the County to review the procedures in place for verifying that an entity with which it plans to enter into a covered transaction is not suspended, debarred, or otherwise excluded, the County divulged that it was unaware of the suspension and debarment requirements related to the SLFRF awards. A population of four covered transactions, totaling $990,897, that equaled or exceeded $25,000 paid from SLFRF funds during the audit period was identified. For each of the four transactions, the County did not verify the suspension and debarment status prior to payment due to the County not having any policies or procedures in place to verify that contractors and subrecipients were neither suspended nor debarred, or otherwise excluded or disqualified from participating in federal assistance programs or activities. The lack of internal controls and noncompliance were systemic issues throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." 2 CFR 200.318(a) states: "The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non- Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327." 2 CFR 200.214 states: "Non-federal entities are subject to the non-procurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR part 180. The regulations in 2 CFR part 180 restrict awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from or ineligible for participation in Federal assistance programs or activities." 31 CFR 19.300 states: "When you enter into a covered transaction with another person at the next lower tier, you must verify that the person with whom you intend to do business is not excluded or disqualified. You do this by: (a) Checking the EPLS; or (b) Collecting a certification from that person if allowed by this rule; or (c) Adding a clause or condition to the covered transaction with that person." Cause A proper system of internal controls was not designed by management of the County. Embedded within a properly designed and implemented internal control system should be internal controls consisting of policies and procedures. Policies reflect the County's management of what should be done to effect internal control, and procedures should consist of actions that would implement these policies. Effect Without the proper implementation of an effectively designed system of internal controls, the internal control system cannot be capable of effectively preventing, or detecting and correcting, material noncompliance. As a result, vendors and subrecipients to whom payments equal to or in excess of $25,000 were not verified to be not suspended, debarred, or otherwise excluded. Noncompliance with the provisions of Federal regulations, and the terms and conditions of the federal award could result in the loss of future federal funding to the County. Questioned Costs There were no questioned costs identified. Recommendation We recommended that management of the County establish a proper system of internal controls and develop policies and procedures to ensure contractors and subrecipients, as appropriate are not suspended, debarred, or otherwise excluded prior to entering into any contracts or subawards. Additionally, we recommend the County establish documented procurement procedures consistent with state and local laws for the acquisition of property or services required under a federal award or subaward. The nonfederal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.
Finding 2022-002: Procurement and Suspension and Debarment Identification of federal program: Program Title: Agriculture Research Basic and Applied Research Assistance Listing Number: 10.001 Award Identification: CA 59-8082-0-001 Federal Agency: U.S. Department of Agriculture, Agriculture Research Service Criteria or Specific Requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During testing for the Fund?s controls on compliance over procurement and suspension and debarment, the Fund could not provide a procurement policy that is in compliance with prescribed standards in the Uniform Guidance. Additionally, suspension and debarment verifications were not performed prior to entering a covered transaction. Cause: The Fund has not updated its procurement policy to fully conform with Uniform Guidance, including policies over suspension and debarment. Effect: The Fund was not in compliance with the procurement policy requirements of Uniform Guidance, specifically around suspension and debarment. Questioned Costs: None Context: The Fund currently does not have a procurement policy that fully complies with Uniform Guidance requirements addressed in Chapter 2 Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Repeat finding: No Recommendation: The Fund should ensure its documented procurement procedures conform to the procurement standards identified in 2 CFR section ?? 200.317 through 200.327, and also address suspension and debarment. Views of responsible individuals: Management concurs with and will implement the recommendation. See corrective action plan.
Finding 2022-004: Procurement, Suspension and Debarment Identification of the federal program: Equitable Sharing Program, ALN 16.922 Criteria: Compliance Requirement I, Procurement, Suspension and Debarment, Part 4 of the 2022 Compliance Supplement states that, ?Although 2 CFR section 200.317-200.327 are not applicable, the Guide, Section VI.A.., requires agencies to follow their own jurisdiction?s procurement policies? and that Suspension and Debarment ? 2 CFR section 180.200-225 is applicable. In addition, the 2022 Compliance Supplement states that ?program policy and procedures are set forth in the Guide to Equitable Sharing for State, Local, and Tribal Law Enforcement Agencies (Guide) (July 2018) as well as Equitable Sharing Wires (Wires). The September 30, 2021 edition of the Wire (used to update the Guide) states that, ??local law enforcement agencies participating in the Department of Justice and Department of Treasury Equitable Sharing Program must verify that vendors are registered in the System for Award Management (SAM) and are in good standing. A vendor in good standing means the vendor is not suspended or debarred from receiving federal funds. This requirement applies to all qualifying purchases. A qualifying purchase is one single payment or multiple payments to a vendor that exceeds $25,000 annually.? Condition: Condition 1: The County purchased office furniture and equipment from a vendor totaling $64,518. Under the County?s purchasing policy, competitive bids were required; however, competitive bid documents were not present in the county?s paid bills files and there was no other documentation of competitive bids being solicited or received, or justification for not receiving bids, which the policy requires to be documented if bids cannot be obtained. Condition 2: The purchase noted in Condition 1, plus an additional purchase of $34,702 from another vendor were above the $25,000 threshold for vendor verification in the SAM system. Neither vendor was verified by the County to be registered and in good standing in the SAM system. Cause: Condition 1: There was an inadvertent disregard of the bidding requirement by the department head for the $64,518 purchase of office equipment, since the purchase was from a regularly used county vendor who offers government discounts. When the disbursement was processed by the County Clerk, there was a failure to recognize there was a bidding requirement prior to the purchase and a failure of the internal control in disbursement processing which identifies purchase subject to county bid requirements and determines if bid documents are present in supporting documents. Condition 2: There were no policy, procedures or internal controls in place for this requirement, as county personnel were not aware of the requirement. The County Attorney has also been unable to establish an account with SAM, even after engaging a consultant to assist, as the system will not allow multiple log ins for the same entity. Effect of Potential Effect: Denial or extinguishment of sharing requests; temporary or permanent exclusion from the Program; freeze on receipt and/or expenditure of shared funds; return of funds or offsets from future sharing. Questioned Costs: The questioned costs for Condition 1 were $64,518, the amount of the transaction noted in Condition 1. The vendors for these two transactions were determined by the auditor to be vendors in good standing in the SAM system; therefore, Condition 2 does not result in additional questioned costs. Context: There were no other transactions in the population of 2022 expenditures in the major program meeting the county?s bidding threshold requirement or the SAM vendor verification threshold for this program. Recommendation: Condition 1: All department heads should follow the existing procurement policy of the county with respect to bidding. The existing review of documentation by the Clerk?s department to ensure compliance with county bidding requirements should always be properly performed and any exceptions to it referred to the governing body, if necessary, prior to processing of disbursement. Condition 2: A policy and procedure should be developed to ensure compliance with the requirement to verify qualifying status of vendors with annual transactions of $25,000 or more. If department heads are unable to access the SAM system to verify vendor qualification, there should be a request forwarded to the County Clerk to do the verification prior to order of goods or services. Views of responsible officials: The Clerk and the County Attorney concur.
Federal Agency: U.S. Department of the Treasury Federal Program Name: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Pass-Through Agency: State of Arizona, the Office of the Governor Pass-Through Number(s): GR-ARPA-HHF-030122-01 and GR-ARPA-090121-01 Award Period: January 1, 2022 ? November 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Condition/Context: The Organization did not maintain a formalized and written procurement policy. In addition, the Organization did follow the required solicitation process as follows: 1. Small purchase procedures for one vendor, with costs between $10,000 and $250,000 related to grant management and financial oversight, were not performed. 2. Formal procurement methods or noncompetitive procurement procedures for one vendor, with costs exceeding $250,000 related to mental health services, were not performed. The Organization contracted with this mental health vendor prior to accepting the Coronavirus State and Local Fiscal Recovery Funds and subsequently did not go through formal procurement procedures. 3. For two vendors, procedures to determine that the vendors were not included on the suspended or debarred vendor list maintained by the General Services Administration, were not performed. Criteria or specific requirement: In accordance with the Compliance Supplement, Part 6 ? Internal Control, 2 CFR section 200.303 requires that nonfederal entities receiving federal awards establish and maintain internal control over the federal awards that provides reasonable assurance that the nonfederal entity is managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards. In accordance with 2 CFR 200.318 (a), the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. In accordance with 2 CFR 200.320 (a)(2)(i), the non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Small purchase procedures - the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Criteria or specific requirement (Continued) In accordance with 2 CFR 200.320 (b)(1 and 2), the non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Formal procurement methods - when the value of the procurement for property or services under a Federal financial assistance award exceeds the SAT, or a lower threshold established by a non-Federal entity, formal procurement methods are required. Formal procurement methods require following documented procedures. Formal procurement methods also require public advertising unless a non-competitive procurement can be used in accordance with ? 200.319 or paragraph (c) of this section. The following formal methods of procurement are used for procurement of property or services above the simplified acquisition threshold or a value below the simplified acquisition threshold the non-Federal entity determines to be appropriate: (1) sealed bids, or (2) proposals. In accordance with 2 CFR 200.320 (c), the non-Federal entity must have and use documented procurement procedures, consistent with the standards of this section and ?? 200.317, 200.318, and 200.319 for any of the following methods of procurement used for the acquisition of property or services required under a Federal award or sub-award. Noncompetitive procurement. There are specific circumstances in which noncompetitive procurement can be used. Noncompetitive procurement - can only be awarded if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold (see paragraph (a)(1) of this section); (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. In accordance with 2 CFR 180.220, the non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR section 180.220). All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Questioned costs: None Cause: The Organization did not have established procurement policies and did not have internal controls designed to ensure compliance with those policies. Effect: The Organization was not in compliance with the Compliance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Repeat Finding: No Recommendation: We recommend that the Organization adopt a formal and written procurement policy. Additionally, management should develop controls to help ensure procurement procedures are followed and to monitor the amount spent with vendors throughout the year to ensure procurement procedures are initiated when the vendor costs exceed the procurement thresholds. These procedures will help ensure compliance with Compliance Supplement and the Code of Federal Regulations related to procurement and suspension and debarment provisions. Views of responsible officials: Management agrees with the audit condition.
Finding 2022-002: Procurement Policy (Material Weakness) Information on the Federal Program: U.S. Department of State ALN 19.040 Criteria or Specific Requirement: 2 CFR Section 200.318 requires that the non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Condition: FCE does not have a formal written procurement policy that conforms to the requirements of the Uniform Guidance. As a result, no procurement files were maintained to document FCE's procurement actions. Questioned Costs: None Cause: FCE has no accounting policies and procedures in place to provide guidance to management on the documentary evidence requirements in accordance with proper internal controls and the Uniform Guidance. Effect or Potential Effect: Without either a procurement policy or procurement documentation, there is a risk that FCE did not perform a proper evaluation of each potential vendor whose costs were charged to federal programs. Recommendation: FCE should develop accounting policies and procedures to provide guidance to management regarding the proper internal controls over both financial reporting and compliance with federal awards. Included in those policies and procedures should be a procurement policy that conforms to the requirements of the Uniform Guidance. Furthermore, FCE should maintain documentation in its files to provide evidence to support that it followed the procurement policy.
2 CFR 200.317 - 200.327 sets procurement standards for non-federal entities other than states. These non-federal entities must use their own documented procurement procedures, which reflect applicable State and local laws and regulations, provided that the procurements conform to applicable Federal statutes and the procurement requirements identified in 2 CFR Part 200. Small purchase procedures are used for purchases that exceed the micro-purchase amount but do not exceed the simplified acquisition threshold. According to the Authority's Procurement Policy, for small purhcases from $3,501 to $50,000, no less than three offerors shall be solicited to submit price quotations, which may be obtained orally by telephone, or in writing, as allowed by State and local laws. Further, contracts shall not be awarded to debarred, suspended, or ineliglbe contracts. Due to deficiencies in the Authority's internal controls over compliance requireements, eight percent of the procurements tested did not follwo the Authority's policy in regards to procurement as they did not obtain and maintain price quotations for small purchases. The Authority should review the uniform guidance regulations over procurement and consider increasing their thresholds based on uniform guidiance guidelines. Further, the Authority should follow their policy and procedures for procurement.
FINDING 2022-001 Procurement, Suspension and Debarment (Repeat Finding 2021-001) Federal Agency: Department of the Treasury Federal Program: 21.027 Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) Criteria: The Department of the Treasury?s Interim Final Rule (Effective May 17, 2021 through March 31, 2022) and the Final Rule (Effective April 1, 2022) encouraged the use of internal Procurement Policies and Procedures when procuring products and/or services. The Department of the Treasury?s Compliance and Reporting Guidance report (Effective June 24, 2021 through April 30, 2025) required recipients (i.e., City of Evanston) to ensure any procurement using CSLFRF funds to be consistent with the procurement standards set forth in the Uniform Guidance at 2 CFR 200.317 through 2 CFR 200.327 as applicable. Procurement Standards of Title 2 of the Code of Federal Regulations (CFR) Part 200 Uniform Administrative Requirements, Costs Principles, and Audit Requirements for Federal Awards (Uniform Guidance) state that all non-federal entities will follow Section 200.318 through Section 200.327. A. Section 200.320 identifies four methods of procurement to be followed, among the methods of procurement the below are three identified thresholds: (a) Informal ? micro purchases (any amount up to $10,000) (b) Informal ? small purchases ($10,000.01 to $249,999.99) (c) Formal ? sealed bids ($250,000 and above) (d) Noncompetitive procurement B. The City of Evanston Purchasing Manual requires the collection of three written quotes for any purchase between $2,500 and $25,000 purchased with federal grant funds, a formal bid process (Bid, RFP, RFQ) for any purchase $25,000 or above purchased with federal grant funds, and a justification memo for a sole source purchase for any amount above $2,500 purchased with federal grant funds. C. The City of Evanston Purchasing Manual requires that for purchases above $2,500 but less than $10,000, approval signature must be obtained from the Department Director. All purchases above $10,000 require approval signature from the City Manager. Purchases above $25,000 must also be approved by the City Council. D. Per Title 2 CFR section 180.300, participant entering into a covered transaction must verify that the person with whom it intends to do business is not excluded or disqualified by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. E. Title 2 CFR section 200.303 states the following regarding internal control: ?The auditee shall maintain internal control over Federal programs that provides reasonable assurance that the auditee is managing Federal awards in compliance with law, regulations, and the provisions of contracts or grant agreements that could have a material effect on each of its Federal programs.? Condition/Context: 1. We tested nine purchase orders totaling $2,408,526. Our procedures revealed the following: a. Two (2) purchase orders in the amount of $27,739 and $150,525 respectively, were purchases greater than $25,000 each, and for which the City of Evanston did not complete a formal procurement process (competitively bid) following its own Purchasing Manual and/or obtain the required three quotations following Section 200.320 of Title 2 of the Code of Federal Regulations (CFR). b. For seven (7) purchase orders totaling $2,391,116, documentation demonstrating that suspension and debarment searches were performed could not be provided by the City of Evanston. c. For one (1) purchase order totaling $700,405, procurement documentation was not provided nor retained by the City of Evanston from third party procurement service provider. Cause: 1. The City of Evanston?s procurement policies do not include processes pertaining to monitoring and review procedures of procurement processes conducted by external procurement service providers to ensure compliance with all applicable procurement policies. 2. The City of Evanston?s procurement policies do not include processes pertaining to entity-wide suspension and debarment checks. 3. Where policies are in place for internal procurement they are not being followed. Effect: City of Evanston is not in compliance with Title 2 of the Code of Federal Regulations (CFR) Part 200 and the requirements outlined in the City of Evanston Purchasing Manual as it relates to purchases above $25,000. Additionally, the effect of noncompliance can result in questioned costs. Recommendation: We recommend that City of Evanston: a. Implement structures to monitor external procurement service providers to ensure their procurement methods comply with applicable federal compliance requirements. b. Further expand Purchasing Manual to include policies and procedures for suspension and debarment searches and retaining support for suspension and debarment check. c. Communicate and re-enforce its procurement policies and procedures to ensure compliance with applicable requirements. d. Centralize the procurement process to ensure all departments are following applicable procedures in a uniform manner. Views of Responsible Officials: The City of Evanston implemented a revised Purchasing Manual as of March 2023. We agree with the auditor?s recommendations and will further review and revise the Purchasing Manual and communicate and reinforce policies and procedures to all departments to ensure compliance with applicable requirements.