Finding Text
Federal Program Information:
Higher Education Institutional Aid (ALN: 84.031B and 84.031E)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – 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 was unable to provide documentation supporting an appropriate competitive bidding process, sole source justification and/or appropriate review of the federal suspension and debarment database prior to the disbursement of funds.
Cause:
Insufficient administrative oversight and internal controls over procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with procurement compliance requirements.
Questioned Costs:
None.
Context:
For 8 of 8 procurement transactions tested, the University was unable to provide documentation supporting an appropriate competitive bidding process, sole source justification and/or appropriate review of the federal suspension and debarment database prior to the disbursement of funds.
Identification as a Repeat Finding:
This is a repeat finding from prior year. This was reported as Finding 2023-005 in the prior year schedule of findings and questioned costs.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The University eliminated the position of Procurement Manager several years back, which decentralized the responsibility for procurement. The change led to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide.
During 2024 GSPAR revised the grant onboarding process to emphasize key federal regulations and emphasize the importance of compliance. Reminders were provided during GSPAR’s semi-annual grant compliance workshops, as well as campus faculty and staff compliance training.
While there was improvement the issues were not fully remediated by June 30, 2024.
During July 2024 the University deployed a sole source justification form for technology purchases. The form will be revised to cover all applicable federal purchases and will require the signature of the principal investigators as well as a representative from GSPAR. The approved form will be added to the purchases record in Colleague.
In addition, the University has modified its new vendor process to require the vendor complete a Disbarment and Suspension Certificate Form, which provides the vendor’s name as well as the principles. Before the vendor is created, a search will be done on the federal website to confirm the vendors status. A screenshot of the results will be saved as part of the vendor record.
The University’s implemented Colleague effective July 2024, which allows the complete purchasing records to be attached to the requisition. Training was provided to the campus to ensure compliance with the new purchasing requirements.