Finding 1103198 (2024-003)

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Requirement
I
Questioned Costs
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Year
2024
Accepted
2025-03-12
Audit: 345761
Organization: Washington University (MO)

AI Summary

  • Core Issue: The University did not consistently document procurement decisions and vendor screenings, risking transactions with suspended or debarred vendors.
  • Impacted Requirements: Violations of 2 CFR 200, including the need for documented procurement procedures and timely vendor screening.
  • Recommended Follow-Up: Improve documentation processes for procurement decisions and ensure all suspension/debarment checks are completed before vendor transactions.

Finding Text

Finding 2024-003: Procurement, Suspension, and Debarment Grantor: National Institute of Health Program: Research and Development Assistance Listing #: 93.395, 93.866 Title: Cancer Treatment Research, Aging Research Award Year: 3/1/2019-11/30/2023, 2/15/2021-1/31/2026 Award #: 3UM1CA18670405S1, 5R01AG07094105 Criteria: -2 CFR 200, Subpart D which require institutions to (1) maintain and use documented procedures for procurement transactions under a federal award or subaward, including for acquisition of property or services; (2) maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. -2 CFR 200.214 which restricts making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in federal awards. Condition: -For 2 of 25 procurements sampled, the University documented both supplier justification and the purchase order after receipt of an invoice from the vendor. -For 1 of 25 procurements sampled, the University did not maintain evidence of their price/cost analysis as requires when the procurement exceeds the simplified acquisition threshold of $250,000. -For 1 of 25 samples selected for suspension and debarment, the University performed the suspension/debarment screen after the date and payment of the vendor invoice. Cause: For vendors that existed in the legacy accounting system, the University has not consistently documented vendor screening results. Additionally, procurement decisions/conclusions were not consistently documented prior to executing transactions with vendors. Effect: There is a risk that the University could enter into transactions with vendors that are suspended/debarred. Separately, failure to document procurement decisions in a timely manner could impact the University's ability to demonstrate compliance with federal regulations and the University's procurement policies. Questioned Costs: There are no questioned costs as the vendor selected was not suspended or debarred and procurement transactions were deemed allowable. Recommendation: Management should enhance its existing processes to ensure all decisions and conclusions supporting procurements are made in a timely manner and completely documented in the procurement files prior to entering into transactions with vendors. The University should also ensure that all required suspension and debarment checks are performed, and documentation is maintained in advance of transacting with vendors. Management's View and Corrective Action Plan: Please refer to management's views and corrective action plan.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $60.20M
84.063 Federal Pell Grant Program $8.37M
93.352 Construction Support $7.97M
84.038 Federal Perkins Loans $7.03M
93.398 Cancer Research Manpower $5.52M
93.185 Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects $2.28M
93.213 Research and Training in Complementary and Integrative Health $2.04M
84.033 Federal Work-Study Program $1.95M
93.866 Covid - Aging Research $1.62M
84.007 Federal Supplemental Educational Opportunity Grants $1.52M
93.121 Oral Diseases and Disorders Research $1.44M
12.RD Defense Threat Reduction Agency $1.35M
93.384 Advanced Research Projects Agency for Health (arpa-H) $1.34M
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $1.33M
93.113 Environmental Health $1.28M
93.RD Covid - National Cancer Institute (nci) $1.19M
93.365 Sickle Cell Treatment Demonstration Program $1.12M
93.153 Coordinated Services and Access to Research for Women, Infants, Children, and Youth $1.05M
47.050 Geosciences $1.02M
93.135 Centers for Research and Demonstration for Health Promotion and Disease Prevention $1.02M
93.834 Capacity Building Assistance (cba) for High-Impact Hiv Prevention $1.01M
93.978 Sexually Transmitted Diseases (std) Provider Education Grants $968,647
47.083 Integrative Activities $895,270
93.732 Mental and Behavioral Health Education and Training Grants $820,841
12.RD Military Medical Research and Development $814,298
81.135 Advanced Research Projects Agency - Energy $766,776
43.012 Space Technology $739,248
93.242 Mental Health Research Grants $723,772
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $667,620
93.U04 Centers for Disease Control and Prevention $650,394
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $531,904
93.998 Autism and Other Developmental Disabilities, Surveillance, Research, and Prevention $527,759
93.361 Covid - Nursing Research $490,429
93.855 Allergy and Infectious Diseases Research $481,689
93.863 Biomedical Advanced Research and Development Authority (barda), Biodefense Medical Countermeasure Development $465,418
93.395 Cancer Treatment Research $438,335
93.088 Covid - Advancing System Improvements for Key Issues in Women's Health $430,671
12.RD Department of Defense $383,456
93.RD National Institute on Drug Abuse (nida) $364,396
98.007 Food for Peace Development Assistance Program (dap) $353,039
81.RD Department of Energy $351,987
84.042 Trio Student Support Services $350,935
47.RD National Science Foundation $318,512
93.136 Injury Prevention and Control Research and State and Community Based Programs $314,295
93.RD Covid - National Center for Advancing Translational Sciences (ncats) $287,197
93.349 Packaging and Spreading Proven Pediatric Weight Management Interventions for Use by Low-Income Families $259,895
10.219 Biotechnology Risk Assessment Research $251,614
93.393 Cancer Cause and Prevention Research $237,070
93.217 Family Planning Services $229,390
93.788 Opioid Str $228,602
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $215,455
21.008 Low Income Taxpayer Clinics $208,736
93.226 Covid - Research on Healthcare Costs, Quality and Outcomes $205,151
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $196,568
93.241 State Rural Health Flexibility Program $188,965
93.866 Aging Research $182,956
93.847 Covid - Diabetes, Digestive, and Kidney Diseases Extramural Research $171,644
93.143 Niehs Superfund Hazardous Substances_basic Research and Education $165,627
66.509 Science to Achieve Results (star) Research Program $160,586
93.310 Trans-Nih Research Support $147,387
93.U02 Centers for Disease Control and Prevention $141,933
16.812 Second Chance Act Reentry Initiative $134,617
93.838 Lung Diseases Research $133,892
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $131,493
12.RD National Security Agency $128,806
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $124,476
16.710 Public Safety Partnership and Community Policing Grants $121,686
93.917 Hiv Care Formula Grants $120,166
93.396 Cancer Biology Research $114,895
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $114,158
19.019 International Programs to Combat Human Trafficking $113,130
93.RD Centers for Disease Control $111,819
93.670 Child Abuse and Neglect Discretionary Activities $111,356
81.089 Fossil Energy Research and Development $110,725
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $110,592
93.879 Medical Library Assistance $110,278
16.582 Crime Victim Assistance/discretionary Grants $105,072
93.351 Research Infrastructure Programs $103,650
93.361 Nursing Research $97,388
81.049 Office of Science Financial Assistance Program $92,063
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $89,190
93.394 Cancer Detection and Diagnosis Research $87,643
43.001 Science $85,688
93.939 Hiv Prevention Activities Non-Governmental Organization Based $84,508
12.598 Centers for Academic Excellence $83,066
93.262 Occupational Safety and Health Program $81,167
10.310 Agriculture and Food Research Initiative (afri) $80,871
93.397 Cancer Centers Support Grants $80,533
19.600 Bureau of Near Eastern Affairs $79,681
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $79,263
47.074 Biological Sciences $73,335
47.078 Polar Programs $73,303
12.910 Research and Technology Development $73,224
93.843 Acl Assistive Technology State Grants for Protection and Advocacy $71,048
93.172 Human Genome Research $69,987
93.853 Covid - Extramural Research Programs in the Neurosciences and Neurological Disorders $68,073
43.008 Office of Stem Engagement (ostem) $64,708
93.307 Minority Health and Health Disparities Research $59,179
93.RD Covid - National Institute of Allergy and Infectious Diseases (niaid) $57,895
93.RD National Heart, Lung and Blood Institute (nhlbi) $57,259
12.800 Air Force Defense Research Sciences Program $57,075
12.RD Defense Advanced Research Projects Agency $56,449
93.U09 Health Resources and Services Administration $55,749
47.076 Stem Education (formerly Education and Human Resources) $55,295
12.U01 Military Medical Research and Development $53,230
93.867 Vision Research $53,067
93.928 Special Projects of National Significance $52,702
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $52,598
93.809 National Organizations for Chronic Disease Prevention and Health Promotion $51,217
47.049 Mathematical and Physical Sciences $50,494
93.173 Research Related to Deafness and Communication Disorders $50,484
11.431 Climate and Atmospheric Research $49,250
93.185 Covid - Immunization Research, Demonstration, Public Information and Education Training and Clinical Skills Improvement Projects $47,298
93.273 Covid - Alcohol Research Programs $47,114
93.RD National Institute of Allergy and Infectious Diseases (niaid) $46,108
93.279 Drug Abuse and Addiction Research Programs $45,406
91.RD United States Institute of Peace $42,704
93.273 Alcohol Research Programs $39,975
20.600 State and Community Highway Safety $39,868
93.U05 Food and Drug Administration $38,404
93.068 Chronic Diseases: Research, Control, and Prevention $37,122
93.RD National Center for Advancing Translational Sciences (ncats) $36,826
84.022 Overseas Programs - Doctoral Dissertation Research Abroad $36,691
12.U02 Military Medical Research and Development $35,074
93.073 Birth Defects and Developmental Disabilities - Prevention and Surveillance $34,568
16.758 Improving the Investigation and Prosecution of Child Abuse and the Regional and Local Children's Advocacy Centers $34,364
84.305 Education Research, Development and Dissemination $32,412
93.940 Hiv Prevention Activities Health Department Based $31,729
93.837 Cardiovascular Diseases Research $31,625
93.988 Cooperative Agreements for Diabetes Control Programs $30,159
93.RD National Cancer Institute (nci) $29,387
12.431 Basic Scientific Research $28,407
93.838 Covid - Lung Diseases Research $28,335
47.075 Social, Behavioral, and Economic Sciences $24,179
93.103 Food and Drug Administration Research $23,836
93.226 Research on Healthcare Costs, Quality and Outcomes $23,095
93.989 International Research and Research Training $22,564
93.110 Maternal and Child Health Federal Consolidated Programs $21,848
93.RD Biomedical Advanced Research and Development Authority (barda), Biodefense Medical Countermeasure Development $21,719
43.007 Space Operations $21,387
93.493 Congressional Directives $20,070
12.300 Basic and Applied Scientific Research $19,256
93.U07 Health Resources and Services Administration $18,965
93.U08 Health Resources and Services Administration $18,735
93.800 Organized Approaches to Increase Colorectal Cancer Screening $18,363
81.112 Stewardship Science Grant Program $18,310
81.087 Renewable Energy Research and Development $17,211
93.399 Cancer Control $15,523
93.080 Blood Disorder Program: Prevention, Surveillance, and Research $15,105
93.RD National Institutes of Health (nih) $14,760
93.233 National Center on Sleep Disorders Research $12,530
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $12,527
93.310 Covid - Trans-Nih Research Support $12,042
64.RD Department of Veterans Affairs $11,564
93.839 Blood Diseases and Resources Research $11,284
93.U06 Food and Drug Administration $11,203
93.914 Hiv Emergency Relief Project Grants $10,421
84.425 Education Stabilization Fund $9,406
12.630 Basic, Applied, and Advanced Research in Science and Engineering $8,813
47.041 Engineering $8,504
93.127 Emergency Medical Services for Children $8,369
11.459 Weather and Air Quality Research $8,218
93.279 Covid - Drug Abuse and Addiction Research Programs $7,775
93.U01 Centers for Disease Control and Prevention $7,548
93.837 Covid - Cardiovascular Diseases Research $7,200
19.900 Aeeca/esf Pd Programs $6,294
93.U03 Centers for Disease Control and Prevention $5,698
43.RD NASA $4,189
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $3,961
93.859 Biomedical Research and Research Training $3,901
93.865 Child Health and Human Development Extramural Research $3,577
47.084 Nsf Technology, Innovation, and Partnerships $3,539
93.078 Strengthening Emergency Care Delivery in the United States Healthcare System Through Health Information and Promotion $3,526
47.079 Office of International Science and Engineering $3,075
93.084 Covid - Prevention of Disease, Disability, and Death by Infectious Diseases $2,458
93.RD Covid - National Heart, Lung and Blood Institute (nhlbi) $2,306
45.024 Promotion of the Arts Grants to Organizations and Individuals $2,154
19.522 Overseas Refugee Assistance Programs for Strategic Global Priorities $1,734
93.840 Covid - Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $960
93.239 Policy Research and Evaluation Grants $776
98.RD Agency for International Development $345
93.350 National Center for Advancing Translational Sciences $189
93.U10 Covid - Biomedical Advanced Research and Development Authority (barda) $-64
47.070 Computer and Information Science and Engineering $-380
20.RD National Highway Traffic Safety Administration $-413
93.155 Rural Health Research Centers $-606
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $-941
97.077 Homeland Security Research, Development, Testing, Evaluation and Demonstration of Technologies Related to Countering Weapons of Mass Destruction $-1,159
15.805 Assistance to State Water Resources Research Institutes $-1,431
93.855 Covid - Allergy and Infectious Diseases Research $-6,834
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation�s Health $-9,781
98.001 Usaid Foreign Assistance for Programs Overseas $-10,136
12.420 Military Medical Research and Development $-15,624