Finding 1162408 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2025-11-14
Audit: 372190
Organization: Trustees of Boston College (MA)

AI Summary

  • Core Issue: A vendor was not checked for suspension and debarment due to a system failure, leading to potential compliance risks.
  • Impacted Requirements: The failure violates 2 CFR 200.214, which mandates verification of vendor eligibility before transactions.
  • Recommended Follow-Up: Implement cross-training for staff to ensure timely resolution of system issues and compliance with vendor checks.

Finding Text

2025-001 – Suspension and Debarment Cluster: Research and Development Grantor: Social Security Administration, National Science Foundation Award Name: Center for Retirement Research at Boston College and Affiliated Institutions: Retirement and Disability Research Consortium, Building a Youth-Led Learning Community through Automating Hydroponic Systems, Empowering Youth in STEM and Technological Careers through AI-Enhanced Sustainable and Community-Focused Urban Gardening Award Number: 6 RDR23000010, 2048994, 2241766 Award Year: FY2025 Assistance Listing Numbers: 96.007, 47.076, 47.076 Assistance Listing Titles: Social Security Research and Demonstration; STEM Education (formerly Education and Human Resources) Pass-Through Entities: None - Direct Criteria: Per 2 CFR 200.214, when entering into a covered transaction with an entity, the auditee must have established procedures to verify that the entity is not suspended, debarred or otherwise excluded from participating in the transaction. Condition: For 1 of 25 new vendors sampled, the vendor was not included in the ongoing suspension and debarment monitoring process, which is performed via a third-party servicer. Upon further discussion with the University, it was determined that the selected vendor was part of one day where a total of an additional 24 new vendors were also excluded from the ongoing process. Of the 25 total vendors, 3 of these vendors incurred expenditures related to federal awards totaling approximately $7,000 during the fiscal year. Cause: There was a system failure on one specific day between the University and the third-party servicer that prevented the suspension and debarment checks from being performed on new vendors. After the system failure, University personnel did not confirm that new vendors that were intended to be added on the date in question, were in fact added to the system. Effect: New vendors were not checked for suspension and debarment prior to the University entering into a transaction with the affected vendors. Questioned Costs: None noted. Repeat Finding: No. Recommendation: PwC recommends cross training of individuals responsible for the daily system interactions with the third-party servicer to ensure any system issues are promptly resolved and new vendors are checked for suspension and debarment prior to the University entering into a transaction with them. Management’s Views and Corrective Action Plan: Management’s response is included in Management's Views and Corrective Action Plan included at the end of this report after the Schedule of Status of Prior Audit Findings.

Corrective Action Plan

2025-001 - Suspension and Debarment Cluster: Research and Development Grantor: Social Security Administration, National Science Foundation Award Name: Center for Retirement Research at Boston College and Affiliated Institutions: Retirement and Disability Research Consortium, Building a Youth-Led Learning Community through Automating Hydroponic Systems, Empowering Youth in STEM and Technological Careers through Al-Enhanced Sustainable and Community-Focused Urban Gardening Award Number: 6 RDR23000010, 2048994, 2241766 Award Year: FY2025 Assistance Listing Numbers: 96.007, 47.076, 47.076 Assistance Listing Titles: Social Security Research and Demonstration; STEM Education (formerly Education and Human Resources) Pass-Through Entities: None - Direct Management's View and Corrective Action Plan The University concurs with this finding. On June 25, 2024, the University encountered multiple job failures due to the expiration of a Java Security Certificate. As a result, the file which was to be submitted to the University's third-party servicer for new vendor suspension and debarment screening was not transmitted. The University's Data Center has procedures in place which should have ensured that the vendor file was resubmitted to the third-party servicer once the University's server-related issues were resolved. Unfortunately, due to incorrect documentation in the production operations system (a.k.a. runbook) the vendor file was not resubmitted. Upon further review it was determined that over the course of the fiscal year this was the only incident where the file failed to be transmitted to the servicer. The 25 vendors not screened as a result of the job failure represented less than 1 % of the 3,860 new vendors successfully transmitted and screened by the third-party servicer during the 2025 fiscal year. To ensure that any system issues affecting the daily transmission of the vendor files to the third-party servicer are promptly resolved and new vendors are checked for suspension and debarment, the Information Technology team will enhance the procedure documentation (runbook) and team members will receive cross training. Both the update to the runbook and cross training of team members will be completed by the end of November 2025. University Contact Lyndsay King Associate Vice President, Finance and University Controller Office of the Controller 617-552-3363

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1162406 2025-001
    Material Weakness Repeat
  • 1162407 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loan $87.93M
84.063 Federal Pell Grant Program $11.84M
84.033 Federal Work-Study Program $2.43M
84.038 FEDERAL PERKINS LOAN OUTSTANDING LOANS AS OF JUNE 1 2023 $2.21M
96.007 Social Security Research and Demonstration $2.10M
84.007 Federal Supplemental Educational Opportunity Grants $1.46M
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $1.10M
98.001 USAID Foreign Assistance for Programs Overseas $541,924
84.042 TRIO-Student Support Services $324,001
93.307 Minority Health and Health Disparities Research $290,198
12.630 Basic, Applied and Advanced Research in Science and Engineering $263,060
93.364 NURSING STUDENT LOANS $261,571
12.300 Basic and Applied Scientific Research $254,438
84.217 TRIO-McNair Post-Baccalaureate Achievement $229,505
12.431 Basic Scientific Research $227,513
84.305S Education Research, Development And Dissemination $220,682
11.431 Climate and Atmospheric Research $203,275
93.576 Refugee and Entrant Assistance Discretionary Grants $196,702
84.411 Education Innovation and Research (Formerly Investing in Innovation (I3) Fund) $180,881
47.079 Office of International Science and Engineering $168,760
81.RD Department of Energy $146,554
81.049 Office Of Science Financial Assistance Program $143,504
47.050 Geosciences $143,429
47.084 Technology, Innovation and Partnerships $143,303
93.396 Cancer Biology Research $140,055
12.800 Air Force Defense Research Sciences Program $126,647
84.305A Education Research, Development And Dissemination $108,909
93.989 International Research and Research Training $97,553
93.173 Research Related to Deafness and Communication Disorders $94,105
93.865 Child Health and Human Development Extramural Research $93,223
16.746 Capital Case Litigation Initiative $90,383
84.305 Education Research, Development And Dissemination $85,379
93.859 Biomedical Research and Research Training $78,400
47.075 Social, Behavioral, and Economic Sciences $67,117
93.361 Nursing Research $61,292
45.161 Promotion of the Humanities Research $52,886
93.393 Cancer Cause And Prevention Research $48,143
47.078 Polar Programs $45,478
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $37,836
93.855 Allergy and Infectious Diseases Research $37,184
12.910 Research and Technology Development $36,943
93.242 Mental Health Research Grants $36,011
47.074 Biological Sciences $35,185
12.RD Air Force Research Laboratory $33,560
47.070 Computer and Information Science and Engineering $30,476
47.041 Engineering $24,180
47.049 Mathematical and Physical Sciences $23,059
93.243 Substance Abuse and Mental Health Services, Projects of Regional and National Significance $21,496
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $19,885
93.113 Injury Prevention and Control Research and State and Community Based Programs $19,360
43.001 Science $18,980
93.866 Aging Research $18,009
45.163 Promotion of the Humanities Professional Development $16,915
10.215 Sustainable Agriculture Research and Education $10,867
10.310 Agriculture and Food Research Initiative (AFRI) $10,615
10.216 Plant and Animal Disease, Pest Control, and Animal Care $10,571
93.279 Drug Abuse and Addiction Research Programs $10,475
11.432 National Oceanic and Atmospheric Administration (NOAA) $8,124
93.310 Trans-NIH Research Support $7,185
93.837 Cardiovascular Diseases Research $6,849
93.273 Alcohol Research Programs $6,532
19.900 AEECA/ESF PD Programs $5,921
93.110 Maternal and Child Health Federal Consolidated Programs $5,804
43.003 Exploration $5,654
93.398 Cancer Research Manpower $2,597
84.200 Graduate Assistance In Areas of National Need $2,362
93.262 Occupational Safety and Health Program $2,069
47.076 Education and Human Resources $1,034
84.038 FEDERAL PERKINS LOAN NEW LOANS ISSUED DURING FY25 $0
84.038 FEDERAL PERKINS LOAN ADMINISTRATIVE COST ALLOWANCE $0
93.113 Environmental Health $-18,137