2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023 – 025 – Procurement Policy Federal Agency: Various Federal Program Name: Research and Development Cluster Assistance Listing Number: Various Federal Award Identification Number and Year: Various Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Uniform guidance requires auditees to follow procurement standards set forth. sections of the Uniform Guidance set forth five permissible procurement methods for non-Federal entities expending Federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match requirements of the Uniform Guidance. Questioned costs: None. Context: The University's procurement policy does not currently match requirements of the Uniform Guidance related to defining the required levels of procurement and when competitive bids are required. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: No. Recommendation: We recommend the University review its procurement policy to insure it meets federal regulations. Views of responsible officials: There is no disagreement with the audit finding.
2023-007 – Procurement, Small Purchases (Significant Deficiency in Internal Controls over Compliance, Questioned Costs Greater than $25k) Federal Program Information Federal Award Title and ALN: Research & Development Cluster, 84.031 Federal Awarding Agency: U.S. Department of Education Federal Award ID Number: P031S210288, P031C200002 Federal Award Year: 2023 Condition: During our review of procurement testing, the College did not follow small purchase procedures and obtain quotes to ensure the vendor with the lowest price was used for one sample. Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Per 2 CFR 200.318(i), non-federal entities must retain documentation sufficient to detail the history of procurement decisions. Cause: The College did not obtain three quotes prior to using vendor for a purchase. Effect: The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Questioned Costs: Known and likely questioned costs of $32,607 Auditor recommendation: We recommend the College strengthen controls to ensure purchasing policies and procedures are being followed and train staff in the purchasing department to comply with all relevant federal procurement requirements.
2023-007 – Procurement, Small Purchases (Significant Deficiency in Internal Controls over Compliance, Questioned Costs Greater than $25k) Federal Program Information Federal Award Title and ALN: Research & Development Cluster, 84.031 Federal Awarding Agency: U.S. Department of Education Federal Award ID Number: P031S210288, P031C200002 Federal Award Year: 2023 Condition: During our review of procurement testing, the College did not follow small purchase procedures and obtain quotes to ensure the vendor with the lowest price was used for one sample. Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Per 2 CFR 200.318(i), non-federal entities must retain documentation sufficient to detail the history of procurement decisions. Cause: The College did not obtain three quotes prior to using vendor for a purchase. Effect: The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Questioned Costs: Known and likely questioned costs of $32,607 Auditor recommendation: We recommend the College strengthen controls to ensure purchasing policies and procedures are being followed and train staff in the purchasing department to comply with all relevant federal procurement requirements.
2023-007 – Procurement, Small Purchases (Significant Deficiency in Internal Controls over Compliance, Questioned Costs Greater than $25k) Federal Program Information Federal Award Title and ALN: Research & Development Cluster, 84.031 Federal Awarding Agency: U.S. Department of Education Federal Award ID Number: P031S210288, P031C200002 Federal Award Year: 2023 Condition: During our review of procurement testing, the College did not follow small purchase procedures and obtain quotes to ensure the vendor with the lowest price was used for one sample. Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Per 2 CFR 200.318(i), non-federal entities must retain documentation sufficient to detail the history of procurement decisions. Cause: The College did not obtain three quotes prior to using vendor for a purchase. Effect: The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Questioned Costs: Known and likely questioned costs of $32,607 Auditor recommendation: We recommend the College strengthen controls to ensure purchasing policies and procedures are being followed and train staff in the purchasing department to comply with all relevant federal procurement requirements.
2023-007 – Procurement, Small Purchases (Significant Deficiency in Internal Controls over Compliance, Questioned Costs Greater than $25k) Federal Program Information Federal Award Title and ALN: Research & Development Cluster, 84.031 Federal Awarding Agency: U.S. Department of Education Federal Award ID Number: P031S210288, P031C200002 Federal Award Year: 2023 Condition: During our review of procurement testing, the College did not follow small purchase procedures and obtain quotes to ensure the vendor with the lowest price was used for one sample. Criteria: Per 2 CFR 200.303(a), the non-federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Per 2 CFR 200.318(i), non-federal entities must retain documentation sufficient to detail the history of procurement decisions. Cause: The College did not obtain three quotes prior to using vendor for a purchase. Effect: The College may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Questioned Costs: Known and likely questioned costs of $32,607 Auditor recommendation: We recommend the College strengthen controls to ensure purchasing policies and procedures are being followed and train staff in the purchasing department to comply with all relevant federal procurement requirements.
Criteria: The acquisition of property or services which is higher than the micro-purchase threshold ($10,000 at the time of the grant in question) but does not exceed the simplified acquisition threshold ($250,000 established in the FAR) must follow small purchase procedures. Small purchase procedures include price or rate quotations obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. Additionally, the non-Federal entity may select noncompetitive procurement as their procurement method but must meet one of the five mentioned circumstances in 2 CFR 200.320(c). Lastly, general procurement standards must be followed. Questioned Costs: None. Repeat finding: The same finding was reported during the program specific audit as of and for the year ended December 31, 2022 as 2022-001. Recommendation: We recommend that the Organization adopt a procurement procedure in compliance with 2 CFR and ensure they have a full understanding of the required procurement policy. Views of Responsible Officials: A procurement procedure has since been adopted and approved by the Board. The Executive Director will ensure that all future purchases comply with 2 CFR. Condition: During our audit, certain grant expenditures with subcontractors, exceeding $10,000, were tested for which the Organization did not obtain quotes for. Cause: The Organization did not obtain quotes from subcontractors that were included in a contractor’s original bid. The Organization ultimately paid the subcontractors directly. Effect: The Organization did not adequately comply with 2 CFR 200.320. Non-compliance could lead to additional compliance concerns and questioned costs.
Reference Number: 2023-002 United States Department of Agriculture Federal Assistance Listing Number & Program Name: 10.553 & 10.555 Child Nutrition Cluster Description: Procurement Criteria: 2 CFR 200.320 Methods of Procurement state that if the Sealed Bids method is used - This is a procurement method in which bids are publicly solicited through an invitation and a firm fixed-price contract (lump sum or unit price) is awarded to the responsible bidder whose bid conforms to all the material terms and conditions of the invitation and is the lowest in price. The Organization’s procurement policy also states that purchases ranging from >$100,000 require a minimum of three written bids. Condition: During our testing of procurement transactions, we totaled purchases from one vendor above $100,000 in purchases had no price quotes as required by the Organization’s procurement policy. Cause: The Organization did not follow their Federal Funds Procurement policy related to the appropriate methods of procurement. Effect: Obtaining price quotes or proposals from an adequate number of vendors allows the Organization to use federal funds in the most fiscally responsible way. The lack of quotes and proposals may cause the Organization to overpay for supplies or services. Auditors’ Recommendation: We recommend the Organization review their procurement policy and adhere to current policy for going out for the minimum amount of bids on required vendors. Corrective Action Plan: See attachment for Organization’s corrective action plan.
2023-002 – Procurement and Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program: Arts in Education Federal Assistance Listing Number: 84.351 Pass-through Entity: Not applicable. Award Identification Number: S351A210115 and U351D180067 Year: 2022 and 2023 Criteria: 2 CFR §200.320(b) requires that for purchases exceeding the micro-purchase threshold, price or rate quotations must be obtained from an adequate number of qualified sources. If a noncompetitive (single-source) procurement is used, the entity must document the justification in accordance with 2 CFR §200.320(c). Condition: During testing, we identified two vendors with transactions exceeding the micro-purchase threshold. For one vendor, the Organization did not obtain competitive price or rate quotations, and for the other, the Organization did not document a valid single-source justification. Context: The procurement transactions reviewed represented the entire population of expenditures exceeding the micro-purchase threshold during the period. In both cases, the documentation did not align with competitive procurement requirements. Given that all transactions in the population were affected, this indicates an area where compliance practices could be strengthened. Cause: Although the Organization has a formal procurement policy outlining requirements for competitive quotes and single-source justifications in accordance with 2 CFR §200.320, these procedures were not followed for the transactions tested. Effect: Failure to obtain competitive quotes or document single-source justifications increases the risk of noncompliance with federal procurement requirements and may result in unallowable costs being charged to the federal program. Questioned Costs: Known questioned costs total $163,818, representing the federal share of the transactions where procurement requirements were not met. Repeat Finding: No Recommendation: We recommend the Organization ensure that its procurement policy is fully implemented. Staff should be trained and held accountable for obtaining competitive price or rate quotations for all purchases exceeding the micro-purchase threshold, or for documenting appropriate single-source justifications when applicable. Views of Responsible Officials: See Corrective Action Plan.
U.S. Department of Health and Human Services Leading Edge Acceleration Projects (LEAP) in Health Information Technology - 93.345 Award #90AX0034/01-00 Criteria or Specific Requirement – Procurement and Suspension and Debarment In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non-competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR Section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition – The Organization's Procurement Policy and Procedure is not in alignment with the requirements of 2 CFR Section 200.320. The policy does not document different procurement methods for various levels of purchases nor does it outline guidance on what are acceptable procurement methods, documentation to be retained, etc. Additionally, formalized documentation supporting the Organization is in compliance with policies and regulations supporting its procurement decisions did not exist. Lastly, there was no suspension and debarment check completed prior to purchases made with federal funds. Cause – The Organization's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds. Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred. Questioned Costs – Total questioned costs of $233,700 was identified and represents the value of reimbursements submitted for contracted services under one agreement which the procurement process could not be supported in line with the Uniform Guidance. Context – One purchase of $233,700 out of a total of multiple purchases totaling $239,391 subject to procurement requirements in 2023 was selected for testing. The Organization could not provide documentation supporting their purchase adhered to requirements for formal procurement or noncompetitive procurement outside of a general budget approval from the grantor. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. Identification as a Repeat Finding, if applicable – Not applicable Recommendation – Policies and procedures should be modified to ensure that procurement policies are in alignment with federal regulations, support for procurement decisions are maintained and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements. Views of Responsible Official and Planned Corrective Actions – Management agrees with finding. See corrective action plan.
Condition: Upon inquiry of county personnel and a test of fifteen (15) disbursements totaling $810,215, the following instances of noncompliance were noted: • The County failed to document suspension and debarment of vendors for purchases over $25,000. • The County failed to have written standards of conduct that cover conflicts of interest and that govern the performance of its employees engaged in the selection, award, and administration of contract. Cause of Condition: Policies and procedures have not been designed and implemented to ensure federal disbursements are made in accordance with federal compliance requirements. Effect of Condition: This condition resulted in noncompliance with grant requirements and could result in a loss of federal funds. Recommendation: OSAI recommends the County gain an understanding of the grant requirements for this program and implement internal controls to ensure compliance with these grant requirements. Management Response: Chairman of the Board of County Commissioners: These procurement issues originated during the prior County Clerk’s administration, but the current leadership is focused on corrective measures. Together, we are: • developing a SOP to ensure vendor checks for suspension and debarment are conducted on all purchases over $25,000, • establishing written standards of conduct to address conflicts of interest and set clear procurement guidelines, • and enhancing oversight and review to ensure all procurement processes are fully compliant with federal regulations. Our goal is to build a consistent, transparent procurement framework that safeguards both compliance and public trust. County Clerk: I was not the County Clerk in office at this time. To correct this issue, the County plans to develop a SOP to timely and accurately track and report on the SEFA. The SOP will be reviewed, adopted, and monitored by the Board of County Commissioners. Criteria: Compliance and Reporting Guidance, State and Local Fiscal Recovery Funds (8. Procurement, Suspension & Debarment.) reads as follows: Recipients are responsible for ensuring that any procurement using SLFRF funds, or payments under procurement contracts using such funds, are consistent with the procurement standards set forth in the Uniform Guidance at 2 CFR 200.317 through 2 CFR 200.327, unless stated otherwise by Treasury. As outlined in FAQ 13.15, only a subset of the Uniform Guidance requirements at 2 CFR Part 200 Subpart D (Post Federal Award Requirements) applies to recipients’ use of funds in the revenue loss eligible use category. The procurement standards set forth in the Uniform Guidance at 2 CRF 200.317 through 2 CRF 200.327 are not included in FAQ 13.15’s list of applicable Subpart D requirements that apply to recipients’ use of funds in the revenue loss eligible use category. The Uniform Guidance establishes in 2 CFR 200.319 that all procurement transactions for property or services must be conducted in a manner providing full and open competition, consistent with standards outlined in 2 CFR 200.320, which allows for non-competitive procurements only in certain circumstances. Recipients must have and use documented procurement procedures that are consistent with the standards outlined in 2 CFR 200.317 through 2 CFR 200.320. In addition, the Uniform Guidance at 2 CFR 200.214, 2 CFR Part 180, and Treasury’s implementing regulations at 31 CFR Part 19, prohibit recipients from entering into contracts with suspended or debarred parties. The procurement standards outlined in the Uniform Guidance require an infrastructure for competitive bidding and contractor oversight, including maintaining written standards of conduct. Your organization must ensure adherence to all applicable local, State, and federal procurement laws and regulations. Further, 2 CFR § 200.319 Competition (d) reads as follows: The non-Federal entity must have written procedures for procurement transactions.
FA 2023-001 Improve/Strengthen Controls over Expenditures Compliance Requirements: Activities Allowed or Unallowed Allowable Costs/Cost Principles Period of Performance Procurement and Suspension and Debarment Internal Control Impact: Material Weakness Compliance Impact: Material Noncompliance Federal Awarding Agency: U.S. Department of Education Pass-Through Entity: Georgia Department of Education Assistance Listing Number and Title: 84.371C – Comprehensive Literacy Development Federal Award Number: S371C190016-19A (Years: 2017-21) Questioned Costs: $124,399.84 Repeat of Prior Year Finding: FA 2022-002 Description: A review of expenditures and journal entries related to the Comprehensive Literacy Development program revealed that the School District’s internal control procedures were not operating to ensure that appropriate reviews and approvals occurred and the School District’s procurement procedures were followed. Background Information: The Comprehensive Literacy Development Program (CLD) was authorized under Sections 2222-2225 of the Elementary and Secondary Education Act of 1965 to create a comprehensive literacy program to advance literacy skills, including pre-literacy skills, reading, and writing, for children from birth to grade 12, with an emphasis on disadvantaged children, including children living in poverty, English learners, and children with disabilities. CLD funding was granted to the Georgia Department of Education (GaDOE) by the U.S. Department of Education (ED). GaDOE is responsible for distributing funds to local educational agencies (LEAs) and overseeing the expenditure of funds by LEAs. CLD funds totaling $802,825.69 were expended and reported on the Burke County Board of Education’s Schedule of Expenditures of Federal Awards (SEFA) for fiscal year 2023. Criteria: As a recipient of federal awards, the School District is required to establish and maintain effective internal control over federal awards that provides reasonable assurance of managing the federal awards in compliance with federal statutes, regulations, and the terms and conditions of the federal awards pursuant to Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), Section 200.303 – Internal Controls. Provisions included in the Uniform Guidance, Section 200.403 – Factors Affecting Allowability of Costs state that “costs must meet the following general criteria in order to be allowable under Federal awards: (a) Be necessary and reasonable for the performance of the Federal award and be allocable thereto under these principles, (b) Conform to any limitations or exclusions set forth in these principles or in the Federal award as to types or amount of cost items, (c) Be consistent with policies and procedures that apply uniformly to both federally-financed and other activities of the non-Federal entity… (g) Be adequately documented, (h) Cost must be incurred during the approved budget period…” Additionally, provisions included in the Uniform Guidance, Section 200.318 – General Procurement Standards state in part that “(a) the non-Federal entity must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations and… (b) non-Federal entities must maintain oversight to ensure that contractors perform in accordance with the terms, conditions, and specifications of their contracts or purchase orders.” In addition, provisions included in the Uniform Guidance, Section 200.320 – Methods of Procurement to Be Followed provide guidance for procurement through small purchase procedures and state “If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources.” Condition: Auditors performed a review of various expenditure activity associated with the CLD program to determine if appropriate internal controls were implemented and applicable compliance requirements were met. The following deficiencies were identified: • A sample of 60 expenditures was randomly selected for testing using a non-statistical sampling approach. Evidence of review and approval was not reflected for 11 expenditures, and adequate evidence of receipt was not maintained for 14 expenditures. • A sample of two journal entries was randomly selected for testing using a non-statistical sampling approach. Evidence of review to ensure that the activity was allowable and occurred during the period of performance was not reflected for either journal entry tested. • A sample of 43 procurement transactions was randomly selected for testing using a nonstatistical sampling approach. Four procurement transactions did not reflect evidence of supervisory review and approval, and the School District could not provide evidence that an adequate number of rate or price quotations were obtained from qualified sources for 13 small purchase procurements reviewed. Questioned Costs: Upon testing a sample of $157,184.97 in procurement transactions, known questioned costs of $124,399.84 were identified for expenditures that did not follow the School District’s procurement procedures. Using the total population of $743,095.26 in procurement transactions, we project the likely questioned costs to be approximately $588,102.87. Cause: The School District did not maintain evidence of review and approval of expenditures, journal entries, and procurement transactions as a result of oversight. Small purchase procurement transactions did not follow the School District’s procurement policy because the Federal Programs Directors was unaware that it was necessary to follow these procedures for the purchase of instructional materials. Effect or Potential Effect: The School District is not in compliance with the Uniform Guidance and GaDOE guidance. Failure to review expenditures for allowability, and journal entries for allowability and period of performance compliance exposes the School District to unnecessary risk of error and misuse of federal funds. In addition, failure to appropriately follow applicable procurement procedures exposes the School District to unnecessary risk of error and misuse of federal funds. Lastly, this deficiency could lead to the return of grant funds associated with unallowable expenditures. Recommendation: The School District should review current internal control procedures related to the CLD program. Where vulnerable, the School District should develop and/or modify its policies and procedures to ensure that all expenditures, journal entries, and procurement transactions reflect evidence of review for associated compliance requirements. In addition, expenditure voucher packages should contain all required components. Furthermore, the School District should evaluate and improve internal control procedures to ensure that required procurement methods are properly identified and followed and required procurement documentation is properly identified, safeguarded, and retained. Management should develop a monitoring process to ensure that these procedures are operating appropriately. Views of Responsible Officials: We concur with this finding. The finding states evidence of review and approval was not reflected for 11 expenditures. While 11 invoices were not approved by the Director in charge of the grant, 10 were approved by the building level Principal or Central Office Director and the Superintendent, and 1 was approved by the Superintendent. Additionally, all expenditures charged to the grant were submitted to the Georgia Department of Education for review and approval for reimbursement of expenditures. All expenditures were approved and reimbursed. The finding states adequate evidence of receipt was not maintained for 14 expenditures. While packing slips weren’t provided for 14 voucher packages, 13 of the packages were reviewed and approved for payment by the Director in charge of the grant, and 1 was approved by the Principal and Superintendent. Approval for payment isn’t granted unless items are received. The finding states evidence of review to ensure that the activity was allowable and occurred during the period of performance was not reflected for 2 journal entries. The journal entry to record indirect costs in the amount of $3,572 did not exceed the indirect costs budgeted amount of $20,000 included in the grant budget submitted by the School District and approved by the Georgia Department of Education. While not approved by the Director in charge of the grant, the journal entry was accurate and properly recorded indirect costs. Additionally, the journal entry was submitted to the Georgia Department of Education for review and approval for reimbursement of expenditures. As stated above, all expenditures were approved and reimbursed. The journal entry to reverse salary and benefit accruals is an annual, standard journal entry utilized for operational efficiency and best practice to reverse salary and benefit accruals that are required under Generally Accepted Accounting Principles. While not approved by the Director in charge of the grant, the journal entry was appropriate and necessary to ensure expenditures were accurately recorded in the proper accounting period and only included reversals related to personnel the Director approved to be paid from the grant. The finding states 3 procurement transactions did not reflect evidence of supervisory review and approval. While 3 transactions included invoices that were not approved by the Director in charge of the grant, 2 invoices were approved by the building level Principal and the Superintendent, and 1 was approved by the Superintendent. All 3 of the transactions included purchase orders that were properly approved by the Director in charge of the grant. Auditor’s Concluding Remarks: Under the Uniform Guidance, auditees are required to implement internal controls over federal awards. Upon completing procedures over internal controls associated with the Activities Allowed or Unallowed, Allowable Costs/Cost Principles, Period of Performance, and Procurement and Suspension and Debarment compliance requirements, auditors obtained an understanding of internal controls put in place and subsequently tested those controls. Auditors noted that the internal controls described by the School District were not in place for the transactions identified. Based on this information, we reaffirm our finding and will review the status of the finding during our next audit.
Material Weakness Finding No. 2023-003: Procurement Policies U.S. Department of Education Native Hawaiian Education Act Program Federal Assistance Listing Number 84.362A. U.S. Department of Health and Human Services Health Care for Native Hawaiians Federal Assistance Listing Number 93.932. Criteria The Uniform Guidance 2 CFR §200.320 sets forth the methods of procurement to be followed in the acquisition of property or services required under a Federal award or subaward, which includes formal purchase methods such as proposal or bids when the value of the property or services under a Federal financial assistance award exceeds a certain threshold, as defined. Furthermore, 2 CFR §200.320(c) provides specific circumstances in which noncompetitive procurement can be used. Condition During our audit, we noted that the Organization made subawards to entities which were subject to a formal purchase method, for which competitive processes for selection were not performed, nor was documentation of the specific criteria of 2 CFR §200.320(c) met to support noncompetitive procurements maintained. Cause Management had not updated its policies and procedures to incorporate certain pertinent sections of the procurement standards of the Uniform Guidance. Effect The lack of procurement standards in accordance with the Uniform Guidance may result in allowable cost issues. Identification of a Repeat Finding This finding was reported as a federal award finding in the immediately previous audit as Finding No. 2022-003. Recommendation We recommend that the Organization incorporate the procurement standards of the Uniform Guidance to its policies and procedures manual to ensure compliance with Federal standards, including 2 CFR §200.318(h) which stipulates that sufficient detail of the history of the procurement must be maintained, including the selection of the contractor.
Revise Written Policies and Develop Procedures over Administration of Federal Grants Federal Agency: U.S. Department of Education Pass-through Agency: New Hampshire Department of Education Program: Elementary and Secondary School Emergency Relief Fund Assistance Listing Number: 84.425 Compliance Requirements: Activities Allowed or Unallowed; Allowable Costs/Cost Principles; Equipment Management; and Procurement, Suspension and Debarment Criteria: The Uniform Guidance requires nonfederal entities that receive federal awards to establish written policies and procedures as described in the following sections: • Time and effort (2 CFR 200.431) • Equipment (2 CFR 200.313) • General procurement standards (2 CFR 200.318) • Competition (2 CFR 200.319) • Methods of procurement to be followed (2 CFR 200.320) Condition: The School District did not have procedures to comply with its written policies relative to federal awards as required by the Uniform Guidance. Cause: The School District was not aware of these compliance requirements. Effect: The School District is not in compliance with the Uniform Guidance with respect to these written policies. Recommendation: We recommend that the School District update its policies and procedures to comply with the Uniform Guidance requirements stated above. Management’s Response: Management agrees with the finding.
Assistance Listing Number 93.576, Refugee and Entrant Assistance Discretionary Grants, U.S. Department of Health and Human Services, FAIN 90RP0121, Award Year 2023, Passed Through by the United States Conference of Catholic Bishops Criteria or Specific Requirement – Procurement, Suspension, and Debarment – 2 CFR § 200.317–.327; 2 CFR § 200.214 Condition – Catholic Charities is required to have and use documented procurement procedures, consistent with federal, state, and local laws and regulations, for the acquisition of property and services required under a federal award or subaward and for determining an entity is not suspended or debarred before entering into a covered transaction. Additionally, Catholic Charities is required to maintain support that documents the full history of procurement transactions. Cause – Catholic Charities’ procurement procedures are not tailored to include considerations of the Uniform Guidance, including methods of procurement to be followed, the thresholds at which certain procedures are necessary, provisions regarding conflicts of interests, procedures to ensure vendors are not debarred or suspended from participation in federal assistance programs or activities, and maintenance of documentation related to procurement transactions. Effect – Catholic Charities’ procurements were not conducted in accordance with federal laws and regulations, and Catholic Charities’ procurement policy does not meet federal requirements. In addition, the entity did not have a policy to check suspension and debarment for contracts using federal awards. Questioned Costs – None Context – Two purchases exceeded the small purchase threshold for this program during 2023, one of which was also above the simplified acquisition threshold. Neither had documentation supporting price or rate quotations, and neither had documentation that procedures were performed to ensure vendors were not debarred, suspended, or otherwise excluded from participation in federal assistance programs or activities. Identification as a Repeat Finding, if applicable – N/A Recommendation – Catholic Charities should revise its procurement policy to ensure procurements are conducted in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions – Management concurs with the finding, and changes to Catholic Charities’ procurement policy are being considered. Catholic Charities performed a retroactive review of both procurements and determined that they both would have qualified as noncompetitive procurements under 2 CFR § 200.320(c) due to both the specialized nature of the services provided and the public exigency presented by the nature of the Afghan refugee program. Management also determined that the lack of documentation related to these transactions is in part related to significant turnover occurring since this program was active.
CRITERIA: Under the Uniform Guidance, specifically 2 CFR 200.320, an organization must have and use documented procurement procedures. This includes a requirement to maintain the procurement documents. CONDITION: Formal documentation of the procurement process was unavailable for certain vendors. Management was able to provide a list of which contractors were considered for the project. CONTEXT: The Organization has undertaken several construction projects under California's Project HomeKey program, which includes Federal funds. The HomeKey program was intended to rapidly convert motels into permanent housing and management was required to select and engage architects and contractors quickly. EFFECT OR POTENTIAL EFFECT: Management was unable to produce documentation of selection of one of its general contractors. QUESTIONED COST: None RECOMMENDATION: Management was unable to produce documentation of selection of one of its general contractors. VIEWS OF RESPONSIBLE OFFICIALS: Management should revise its documentation system to allow for centralized and accessible storage of support for its vendor procurement process.
Federal Agency: U.S. Department of Health and Human Services Federal Program Name: Grants for New and Expanded Services Under the Health Center Program Assistance Listing Number: 93.224/93.527 Federal Award Identification Number: L2C42352-01-00; Award Periods: July 1, 2021 – June 30, 2023; Type of Finding: Material weakness in internal control over compliance Criteria: 2 CFR section 200.320 outlines the acceptable methods of procurement. Purchases below the simplified acquisition threshold, but above the micro-purchase threshold, require price or rate quotations to be obtained from an adequate number of qualified sources. Noncompetitive procurement can be used in certain circumstances however the non-Federal entity is to maintain appropriate documentation justifying the use of sole source procurement consistent with 2 CFR 200.320(c). Condition: Legacy did not maintain appropriate documentation to support the procurement method utilized for procurements selected for testing. Questioned Costs: Unknown. Context: Five (5) of five (5) procurement transactions selected for testing. Cause: Legacy did not maintain appropriate documentation based on the method of procurement utilized. Effect: Legacy may inadvertently select vendors without regard to fair competition and cost analysis. Repeat Finding: Yes. Prior Year Finding: 2022-002. Recommendation: We recommend Legacy consistently follow its established policies and procedures related to maintaining necessary documentation to support the method of procurement utilized. Legacy may also consider qualifying multiple vendors for particular goods/service and then utilizing an approved vendors list. Views of Responsible Officials: There is no disagreement with the audit finding.