Finding Text
2023-005 – Procurement, Suspension & Debarment – Significant Deficiency in Internal Controls over Compliance
Department of Education
Federal Assistance Listing Number: 84.031
Federal Program Name: Higher Education Institutional Aid
Federal Award Number: P031S210057, P031S170020, P031C210038
Award Year: 2022-23, 2021-22
Federal Assistance Listing Number: 84.425E, 84.425F
Federal Program Name: Higher Education Emergency Relief Funds (HEERF) Institutional Portion,
Federal Award Number: P425F201298
Award Year: 2022-23
Criteria – Non-federal entities, must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. They must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided the policies and procedures conform to applicable federal statutes and the procurement requirements identified in 2 CFR Part 200.
Condition/context – A sample of 4 expenditures greater than the micropurchase threshold of $10,000 but less than the simplified acquisition threshold of $250,000 were selected from the 20 transactions that exceeded the micropurchase threshold of $10,000. For all four of the expenditures the University did not obtain the required rate quotations; per the University’s documented policy two quotes should have been obtained or have documentation supporting their conclusion to sole source the purchases.
Our sample was not, and was not intended to be, statistically valid.
Questioned costs – None.
Cause/effect – The personnel completing purchases on behalf of the University were unaware of the internal procurement policies that are in conformance with federal statutes and 2 CFR Part 200. The lack of obtaining the required rate quotations increases the risk that the price paid was not competitive when compared to the market and that the transaction may not have been in a manner providing full and open competition. The lack of a documented standard of conduct that covers conflict of interest increases the risk that an actual or perceived conflict could occur.
Repeat finding – Yes, 2022-006
Recommendation – We recommend the University implement controls to ensure all employees making federal purchases on behalf of the University are aware of the University’s documented procurement policy that is in accordance with 2 CFR Part 200. In addition, we recommend the University document its standard of conduct that covers conflicts of interest and governs the performance of its employees engaged in the selection, award, and administration of contracts.
Views of responsible officials and planned corrective actions – The University puts measures in place to guarantee that every employee who makes federal purchases on the University's behalf is aware of the documented procurement policy that complies with 2 CFR Part 200. The University will formalize its code of conduct, which addresses conflicts of interest and sets performance standards for staff members who choose, award, and manage contracts.