Finding 1168578 (2025-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-01-09
Audit: 380438

AI Summary

  • Core Issue: The University did not consistently document the rationale for selecting contractors in procurement processes, despite supporting full and open competition.
  • Impacted Requirements: This finding relates to compliance with 2 CFR Section 200.319, which mandates full and open competition in procurement.
  • Recommended Follow-Up: Enhance documentation practices by recording contractor selection rationale, revise the Procurement Policy, provide staff training, and conduct periodic reviews for compliance.

Finding Text

Assistance Listing Number, Federal Agency, and Program Name Research and Development Cluster National Science Foundation, Department of Commerce, Department of Health and Human Services ALN 47.070, 11.024, , 93.113 Coronavirus State and Local Fiscal Recovery Funds Program ALN 21.027 Federal Award Identification Number and Year Various (R&D) and 21.027 Pass through Entity Various (R&D) and City of Southfield, Michigan; United Way for Southeastern Michigan; MEDC (21.027) Finding Type Significant deficiency Repeat Finding No Criteria A nonfederal entity must conduct all procurement transactions in a manner providing full and open competition in accordance with 2 CFR Section 200.319. Condition The University supported full and open competition when testing Research and Development procurement contracts but did not support rationale for utilizing the selected contractor for 12 of the 23 samples tested. The University supported full and open competition when testing Coronavirus State and Local Fiscal Recovery Funds procurement contracts but did not support rationale for utilizing the selected contractor for 5 of the 5 samples tested. Questioned Costs None If Questioned Costs are not Determinable, Description of Why Known Questioned Costs Were Undetermined or Otherwise Could not be Reported N/A Identification of How Questioned Costs Were Computed N/A Context While the University utilized full and open competition in its procurement process, it did not consistently retain documentation explaining the rationale for selecting specific contractors. Cause and Effect The absence of documented rationale for contractor selection may reflect a focus on meeting competition requirements without fully capturing decision making details. This can make it more difficult to demonstrate the basis for contractor choice and ensure clarity in the procurement process. Recommendation The University should enhance its procurement documentation practices by consistently recording the rationale for contractor selection. This will help ensure transparency, support future reviews, and demonstrate alignment with competitive procurement principles in accordance with 2 CFR Section 200.319. Views of Responsible Officials and Planned Corrective Actions Management will reinforce its existing procurement procedures to ensure that competitive selections are not only conducted appropriately but also consistently documented. Management will implement a standardized documentation protocol that captures the rationale, evaluation criteria, and selection process for each procurement decision. The Procurement Policy will be revised, training will be provided to relevant staff, and periodic reviews will be conducted to ensure compliance.

Corrective Action Plan

Condition: The University supported full and open competition when testing Research and Development procurement contracts but did not support rationale for utilizing the selected contractor for 12 of the 23 samples tested. The University supported full and open competition when testing Coronavirus State and Local Fiscal Recovery Funds procurement contracts but did not support rationale for utilizing the selected contractor for 5 of the 5 samples tested. Planned Corrective Action: Management will reinforce its existing procurement procedures to ensure that competitive selections are not only conducted appropriately but also consistently documented. Management will implement a standardized documentation protocol that captures the rationale, evaluation criteria, and selection process for each procurement decision. The Procurement Policy will be revised, training will be provided to relevant staff, and periodic reviews will be conducted to ensure compliance. Contact person responsible for corrective action: Luba Kagan Anticipated Completion Date: June 30, 2026

Categories

Procurement, Suspension & Debarment Significant Deficiency

Other Findings in this Audit

  • 1168546 2025-002
    Material Weakness Repeat
  • 1168547 2025-002
    Material Weakness Repeat
  • 1168548 2025-002
    Material Weakness Repeat
  • 1168549 2025-002
    Material Weakness Repeat
  • 1168550 2025-002
    Material Weakness Repeat
  • 1168551 2025-002
    Material Weakness Repeat
  • 1168552 2025-002
    Material Weakness Repeat
  • 1168553 2025-002
    Material Weakness Repeat
  • 1168554 2025-002
    Material Weakness Repeat
  • 1168555 2025-002
    Material Weakness Repeat
  • 1168556 2025-002
    Material Weakness Repeat
  • 1168557 2025-002
    Material Weakness Repeat
  • 1168558 2025-002
    Material Weakness Repeat
  • 1168559 2025-002
    Material Weakness Repeat
  • 1168560 2025-002
    Material Weakness Repeat
  • 1168561 2025-002
    Material Weakness Repeat
  • 1168562 2025-002
    Material Weakness Repeat
  • 1168563 2025-002
    Material Weakness Repeat
  • 1168564 2025-002
    Material Weakness Repeat
  • 1168565 2025-002
    Material Weakness Repeat
  • 1168566 2025-002
    Material Weakness Repeat
  • 1168567 2025-002
    Material Weakness Repeat
  • 1168568 2025-002
    Material Weakness Repeat
  • 1168569 2025-002
    Material Weakness Repeat
  • 1168570 2025-002
    Material Weakness Repeat
  • 1168571 2025-002
    Material Weakness Repeat
  • 1168572 2025-002
    Material Weakness Repeat
  • 1168573 2025-003
    Material Weakness Repeat
  • 1168574 2025-003
    Material Weakness Repeat
  • 1168575 2025-003
    Material Weakness Repeat
  • 1168576 2025-003
    Material Weakness Repeat
  • 1168577 2025-003
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $11.74M
84.063 FEDERAL PELL GRANT PROGRAM $3.03M
21.027 COVID- 19 - CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $717,764
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $692,002
84.033 FEDERAL WORK-STUDY PROGRAM $170,275
93.113 ENVIRONMENTAL HEALTH $155,749
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $127,970
20.200 HIGHWAY RESEARCH AND DEVELOPMENT PROGRAM $118,839
12.RD USACE $105,933
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $102,216
93.884 PRIMARY CARE TRAINING AND ENHANCEMENT $96,717
12.600 COMMUNITY INVESTMENT $87,394
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $81,132
11.024 BUILD TO SCALE $69,183
81.RD DEPARTMENT OF ENERGY $33,622
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $32,874
47.083 INTEGRATIVE ACTIVITIES $28,828
59.065 GROWTH ACCELERATOR FUND COMPETITION $27,049
81.010 OFFICE OF TECHNOLOGY TRANSITIONS (OTT)-TECHNOLOGY DEPLOYMENT, DEMONSTRATION AND COMMERCIALIZATION $23,476
81.089 FOSSIL ENERGY RESEARCH AND DEVELOPMENT $20,669
47.084 NSF TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $17,235
47.041 ENGINEERING $15,983
45.129 PROMOTION OF THE HUMANITIES FEDERAL/STATE PARTNERSHIP $13,476
20.505 METROPOLITAN TRANSPORTATION PLANNING AND STATE AND NON-METROPOLITAN PLANNING AND RESEARCH $12,976
59.059 CONGRESSIONAL GRANTS $4,724