Finding Text
Finding 2024-012 – I. Procurement and Suspension and Debarment
Information on Federal Program(s) – Mission Support (ALN 43.009)
Criteria or Specific Requirement - The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition – The University did not maintain and use documented procurement procedures.
Cause - Administrative oversight and insufficient internal controls.
Effect or Potential Effect – Noncompliance with federal procurement standards.
Questioned Costs – None.
Context – For 1 of 1 procurement transactions tested, the University was unable to provide records documenting appropriate vendor selection.
Indication of Repeat Finding – No similar findings identified in the prior year.
Recommendation – We recommend that the University enhance its procedures and internal controls over compliance to ensure that procurement transactions are appropriately documented.
Views of Responsible Officials – The University acknowledges that the required procurement procedures and controls were not followed. The University is developing a series of internal controls and procedures to ensure that procurement procedures and internal controls are designed and followed as required for all NIH and NASA grant procurements.