FAC Explorer

Finding 1170289 (2024-006)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2026-01-22
Audit: 383421
Organization: Kentucky State University (KY)
Auditor: CLIFTONLARSONALLEN LLP

AI Summary

  • Core Issue: The University failed to maintain documentation verifying that vendors were not suspended or debarred before awarding contracts.
  • Impacted Requirements: Compliance with 2 CFR 180 and 2 CFR 200.213, which mandate checks against the SAM.gov 'Exclusions' list.
  • Recommended Follow-Up: Implement procedures for vendor verification, retain documentation, and train staff on compliance requirements.

Finding Text

2024 – 006 – Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Extension Services at 1890 Colleges and the Education Stabilization Fund Assistance Listing Number: 10.512; 84.425 Federal Award Identification Number and Year: NI201444XXXXG008-0005; P425J200025 - 2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per 2 CFR 180 and 2 CFR 200.213, nonfederal entities must ensure that vendors are not suspended or debarred from federal programs. Verification can be performed by checking the SAM.gov 'Exclusions' list, collecting a certification from the vendor, or including a clause in the contract requiring compliance. Condition: Documentation supporting the University's suspension and debarment checks for sampled vendors was not maintained. Questioned costs: None. Context: During testing of Suspension and Debarment compliance, we noted that three out of three sampled procurement transactions tested for Program 10.512, as well as two out of two sampled transactions tested for Program 84.425, did not include documentation demonstrating that vendors were verified as not suspended or debarred prior to award. Cause: The University did not maintain records of suspension and debarment checks for sampled transactions. Effect: Without documented verification, there is an increased risk that federal funds could be expended with ineligible vendors, resulting in potential noncompliance with Uniform Guidance and exposure to questioned costs. Repeat Finding: No. Recommendation: We recommend the University implement and enforce procedures to verify vendor status through SAM.gov or other acceptable methods prior to award, retain documentation of the verification in procurement files, and train staff on suspension and debarment requirements under Uniform Guidance. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Federal Agency: U.S. Department of Agriculture Federal Program Name: Extension Services at 1890 Colleges and the Education Stabilization Fund Assistance Listing No.: 10.512; 84.425 Recommendation: We recommend the University implement and enforce procedures to verify vendor status through SAM.gov or other acceptable methods prior to award, retain documentation of the verification in procurement files, and train staff on suspension and debarment requirements under Uniform Guidance. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Procedures were implemented in FY26 to maintain documentation in Banner. The University has implemented additional procedures and buyers have been trained in checking SAM.gov for each federally funded Purchase Order. Name(s) of the contact person(s) responsible for corrective action: Eileen Butts, Director of Purchasing Planned completion date for corrective action plan: January 31, 2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1170284 2024-006
    Material Weakness Repeat
  • 1170285 2024-006
    Material Weakness Repeat
  • 1170286 2024-006
    Material Weakness Repeat
  • 1170287 2024-006
    Material Weakness Repeat
  • 1170288 2024-006
    Material Weakness Repeat
  • 1170290 2024-007
    Material Weakness Repeat
  • 1170291 2024-007
    Material Weakness Repeat
  • 1170292 2024-007
    Material Weakness Repeat
  • 1170293 2024-007
    Material Weakness Repeat
  • 1170294 2024-008
    Material Weakness Repeat
  • 1170295 2024-009
    Material Weakness Repeat
  • 1170296 2024-010
    Material Weakness Repeat
  • 1170297 2024-010
    Material Weakness Repeat
  • 1170298 2024-010
    Material Weakness Repeat
  • 1170299 2024-010
    Material Weakness Repeat
  • 1170300 2024-011
    Material Weakness Repeat
  • 1170301 2024-011
    Material Weakness Repeat
  • 1170302 2024-011
    Material Weakness Repeat
  • 1170303 2024-011
    Material Weakness Repeat
  • 1170304 2024-011
    Material Weakness Repeat
  • 1170305 2024-011
    Material Weakness Repeat
  • 1170306 2024-012
    Material Weakness Repeat
  • 1170307 2024-012
    Material Weakness Repeat
  • 1170308 2024-012
    Material Weakness Repeat
  • 1170309 2024-012
    Material Weakness Repeat
  • 1170310 2024-013
    Material Weakness Repeat
  • 1170311 2024-013
    Material Weakness Repeat
  • 1170312 2024-014
    Material Weakness Repeat
  • 1170313 2024-015
    Material Weakness Repeat
  • 1170314 2024-016
    Material Weakness Repeat
  • 1170315 2024-017
    Material Weakness Repeat
  • 1170316 2024-017
    Material Weakness Repeat
  • 1170317 2024-018
    Material Weakness Repeat
  • 1170318 2024-018
    Material Weakness Repeat
  • 1170319 2024-019
    Material Weakness Repeat
  • 1170320 2024-019
    Material Weakness Repeat
  • 1170321 2024-019
    Material Weakness Repeat
  • 1170322 2024-019
    Material Weakness Repeat
  • 1170323 2024-019
    Material Weakness Repeat
  • 1170324 2024-019
    Material Weakness Repeat
  • 1170325 2024-019
    Material Weakness Repeat
  • 1170326 2024-019
    Material Weakness Repeat
  • 1170327 2024-019
    Material Weakness Repeat
  • 1170328 2024-019
    Material Weakness Repeat
  • 1170329 2024-019
    Material Weakness Repeat
  • 1170330 2024-019
    Material Weakness Repeat
  • 1170331 2024-020
    Material Weakness Repeat
  • 1170332 2024-020
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $10.18M
84.063 FEDERAL PELL GRANT PROGRAM $5.38M
10.205 PAYMENTS TO 1890 LAND-GRANT COLLEGES AND TUSKEGEE UNIVERSITY $4.79M
84.425 EDUCATION STABILIZATION FUND $2.70M
10.524 SCHOLARSHIPS FOR STUDENTS AT 1890 INSTITUTIONS $1.51M
10.512 EXTENSION SERVICES AT 1890 COLLEGES AND TUSKEGEE UNIVERSITY, WEST VIRGINIA STATE COLLEGE, AND CENTRAL STATE UNIVERSITY $823,316
84.382 STRENGTHENING MINORITY-SERVING INSTITUTIONS $388,732
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $342,661
84.031 HIGHER EDUCATION INSTITUTIONAL AID $248,774
16.726 JUVENILE MENTORING PROGRAM $219,372
10.216 1890 INSTITUTION CAPACITY BUILDING GRANTS $171,463
10.229 EXTENSION COLLABORATIVE ON IMMUNIZATION TEACHING & ENGAGEMENT $154,867
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $144,896
10.443 OUTREACH AND ASSISTANCE FOR SOCIALLY DISADVANTAGED AND VETERAN FARMERS AND RANCHERS $139,844
84.033 FEDERAL WORK-STUDY PROGRAM $130,545
10.937 PARTNERSHIPS FOR CLIMATE-SMART COMMODITIES $118,066
10.237 FROM LEARNING TO LEADING: CULTIVATING THE NEXT GENERATION OF DIVERSE FOOD AND AGRICULTURE PROFESSIONALS $105,772
10.175 FARMERS MARKET AND LOCAL FOOD PROMOTION PROGRAM $82,888
84.042 TRIO STUDENT SUPPORT SERVICES $60,354
10.025 PLANT AND ANIMAL DISEASE, PEST CONTROL, AND ANIMAL CARE $54,210
10.523 CENTERS OF EXCELLENCE AT 1890 INSTITUTIONS $42,989
10.147 OUTREACH EDUCATION AND TECHNICAL ASSISTANCE $42,846
81.089 FOSSIL ENERGY RESEARCH AND DEVELOPMENT $41,056
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $40,044
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $29,109
10.500 COOPERATIVE EXTENSION SERVICE $29,066
12.905 CYBERSECURITY CORE CURRICULUM $28,257
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $21,929
10.215 SUSTAINABLE AGRICULTURE RESEARCH AND EDUCATION $19,354
10.311 BEGINNING FARMER AND RANCHER DEVELOPMENT PROGRAM $16,617
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $14,668
10.001 AGRICULTURAL RESEARCH BASIC AND APPLIED RESEARCH $10,949
10.514 EXPANDED FOOD AND NUTRITION EDUCATION PROGRAM $6,295
10.515 RENEWABLE RESOURCES EXTENSION ACT $5,335
84.047 TRIO UPWARD BOUND $3,232
93.969 PPHF GERIATRIC EDUCATION CENTERS $2,198
10.226 SECONDARY EDUCATION, TWO-YEAR POSTSECONDARY EDUCATION, AND AGRICULTURE IN THE K-12 CLASSROOM $1,251
47.083 INTEGRATIVE ACTIVITIES $-1,218
10.202 COOPERATIVE FORESTRY RESEARCH $-3,540