2023-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, F, G) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: 20-02-HDH-EHA-001, E-22-MC-35-0001 Award Period: July 1, 2022 – June 30, 2023 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement, suspension and debarment regulations or its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled two (out of a population of two) vendors who received more than $10,000 in fiscal year 2023 and noted no evidence of obtaining bids or quotes. Additionally, adequate sole source documentation was absent to support the procurement. • We sampled two (out of a population of two) vendors for tests of internal control over compliance and noted that Heading Home did not provide evidence of internal controls regarding suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for purchases exceeding $10,000, three (3) written competitive bids must be obtained before selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2023) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2023). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and the non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provide reasonable assurance that Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you entering into a covered transaction with another person at the next lower tier, you must verify that the person you intend to conduct business with is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home has not followed its policies and procedures related to procurement. Additionally, the procurement policy does not include the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with its policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors, exposing itself to potential liability and the risk of losing federal funds. Recommendation We recommend Heading Home follow its internal control policies and procedures related to procurement, as well as the following: • Document controls such as including the procurement files include proof of SAM.gov verification to ensure compliance with federal procurement regulations and internal procurement policy. • Implement policies and procedures to verify contractor suspension or debarment status before awarding contracts using federal funds. • Include the required suspension and debarment clause in contracts with federally funded contractors. View of Responsible Official and Corrective Action Plan Heading Home management agrees with this finding. Management has reviewed existing procurement policies and procedures found in Section III Policy #301 of Heading Home’s fiscal policies and procedures with appropriate staff and will enforce policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff, and which require vendors to be reviewed on the SAM website, to ensure they have not been suspended or debarred. Although this review was conducted after the fact, each of the five vendors noted in this finding has since been reviewed on the SAM website, and none of them returned a notice of suspension or debarment. Management is in the process of reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement, as well as for those anticipated to meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management reviewed the above mentioned vendors and noted none of them were suspended or debarred. Circumstantial evidence consisting of emails leads the organization to believe bids/quotes were in fact solicited but the actual procurement packets could not be located due to the extensive turnover in management during 2023. Management anticipates the above corrective action plan will be fully implemented by September 30, 2025. The personnel responsible for overseeing implementation include Connie Chavez, Chief Executive Officer; Debbie Brickman, Chief Financial Officer; and Armando Sanchez, contract accountant team lead.
2023-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, F, G) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: 20-02-HDH-EHA-001, E-22-MC-35-0001 Award Period: July 1, 2022 – June 30, 2023 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement, suspension and debarment regulations or its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled two (out of a population of two) vendors who received more than $10,000 in fiscal year 2023 and noted no evidence of obtaining bids or quotes. Additionally, adequate sole source documentation was absent to support the procurement. • We sampled two (out of a population of two) vendors for tests of internal control over compliance and noted that Heading Home did not provide evidence of internal controls regarding suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for purchases exceeding $10,000, three (3) written competitive bids must be obtained before selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2023) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2023). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and the non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provide reasonable assurance that Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you entering into a covered transaction with another person at the next lower tier, you must verify that the person you intend to conduct business with is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home has not followed its policies and procedures related to procurement. Additionally, the procurement policy does not include the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with its policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors, exposing itself to potential liability and the risk of losing federal funds. Recommendation We recommend Heading Home follow its internal control policies and procedures related to procurement, as well as the following: • Document controls such as including the procurement files include proof of SAM.gov verification to ensure compliance with federal procurement regulations and internal procurement policy. • Implement policies and procedures to verify contractor suspension or debarment status before awarding contracts using federal funds. • Include the required suspension and debarment clause in contracts with federally funded contractors. View of Responsible Official and Corrective Action Plan Heading Home management agrees with this finding. Management has reviewed existing procurement policies and procedures found in Section III Policy #301 of Heading Home’s fiscal policies and procedures with appropriate staff and will enforce policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff, and which require vendors to be reviewed on the SAM website, to ensure they have not been suspended or debarred. Although this review was conducted after the fact, each of the five vendors noted in this finding has since been reviewed on the SAM website, and none of them returned a notice of suspension or debarment. Management is in the process of reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement, as well as for those anticipated to meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management reviewed the above mentioned vendors and noted none of them were suspended or debarred. Circumstantial evidence consisting of emails leads the organization to believe bids/quotes were in fact solicited but the actual procurement packets could not be located due to the extensive turnover in management during 2023. Management anticipates the above corrective action plan will be fully implemented by September 30, 2025. The personnel responsible for overseeing implementation include Connie Chavez, Chief Executive Officer; Debbie Brickman, Chief Financial Officer; and Armando Sanchez, contract accountant team lead.
2023-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, F, G) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: 20-02-HDH-EHA-001, E-22-MC-35-0001 Award Period: July 1, 2022 – June 30, 2023 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement, suspension and debarment regulations or its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled two (out of a population of two) vendors who received more than $10,000 in fiscal year 2023 and noted no evidence of obtaining bids or quotes. Additionally, adequate sole source documentation was absent to support the procurement. • We sampled two (out of a population of two) vendors for tests of internal control over compliance and noted that Heading Home did not provide evidence of internal controls regarding suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for purchases exceeding $10,000, three (3) written competitive bids must be obtained before selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2023) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2023). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and the non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provide reasonable assurance that Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you entering into a covered transaction with another person at the next lower tier, you must verify that the person you intend to conduct business with is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home has not followed its policies and procedures related to procurement. Additionally, the procurement policy does not include the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with its policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors, exposing itself to potential liability and the risk of losing federal funds. Recommendation We recommend Heading Home follow its internal control policies and procedures related to procurement, as well as the following: • Document controls such as including the procurement files include proof of SAM.gov verification to ensure compliance with federal procurement regulations and internal procurement policy. • Implement policies and procedures to verify contractor suspension or debarment status before awarding contracts using federal funds. • Include the required suspension and debarment clause in contracts with federally funded contractors. View of Responsible Official and Corrective Action Plan Heading Home management agrees with this finding. Management has reviewed existing procurement policies and procedures found in Section III Policy #301 of Heading Home’s fiscal policies and procedures with appropriate staff and will enforce policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff, and which require vendors to be reviewed on the SAM website, to ensure they have not been suspended or debarred. Although this review was conducted after the fact, each of the five vendors noted in this finding has since been reviewed on the SAM website, and none of them returned a notice of suspension or debarment. Management is in the process of reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement, as well as for those anticipated to meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management reviewed the above mentioned vendors and noted none of them were suspended or debarred. Circumstantial evidence consisting of emails leads the organization to believe bids/quotes were in fact solicited but the actual procurement packets could not be located due to the extensive turnover in management during 2023. Management anticipates the above corrective action plan will be fully implemented by September 30, 2025. The personnel responsible for overseeing implementation include Connie Chavez, Chief Executive Officer; Debbie Brickman, Chief Financial Officer; and Armando Sanchez, contract accountant team lead.
2023-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, F, G) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: 20-02-HDH-EHA-001, E-22-MC-35-0001 Award Period: July 1, 2022 – June 30, 2023 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement, suspension and debarment regulations or its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled two (out of a population of two) vendors who received more than $10,000 in fiscal year 2023 and noted no evidence of obtaining bids or quotes. Additionally, adequate sole source documentation was absent to support the procurement. • We sampled two (out of a population of two) vendors for tests of internal control over compliance and noted that Heading Home did not provide evidence of internal controls regarding suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for purchases exceeding $10,000, three (3) written competitive bids must be obtained before selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2023) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2023). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and the non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provide reasonable assurance that Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you entering into a covered transaction with another person at the next lower tier, you must verify that the person you intend to conduct business with is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home has not followed its policies and procedures related to procurement. Additionally, the procurement policy does not include the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with its policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors, exposing itself to potential liability and the risk of losing federal funds. Recommendation We recommend Heading Home follow its internal control policies and procedures related to procurement, as well as the following: • Document controls such as including the procurement files include proof of SAM.gov verification to ensure compliance with federal procurement regulations and internal procurement policy. • Implement policies and procedures to verify contractor suspension or debarment status before awarding contracts using federal funds. • Include the required suspension and debarment clause in contracts with federally funded contractors. View of Responsible Official and Corrective Action Plan Heading Home management agrees with this finding. Management has reviewed existing procurement policies and procedures found in Section III Policy #301 of Heading Home’s fiscal policies and procedures with appropriate staff and will enforce policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff, and which require vendors to be reviewed on the SAM website, to ensure they have not been suspended or debarred. Although this review was conducted after the fact, each of the five vendors noted in this finding has since been reviewed on the SAM website, and none of them returned a notice of suspension or debarment. Management is in the process of reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement, as well as for those anticipated to meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management reviewed the above mentioned vendors and noted none of them were suspended or debarred. Circumstantial evidence consisting of emails leads the organization to believe bids/quotes were in fact solicited but the actual procurement packets could not be located due to the extensive turnover in management during 2023. Management anticipates the above corrective action plan will be fully implemented by September 30, 2025. The personnel responsible for overseeing implementation include Connie Chavez, Chief Executive Officer; Debbie Brickman, Chief Financial Officer; and Armando Sanchez, contract accountant team lead.
2023-004 (2021-005) – FEDERAL AND FINANCIAL PROCUREMENT, SUSPENSION, AND DEBARMENT COMPLIANCE Type of Finding: (B, F, G) – Significant Deficiency in Internal Control Over Financial Reporting, Significant Deficiency in Internal Control Over Compliance of Federal Awards and Instance of Non-Compliance Related to Federal Awards Funding Agency: U.S. Department of Housing and Urban Development (HUD) Title: Emergency Solution Grant (ESG) Program AL #: 14.231 Award #: 20-02-HDH-EHA-001, E-22-MC-35-0001 Award Period: July 1, 2022 – June 30, 2023 Questioned Costs: None Statement of Condition Heading Home did not follow federal procurement, suspension and debarment regulations or its federal procurement policy. Context During our testing of procurement, suspension, and debarment we noted the following: • We sampled two (out of a population of two) vendors who received more than $10,000 in fiscal year 2023 and noted no evidence of obtaining bids or quotes. Additionally, adequate sole source documentation was absent to support the procurement. • We sampled two (out of a population of two) vendors for tests of internal control over compliance and noted that Heading Home did not provide evidence of internal controls regarding suspension and debarment requirements. Criteria • Heading Home’s procurement policy states that for purchases exceeding $10,000, three (3) written competitive bids must be obtained before selecting a vendor. • Per 2 CFR 200.320(a)(2)(i) Small purchases - o (i) Small purchase procedures. The acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold ($10,000 in fiscal year 2023) but does not exceed the simplified acquisition threshold ($249,999 in fiscal year 2023). If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. • Additionally, 2 CFR 200.214 requires vendors awarded contracts expected to equal or exceed $25,000 to be checked for suspension and debarment via the System for Award Management Exclusions (SAM.gov). Heading Home is required to verify that entities it plans to do business with are not excluded or disqualified under the federal procurement regulations and the non-procurement common rule, or otherwise declared ineligible under statutory or regulatory authority. According to §200.303 Internal controls of 2 CFR Part 200, the nonfederal entity (Heading Home) must establish and maintain effective internal control over the Federal award that provide reasonable assurance that Heading Home 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). According to §180.300 of Subpart C–Responsibilities of Participants Regarding Transactions Doing Business with Other Persons of 2 CFR Part 180, when you entering into a covered transaction with another person at the next lower tier, you must verify that the person you intend to conduct business with is not excluded or disqualified. This can be done by: (a) Checking SAM Exclusions; or (b) Collecting a certification from that person; or (c) Adding a clause or condition to the covered transaction with that person. Cause Heading Home has not followed its policies and procedures related to procurement. Additionally, the procurement policy does not include the requirement for checking suspension and debarment via SAM.gov. Effect Heading Home is not in compliance with its policies and the federal procurement, suspension, and debarment requirements. Heading Home may have entered into contracts with ineligible contractors, exposing itself to potential liability and the risk of losing federal funds. Recommendation We recommend Heading Home follow its internal control policies and procedures related to procurement, as well as the following: • Document controls such as including the procurement files include proof of SAM.gov verification to ensure compliance with federal procurement regulations and internal procurement policy. • Implement policies and procedures to verify contractor suspension or debarment status before awarding contracts using federal funds. • Include the required suspension and debarment clause in contracts with federally funded contractors. View of Responsible Official and Corrective Action Plan Heading Home management agrees with this finding. Management has reviewed existing procurement policies and procedures found in Section III Policy #301 of Heading Home’s fiscal policies and procedures with appropriate staff and will enforce policies and procedures to ensure competitive bids are obtained where required. Management has also reviewed the existing suspension and debarment policies and procedures found in Section III Policy #302 with appropriate staff, and which require vendors to be reviewed on the SAM website, to ensure they have not been suspended or debarred. Although this review was conducted after the fact, each of the five vendors noted in this finding has since been reviewed on the SAM website, and none of them returned a notice of suspension or debarment. Management is in the process of reviewing all vendors paid $10,000 or more against the SAM website and will ensure all vendors are checked against the website who currently meet this requirement, as well as for those anticipated to meet this threshold. Proof of the SAM website review and approval will be maintained in each vendor file. Management reviewed the above mentioned vendors and noted none of them were suspended or debarred. Circumstantial evidence consisting of emails leads the organization to believe bids/quotes were in fact solicited but the actual procurement packets could not be located due to the extensive turnover in management during 2023. Management anticipates the above corrective action plan will be fully implemented by September 30, 2025. The personnel responsible for overseeing implementation include Connie Chavez, Chief Executive Officer; Debbie Brickman, Chief Financial Officer; and Armando Sanchez, contract accountant team lead.
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 – 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.