Finding 1170305 (2024-011)

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

AI Summary

  • Core Issue: The University's procurement policy does not align with Uniform Guidance requirements, leading to a significant deficiency in internal controls.
  • Impacted Requirements: The policy fails to define necessary procurement levels and competitive bidding criteria as outlined in the Uniform Guidance.
  • Recommended Follow-Up: The University should revise its procurement policy to comply with federal regulations and maintain documentation of quotes and approvals.

Finding Text

2024 – 011 – Procurement Federal Agency: US Department of Agriculture, US Department of Education Federal Program Name: Extension Services at 1890 Colleges, 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: Uniform guidance requires auditees to follow procurement standards. Sections of the Uniform Guidance set forth five permissible procurement methods for nonfederal entities expending federal financial assistance: (1) micro-purchases (§ 200.320(a)(1)); (2) small purchases (§ 200.320(a)(2)); (3) sealed bids (§ 200.320(b)(1)); (4) proposals (§ 200.320(b)(2)); and (5) noncompetitive procurement (§ 200.320(c)(1)-(5)). Condition: The University's procurement policy does not currently match all requirements of the Uniform Guidance, and CliftonLarsonAllen LLP (CLA) was unable to sight evidence of their key control being performed. Questioned costs: None Context: The University's procurement policy does not currently match all requirements of the uniform guidance related to defining the required levels of procurement and when competitive bids are required, and CLA was unable to sight evidence of a key control being performed for five of six sample selections for the Extension Services at 1890 Colleges grant. Cause: The University did not have a process in place to ensure the procurement policy met Uniform Guidance. Effect: The University is not in compliance with Uniform Guidance for procurement. Repeat Finding: Yes, 2023-025 Recommendation: We recommend the University review its procurement policy to ensure it meets federal regulations and ensure they retain documentation of quotes received and final approval forms. Views of responsible officials: There is no disagreement with the audit finding.

Corrective Action Plan

Federal Agency: US Department of Agriculture , US Department of Education Federal Program Name: Extension Services at 1890 Colleges Assistance Listing No.: 10.512 and 84.425 Recommendation: We recommend the University review its procurement policy to ensure it meets federal regulations and ensure they retain documentation of quotes received and final approval forms. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: KSU is revising its procurement policies to ensure compliance with uniform guidance requirements. Name(s) of the contact person(s) responsible for corrective action: Eileen Butts, Director of Purchasing Planned completion date for corrective action plan: March 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
  • 1170289 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
  • 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