2023-001 – Uniform Guidance Procurement Standards Criteria: One of the more significant provisions of the Uniform Guidance that affects the Town is the procurement standards under 2 CFR sections 200.318 through 200.326. Under the procurement standards, the Town is required to have a documented purchasing policy, which at a minimum, incorporates the provisions of the Uniform Guidance. Statement of Condition: The Office of Management and Budget (OMB) revised regulations applicable to federally funded programs. The regulations are contained in Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance). The Uniform Guidance replaced OMB Circulars A-133, A-87, and A-110 and incorporates requirements for grant recipients. The Uniform Guidance includes not only protocols for program management and administration, but also updates compliance regulations for federal awards. Cause: The Town had not adopted a procurement policy that covered all aspects required by the Uniform Guidance. However, during our testing of procurement over federal expenditures, we did not notate any violations of the Uniform Guidance procurement standards. Effect: Items required by the Uniform Guidance procurement standards were not addressed in the policy followed by the Town during the fiscal year. Recommendation: We recommend that management review the applicable provisions of the Uniform Guidance procurement standards and update the Town’s procurement policy appropriately. This would include adding any missing components to the Town’s current procurement policy and updating definitions of types of procurement, i.e. micro-purchases, small purchases, and small acquisition threshold, to match the language used in the Uniform Guidance procurement standards.
2023-003: Written Debarred, Suspended Vendors & Federal Standards of Conflict Findings Prior Year Findings: Yes, 2022-004 Department Agency: Environmental Protection Agency State Department: Wyoming State Loan & Investment Board Office of State Lands & Investments Assistance Listing Number: ALN # 15.252 Compliance Area: Procurement & Suspension & Debarment (I) Type of Finding: Significant Deficiency Questioned Costs: None Criteria: The Town of Dayton should have written standards of conduct in place to verify any entity (vendor) with which the Town spends Federal expenditures of conducts business transactions be not debarred, suspended, or otherwise excluded per 2 CFR 200.318(h) and 2 CFR 180. The written standard should address conduct covering conflicts of interest governing the performance of its employees and contractors engaged in the selection, award, and administration of contracts (Uniform Guidance Section 200.318 and 45 CFR sections 52.203-13 and 52.203-16). Condition: The Town of Dayton did not have written controls in place to ensure that vendors were not suspended or debarred or included on the list of vendors prior to entering into a contract with the Town. The written standard of conduct covering conflicts of interest and governing the performance of its employees and contractors must be documented when engaged in the selection, award and administration of Federal grant contracts. Cause and Effect: The Town of Dayton due to large influx of Federal expenditures. There was not a control in place to ensure that vendors or contractors the Town entered into contracts with were not suspended or debarred before contracts were executed. Without a reliable control in place to ensure compliance, the Town of Dayton could enter into a contract with a suspended or debarred party and have a control of interest with the Federal written contracted parties. Repeat Finding: Yes Recommendation: We recommend that the Town of Dayton put written internal controls in place such as using a checklist to ensure Federal funds that pay contractors are not suspended or debarred and should consider the Town of Dayton adopt a policy on procurement for debarment. The town needs to adopt a written policy when spending Federal funds, to ensure no conflict of interests exist. Response: Please see the last page of this report for he Town's repsonse to this finding.
Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition – In our testing of procurement, suspension and debarment it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect – A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. Questioned Costs – None reported Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – Yes, prior year finding 2022-004 Recommendation – We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials – There is no disagreement with the audit finding.
Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition – In our testing of procurement, suspension and debarment it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect – A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. Questioned Costs – None reported Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – Yes, prior year finding 2022-004 Recommendation – We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials – There is no disagreement with the audit finding.
Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition – In our testing of procurement, suspension and debarment it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect – A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. Questioned Costs – None reported Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – Yes, prior year finding 2022-004 Recommendation – We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials – There is no disagreement with the audit finding.
Department of Education, Passed through North Dakota Department of Public Instruction Federal Financial Assistance Listing/CFDA Number 84.027/84.173 Special Education Cluster Procurement, Suspension, and Debarment Material Weakness in Internal Control over Compliance Criteria – Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non‐federal entities other than states must follow when operating federal programs and the procurement procedures required. Condition – In our testing of procurement, suspension and debarment it was identified that the District did not have a written policy on procurement that satisfied the requirements of 2 CFR sections 200.318 through 200.326. Cause – Lack of oversight, awareness, or understanding of all of the specific requirements under the Uniform Guidance and applicable CFR sections and controls were not adequately designed to ensure compliance with all of these requirements. Effect – A lack of documented policies increase the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower tier entities. Questioned Costs – None reported Context/Sampling – Overall procurement policy. Repeat Finding from Prior Years – Yes, prior year finding 2022-004 Recommendation – We recommend that management establish a written policy that addresses all of the procurement requirements for federal programs as identified in 2 CFR sections 200.318 through 200.326 and maintain adequate supporting documentation and records to document history and methods of procurement and the procedures performed to comply with these CFR sections. Views of Responsible Officials – There is no disagreement with the audit finding.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Assistance Listing Number(s): 10.553 and 10.555 Name of Federal Program or Cluster: Child Nutrition Cluster Name of Federal Agency: Department of Agriculture Name of Pass-through Entity: Wisconsin Department of Public Instruction Pass-through Entity Identifying Number(s): 2023-138142-DPI-SB-546, 2023-138005-DPI-SB-546, 2023-138005-DPI-NSL-547, and 2023-138005-DPI-SK_NSLAE-566 Award Period: July 1, 2022 through June 30, 2023 Criteria: According to 2 CFR, Part 200.300 of the Uniform Guidance, a non-federal entity must have the following policies over compliance: cash management (section 200.302(b)(6)), allowability of costs (section 200.302(b)(7)), procurement (section 200.318-.326, reporting (section 200.303), special tests (section 200.303), travel (section 200.475(b)), compensation (section 200.430(a)(1)), and fringe benefits (section 200.431). Condition: Written policies and procedures are not in accordance with the Uniform Guidance. Cause: Sufficient training has not been provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Effect or Potential Effect: Lack of policies and procedures in accordance with the Uniform Guidance could result in noncompliance, disallowed costs, or discontinuance of federal funding. Repeat Finding: No Recommendation: Additional training should be provided to individuals responsible for the development of written policies and procedures in accordance with the Uniform Guidance. Views of Responsible Officials: One City Schools, Inc. agrees with the finding and are working on creating written policies and procedures in accordance with the Uniform Guidance.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Federal Agency: Department of Education Federal Program Title: Research and Development CFDA Number: Various Award Period: July 1, 2022 through June 30, 2023 Type of Finding: Significant Deficiency in Internal Control over Compliance (Other Matters) Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.212, 200.318(h) and 180.300, along with 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: The University could not produce documentation to show that they performed suspension and debarment verification procedures prior to contracting with the vendors. Questioned costs: None. Context: For 2 of vendors we tested, the University did not maintain documentation to demonstrate that verification procedures were performed prior to contracting with the vendors. However, the University was able to subsequently verify that the vendors were not suspended or debarred. Cause: While the University has suspension and debarment procedures in place, they did not document that the check had been completed for these 2 vendors. Effect: If verification procedures are not performed in a timely manner, the University could enter into contracts with vendors who are suspended or debarred and risk noncompliance and/or disallowed costs. Repeat Finding: No. Recommendation: We recommend the University document suspension and debarment procedures going forward for any aggregate disbursements with vendors greater than $25,000. Views of responsible officials: There is no disagreement with the audit finding. Management has addressed their corrective action plan in a separately issued letter.
Assistance Listing Number, Federal Agency, and Program Name 20.205, U.S. Department of Transportation, Federal Highway Administration Highway Planning and Construction Federal Award Identification Number and Year CPG222, CPG23, CPG223, MT23, OZ23, OZ22, IC22, IC23, PC23, PC22, RS23, RS22 Pass through Entity Michigan Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Under Uniform Guidance 2 CFR 200.319(d), a non federal entity must have written procedures for procurement transactions. Further, under 2 CFR 200.320(c), 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 micropurchase threshold; 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 addition, under 2 CFR 200.318(h), the non federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. Further, the regulations under 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. Condition The Council did not have adequate controls in place to ensure compliance with the applicable procurement and suspension and debarment standards and its own internal procurement policy. Questioned Costs $125,000 Identification of How Questioned Costs Were Computed The questioned costs represent contracts entered into under noncompetitive procurement methods with opportunities for full and open competition and activity related to those contracts reported on the schedule of expenditures of federal awards for the period under audit. Context - During procurement testing, we noted two contracts over the Council's formal procurement threshold of $50,000 where the Council procured these services using noncompetitive methods. However, opportunities existed to procure services with full and open competition. Additionally, we noted six instances for which a check for suspension and debarment was not performed. The Council did perform the suspension and debarment check after we identified the noncompliance and noted that none of the six contractors were suspended or debarred; therefore, noting no questioned costs. Cause and Effect - Per review of the Council's financial management manual, we noted procurement guidelines for primary use vendors (those procured using noncompetitive methods) wer not clearly defined). Additionally, the Council's procurement guidelines are silent on services provided on an extended contract. Further, we noted a lack of controls surrounding chcks for suspension and debarment on primary use vendors. The lack of clarity within the Council's policies and procedures to align with procurement, suspension, and debarment resulted in the noncompliance. Recommendation - We recommend the Council update its policies and procedures to align with procurement, suspension, and debarment requirements under the Uniform Guidance. Views of Responsible Officials and Corrective Action Plan - Management has revised the financial management manual with an updated procurement policy in accordance with federal regulations. The Council has developed detailed procedures and required documentation for staff to ensure compliance. Mandatory training will be provided to staff that engage in purchasing activities.
Assistance Listing Number, Federal Agency, and Program Name 20.205, U.S. Department of Transportation, Federal Highway Administration Highway Planning and Construction Federal Award Identification Number and Year CPG222, CPG23, CPG223, MT23, OZ23, OZ22, IC22, IC23, PC23, PC22, RS23, RS22 Pass through Entity Michigan Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Under Uniform Guidance 2 CFR 200.319(d), a non federal entity must have written procedures for procurement transactions. Further, under 2 CFR 200.320(c), 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 micropurchase threshold; 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 addition, under 2 CFR 200.318(h), the non federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. Further, the regulations under 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. Condition The Council did not have adequate controls in place to ensure compliance with the applicable procurement and suspension and debarment standards and its own internal procurement policy. Questioned Costs $125,000 Identification of How Questioned Costs Were Computed The questioned costs represent contracts entered into under noncompetitive procurement methods with opportunities for full and open competition and activity related to those contracts reported on the schedule of expenditures of federal awards for the period under audit. Context - During procurement testing, we noted two contracts over the Council's formal procurement threshold of $50,000 where the Council procured these services using noncompetitive methods. However, opportunities existed to procure services with full and open competition. Additionally, we noted six instances for which a check for suspension and debarment was not performed. The Council did perform the suspension and debarment check after we identified the noncompliance and noted that none of the six contractors were suspended or debarred; therefore, noting no questioned costs. Cause and Effect - Per review of the Council's financial management manual, we noted procurement guidelines for primary use vendors (those procured using noncompetitive methods) wer not clearly defined). Additionally, the Council's procurement guidelines are silent on services provided on an extended contract. Further, we noted a lack of controls surrounding chcks for suspension and debarment on primary use vendors. The lack of clarity within the Council's policies and procedures to align with procurement, suspension, and debarment resulted in the noncompliance. Recommendation - We recommend the Council update its policies and procedures to align with procurement, suspension, and debarment requirements under the Uniform Guidance. Views of Responsible Officials and Corrective Action Plan - Management has revised the financial management manual with an updated procurement policy in accordance with federal regulations. The Council has developed detailed procedures and required documentation for staff to ensure compliance. Mandatory training will be provided to staff that engage in purchasing activities.
Assistance Listing Number, Federal Agency, and Program Name 20.205, U.S. Department of Transportation, Federal Highway Administration Highway Planning and Construction Federal Award Identification Number and Year CPG222, CPG23, CPG223, MT23, OZ23, OZ22, IC22, IC23, PC23, PC22, RS23, RS22 Pass through Entity Michigan Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Under Uniform Guidance 2 CFR 200.319(d), a non federal entity must have written procedures for procurement transactions. Further, under 2 CFR 200.320(c), 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 micropurchase threshold; 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 addition, under 2 CFR 200.318(h), the non federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. Further, the regulations under 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. Condition The Council did not have adequate controls in place to ensure compliance with the applicable procurement and suspension and debarment standards and its own internal procurement policy. Questioned Costs $125,000 Identification of How Questioned Costs Were Computed The questioned costs represent contracts entered into under noncompetitive procurement methods with opportunities for full and open competition and activity related to those contracts reported on the schedule of expenditures of federal awards for the period under audit. Context - During procurement testing, we noted two contracts over the Council's formal procurement threshold of $50,000 where the Council procured these services using noncompetitive methods. However, opportunities existed to procure services with full and open competition. Additionally, we noted six instances for which a check for suspension and debarment was not performed. The Council did perform the suspension and debarment check after we identified the noncompliance and noted that none of the six contractors were suspended or debarred; therefore, noting no questioned costs. Cause and Effect - Per review of the Council's financial management manual, we noted procurement guidelines for primary use vendors (those procured using noncompetitive methods) wer not clearly defined). Additionally, the Council's procurement guidelines are silent on services provided on an extended contract. Further, we noted a lack of controls surrounding chcks for suspension and debarment on primary use vendors. The lack of clarity within the Council's policies and procedures to align with procurement, suspension, and debarment resulted in the noncompliance. Recommendation - We recommend the Council update its policies and procedures to align with procurement, suspension, and debarment requirements under the Uniform Guidance. Views of Responsible Officials and Corrective Action Plan - Management has revised the financial management manual with an updated procurement policy in accordance with federal regulations. The Council has developed detailed procedures and required documentation for staff to ensure compliance. Mandatory training will be provided to staff that engage in purchasing activities.
Assistance Listing Number, Federal Agency, and Program Name 20.205, U.S. Department of Transportation, Federal Highway Administration Highway Planning and Construction Federal Award Identification Number and Year CPG222, CPG23, CPG223, MT23, OZ23, OZ22, IC22, IC23, PC23, PC22, RS23, RS22 Pass through Entity Michigan Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Under Uniform Guidance 2 CFR 200.319(d), a non federal entity must have written procedures for procurement transactions. Further, under 2 CFR 200.320(c), 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 micropurchase threshold; 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 addition, under 2 CFR 200.318(h), the non federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. Further, the regulations under 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. Condition The Council did not have adequate controls in place to ensure compliance with the applicable procurement and suspension and debarment standards and its own internal procurement policy. Questioned Costs $125,000 Identification of How Questioned Costs Were Computed The questioned costs represent contracts entered into under noncompetitive procurement methods with opportunities for full and open competition and activity related to those contracts reported on the schedule of expenditures of federal awards for the period under audit. Context - During procurement testing, we noted two contracts over the Council's formal procurement threshold of $50,000 where the Council procured these services using noncompetitive methods. However, opportunities existed to procure services with full and open competition. Additionally, we noted six instances for which a check for suspension and debarment was not performed. The Council did perform the suspension and debarment check after we identified the noncompliance and noted that none of the six contractors were suspended or debarred; therefore, noting no questioned costs. Cause and Effect - Per review of the Council's financial management manual, we noted procurement guidelines for primary use vendors (those procured using noncompetitive methods) wer not clearly defined). Additionally, the Council's procurement guidelines are silent on services provided on an extended contract. Further, we noted a lack of controls surrounding chcks for suspension and debarment on primary use vendors. The lack of clarity within the Council's policies and procedures to align with procurement, suspension, and debarment resulted in the noncompliance. Recommendation - We recommend the Council update its policies and procedures to align with procurement, suspension, and debarment requirements under the Uniform Guidance. Views of Responsible Officials and Corrective Action Plan - Management has revised the financial management manual with an updated procurement policy in accordance with federal regulations. The Council has developed detailed procedures and required documentation for staff to ensure compliance. Mandatory training will be provided to staff that engage in purchasing activities.
Assistance Listing Number, Federal Agency, and Program Name 20.205, U.S. Department of Transportation, Federal Highway Administration Highway Planning and Construction Federal Award Identification Number and Year CPG222, CPG23, CPG223, MT23, OZ23, OZ22, IC22, IC23, PC23, PC22, RS23, RS22 Pass through Entity Michigan Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Under Uniform Guidance 2 CFR 200.319(d), a non federal entity must have written procedures for procurement transactions. Further, under 2 CFR 200.320(c), 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 micropurchase threshold; 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 addition, under 2 CFR 200.318(h), the non federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. Further, the regulations under 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. Condition The Council did not have adequate controls in place to ensure compliance with the applicable procurement and suspension and debarment standards and its own internal procurement policy. Questioned Costs $125,000 Identification of How Questioned Costs Were Computed The questioned costs represent contracts entered into under noncompetitive procurement methods with opportunities for full and open competition and activity related to those contracts reported on the schedule of expenditures of federal awards for the period under audit. Context - During procurement testing, we noted two contracts over the Council's formal procurement threshold of $50,000 where the Council procured these services using noncompetitive methods. However, opportunities existed to procure services with full and open competition. Additionally, we noted six instances for which a check for suspension and debarment was not performed. The Council did perform the suspension and debarment check after we identified the noncompliance and noted that none of the six contractors were suspended or debarred; therefore, noting no questioned costs. Cause and Effect - Per review of the Council's financial management manual, we noted procurement guidelines for primary use vendors (those procured using noncompetitive methods) wer not clearly defined). Additionally, the Council's procurement guidelines are silent on services provided on an extended contract. Further, we noted a lack of controls surrounding chcks for suspension and debarment on primary use vendors. The lack of clarity within the Council's policies and procedures to align with procurement, suspension, and debarment resulted in the noncompliance. Recommendation - We recommend the Council update its policies and procedures to align with procurement, suspension, and debarment requirements under the Uniform Guidance. Views of Responsible Officials and Corrective Action Plan - Management has revised the financial management manual with an updated procurement policy in accordance with federal regulations. The Council has developed detailed procedures and required documentation for staff to ensure compliance. Mandatory training will be provided to staff that engage in purchasing activities.
Assistance Listing Number, Federal Agency, and Program Name 20.205, U.S. Department of Transportation, Federal Highway Administration Highway Planning and Construction Federal Award Identification Number and Year CPG222, CPG23, CPG223, MT23, OZ23, OZ22, IC22, IC23, PC23, PC22, RS23, RS22 Pass through Entity Michigan Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Under Uniform Guidance 2 CFR 200.319(d), a non federal entity must have written procedures for procurement transactions. Further, under 2 CFR 200.320(c), 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 micropurchase threshold; 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 addition, under 2 CFR 200.318(h), the non federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. Further, the regulations under 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. Condition The Council did not have adequate controls in place to ensure compliance with the applicable procurement and suspension and debarment standards and its own internal procurement policy. Questioned Costs $125,000 Identification of How Questioned Costs Were Computed The questioned costs represent contracts entered into under noncompetitive procurement methods with opportunities for full and open competition and activity related to those contracts reported on the schedule of expenditures of federal awards for the period under audit. Context - During procurement testing, we noted two contracts over the Council's formal procurement threshold of $50,000 where the Council procured these services using noncompetitive methods. However, opportunities existed to procure services with full and open competition. Additionally, we noted six instances for which a check for suspension and debarment was not performed. The Council did perform the suspension and debarment check after we identified the noncompliance and noted that none of the six contractors were suspended or debarred; therefore, noting no questioned costs. Cause and Effect - Per review of the Council's financial management manual, we noted procurement guidelines for primary use vendors (those procured using noncompetitive methods) wer not clearly defined). Additionally, the Council's procurement guidelines are silent on services provided on an extended contract. Further, we noted a lack of controls surrounding chcks for suspension and debarment on primary use vendors. The lack of clarity within the Council's policies and procedures to align with procurement, suspension, and debarment resulted in the noncompliance. Recommendation - We recommend the Council update its policies and procedures to align with procurement, suspension, and debarment requirements under the Uniform Guidance. Views of Responsible Officials and Corrective Action Plan - Management has revised the financial management manual with an updated procurement policy in accordance with federal regulations. The Council has developed detailed procedures and required documentation for staff to ensure compliance. Mandatory training will be provided to staff that engage in purchasing activities.
Assistance Listing Number, Federal Agency, and Program Name 20.205, U.S. Department of Transportation, Federal Highway Administration Highway Planning and Construction Federal Award Identification Number and Year CPG222, CPG23, CPG223, MT23, OZ23, OZ22, IC22, IC23, PC23, PC22, RS23, RS22 Pass through Entity Michigan Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Under Uniform Guidance 2 CFR 200.319(d), a non federal entity must have written procedures for procurement transactions. Further, under 2 CFR 200.320(c), 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 micropurchase threshold; 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 addition, under 2 CFR 200.318(h), the non federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. Further, the regulations under 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. Condition The Council did not have adequate controls in place to ensure compliance with the applicable procurement and suspension and debarment standards and its own internal procurement policy. Questioned Costs $125,000 Identification of How Questioned Costs Were Computed The questioned costs represent contracts entered into under noncompetitive procurement methods with opportunities for full and open competition and activity related to those contracts reported on the schedule of expenditures of federal awards for the period under audit. Context - During procurement testing, we noted two contracts over the Council's formal procurement threshold of $50,000 where the Council procured these services using noncompetitive methods. However, opportunities existed to procure services with full and open competition. Additionally, we noted six instances for which a check for suspension and debarment was not performed. The Council did perform the suspension and debarment check after we identified the noncompliance and noted that none of the six contractors were suspended or debarred; therefore, noting no questioned costs. Cause and Effect - Per review of the Council's financial management manual, we noted procurement guidelines for primary use vendors (those procured using noncompetitive methods) wer not clearly defined). Additionally, the Council's procurement guidelines are silent on services provided on an extended contract. Further, we noted a lack of controls surrounding chcks for suspension and debarment on primary use vendors. The lack of clarity within the Council's policies and procedures to align with procurement, suspension, and debarment resulted in the noncompliance. Recommendation - We recommend the Council update its policies and procedures to align with procurement, suspension, and debarment requirements under the Uniform Guidance. Views of Responsible Officials and Corrective Action Plan - Management has revised the financial management manual with an updated procurement policy in accordance with federal regulations. The Council has developed detailed procedures and required documentation for staff to ensure compliance. Mandatory training will be provided to staff that engage in purchasing activities.
Assistance Listing Number, Federal Agency, and Program Name 20.205, U.S. Department of Transportation, Federal Highway Administration Highway Planning and Construction Federal Award Identification Number and Year CPG222, CPG23, CPG223, MT23, OZ23, OZ22, IC22, IC23, PC23, PC22, RS23, RS22 Pass through Entity Michigan Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Under Uniform Guidance 2 CFR 200.319(d), a non federal entity must have written procedures for procurement transactions. Further, under 2 CFR 200.320(c), 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 micropurchase threshold; 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 addition, under 2 CFR 200.318(h), the non federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. Further, the regulations under 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. Condition The Council did not have adequate controls in place to ensure compliance with the applicable procurement and suspension and debarment standards and its own internal procurement policy. Questioned Costs $125,000 Identification of How Questioned Costs Were Computed The questioned costs represent contracts entered into under noncompetitive procurement methods with opportunities for full and open competition and activity related to those contracts reported on the schedule of expenditures of federal awards for the period under audit. Context - During procurement testing, we noted two contracts over the Council's formal procurement threshold of $50,000 where the Council procured these services using noncompetitive methods. However, opportunities existed to procure services with full and open competition. Additionally, we noted six instances for which a check for suspension and debarment was not performed. The Council did perform the suspension and debarment check after we identified the noncompliance and noted that none of the six contractors were suspended or debarred; therefore, noting no questioned costs. Cause and Effect - Per review of the Council's financial management manual, we noted procurement guidelines for primary use vendors (those procured using noncompetitive methods) wer not clearly defined). Additionally, the Council's procurement guidelines are silent on services provided on an extended contract. Further, we noted a lack of controls surrounding chcks for suspension and debarment on primary use vendors. The lack of clarity within the Council's policies and procedures to align with procurement, suspension, and debarment resulted in the noncompliance. Recommendation - We recommend the Council update its policies and procedures to align with procurement, suspension, and debarment requirements under the Uniform Guidance. Views of Responsible Officials and Corrective Action Plan - Management has revised the financial management manual with an updated procurement policy in accordance with federal regulations. The Council has developed detailed procedures and required documentation for staff to ensure compliance. Mandatory training will be provided to staff that engage in purchasing activities.
Assistance Listing Number, Federal Agency, and Program Name 20.205, U.S. Department of Transportation, Federal Highway Administration Highway Planning and Construction Federal Award Identification Number and Year CPG222, CPG23, CPG223, MT23, OZ23, OZ22, IC22, IC23, PC23, PC22, RS23, RS22 Pass through Entity Michigan Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Under Uniform Guidance 2 CFR 200.319(d), a non federal entity must have written procedures for procurement transactions. Further, under 2 CFR 200.320(c), 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 micropurchase threshold; 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 addition, under 2 CFR 200.318(h), the non federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. Further, the regulations under 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. Condition The Council did not have adequate controls in place to ensure compliance with the applicable procurement and suspension and debarment standards and its own internal procurement policy. Questioned Costs $125,000 Identification of How Questioned Costs Were Computed The questioned costs represent contracts entered into under noncompetitive procurement methods with opportunities for full and open competition and activity related to those contracts reported on the schedule of expenditures of federal awards for the period under audit. Context - During procurement testing, we noted two contracts over the Council's formal procurement threshold of $50,000 where the Council procured these services using noncompetitive methods. However, opportunities existed to procure services with full and open competition. Additionally, we noted six instances for which a check for suspension and debarment was not performed. The Council did perform the suspension and debarment check after we identified the noncompliance and noted that none of the six contractors were suspended or debarred; therefore, noting no questioned costs. Cause and Effect - Per review of the Council's financial management manual, we noted procurement guidelines for primary use vendors (those procured using noncompetitive methods) wer not clearly defined). Additionally, the Council's procurement guidelines are silent on services provided on an extended contract. Further, we noted a lack of controls surrounding chcks for suspension and debarment on primary use vendors. The lack of clarity within the Council's policies and procedures to align with procurement, suspension, and debarment resulted in the noncompliance. Recommendation - We recommend the Council update its policies and procedures to align with procurement, suspension, and debarment requirements under the Uniform Guidance. Views of Responsible Officials and Corrective Action Plan - Management has revised the financial management manual with an updated procurement policy in accordance with federal regulations. The Council has developed detailed procedures and required documentation for staff to ensure compliance. Mandatory training will be provided to staff that engage in purchasing activities.
Assistance Listing Number, Federal Agency, and Program Name 20.205, U.S. Department of Transportation, Federal Highway Administration Highway Planning and Construction Federal Award Identification Number and Year CPG222, CPG23, CPG223, MT23, OZ23, OZ22, IC22, IC23, PC23, PC22, RS23, RS22 Pass through Entity Michigan Department of Transportation Finding Type Material weakness and material noncompliance with laws and regulations Repeat Finding No Criteria Under Uniform Guidance 2 CFR 200.319(d), a non federal entity must have written procedures for procurement transactions. Further, under 2 CFR 200.320(c), 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 micropurchase threshold; 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 addition, under 2 CFR 200.318(h), the non federal entity must award contracts only to responsible contractors possessing the ability to perform successfully under the terms and conditions of a proposed procurement. Consideration will be given to such matters as contractor integrity, compliance with public policy, record of past performance, and financial and technical resources. Further, the regulations under 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. Condition The Council did not have adequate controls in place to ensure compliance with the applicable procurement and suspension and debarment standards and its own internal procurement policy. Questioned Costs $125,000 Identification of How Questioned Costs Were Computed The questioned costs represent contracts entered into under noncompetitive procurement methods with opportunities for full and open competition and activity related to those contracts reported on the schedule of expenditures of federal awards for the period under audit. Context - During procurement testing, we noted two contracts over the Council's formal procurement threshold of $50,000 where the Council procured these services using noncompetitive methods. However, opportunities existed to procure services with full and open competition. Additionally, we noted six instances for which a check for suspension and debarment was not performed. The Council did perform the suspension and debarment check after we identified the noncompliance and noted that none of the six contractors were suspended or debarred; therefore, noting no questioned costs. Cause and Effect - Per review of the Council's financial management manual, we noted procurement guidelines for primary use vendors (those procured using noncompetitive methods) wer not clearly defined). Additionally, the Council's procurement guidelines are silent on services provided on an extended contract. Further, we noted a lack of controls surrounding chcks for suspension and debarment on primary use vendors. The lack of clarity within the Council's policies and procedures to align with procurement, suspension, and debarment resulted in the noncompliance. Recommendation - We recommend the Council update its policies and procedures to align with procurement, suspension, and debarment requirements under the Uniform Guidance. Views of Responsible Officials and Corrective Action Plan - Management has revised the financial management manual with an updated procurement policy in accordance with federal regulations. The Council has developed detailed procedures and required documentation for staff to ensure compliance. Mandatory training will be provided to staff that engage in purchasing activities.