Assistance Listing Numbers: 10.001, 10.200, 10.215, 10.307, 10.310, 10.311, and 10.912
Name of Federal Program or Cluster: Research and Development Cluster
Name of Federal Agency: Department of Agriculture
Federal Award Identification Numbers:
58-5090-2-037
2022-38624-38368
2021-38640-34714
2020-38640-31522
2022-38640-37486
2023-51300-40959
2021-68012-35917
2019-68012-29852
2020-68012-31934
2021-49400-35592
NR225F48XXXXG006
Name of Pass-through Entities and Award Periods: Michigan State University-September 1, 2022 through
August 31, 2025; Regents of the University of Minnesota- April 1, 2021 through March 31, 2023, March 1,
2022 through February 28, 2025, and April 1, 2023 through March 31, 2025; Board of Regents of the
University of Wisconsin System- September 1, 2019 through August 31, 2024, September 1, 2020 through
August 31, 2025, and January 1, 2022 through December 31, 2026
Criteria or Specific Requirement: 2 CFR section 200.318(a) requires a non-federal entity to have and use
documented procurement procedures, consistent with state, local, and tribal laws and regulations and the
standards of 2 CFR sections 200.317 through 200.327. 2 CFR section 200.318(c)(1) requires a non- federal
entity to maintain written standards of conduct covering conflicts of interest and governing the actions of its
employees engaged in the selection, award and administration of contracts. 2 CFR section 200.318(i)
requires a non-federal entity to maintain records sufficient to detail the history of procurement including, but
not limited to, the: rationale for the method of procurement, selection of contract type, contractor selection
or rejection, and the basis for the contract price.
Condition: There are no documented procurement procedures that meet the requirements of 2 CFR
sections 200.317 through 200.327 that were implemented for the fiscal year. There are no consistently
implemented internal controls documented to ensure compliance with 2 CFR sections 200.317 through
200.327. 19 out of 60 procurements did not have documented an internal control over compliance. 1 of 2
simplified acquisition procurements had no documentation of the rationale for the method, documentation
to support a required procurement method used, contractor selections or rejections, suspension and
debarment, and bases for contract prices. The only support documented are the invoices. No covered
transactions were documented as tested for suspension and debarment. Cause: There were no written procedures over procurement and when changes in management and
accounting services occurred internal control documentation was not consistent and compliance
requirements were not understood.
Effect or Potential Effect: Procurement transactions may not be in compliance and disallowed.
Questioned Costs: $22,000 – two simplified acquisitions
Context: 60 ($76,181) out of 721 ($302,069) procurement transactions were tested. Two of the 721
procurements were simplified acquisitions while the remaining were micro purchases.
Repeat Finding: This is a repeat of Finding 2022-005.
Recommendation: The Organization should develop and document procurement procedures that meet
state, local, and Uniform Guidance requirements. Internal controls should be designed, implemented, and
documented within the procurement procedures to ensure compliance with 2 CFR sections 200.317 through
200.327. At a minimum, the procurement history including rationale for the method, procurement method
support, contract selections and rejections, suspension and debarment, and bases for contract prices
should be documented.
Views of Responsible Officials: Management agrees with the finding and will implement procurement
procedures.