Finding 1179861 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-17

AI Summary

  • Core Issue: The University failed to consistently verify that vendors are not suspended or debarred as required by federal guidelines.
  • Impacted Requirements: Non-federal entities must check the status of parties involved in covered transactions to ensure compliance with 2 CFR section 180.995.
  • Recommended Follow-Up: The University should establish and implement formal policies and procedures for suspension and debarment to meet compliance standards.

Finding Text

2025-002 – Suspension and Debarment Policy Federal Agency: U.S. Department of Education Federal Program Name: Developing Hispanic-Serving Institutions Program: Ensuring Success for the New Majority Student; Bienestar (Wellbeing) for All Assistance Listing Number: 84.031S Federal Award Identification Number and Year: P031S230321, P031S210125; 2024-2025 Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University did not consistently perform requirements for suspension and debarment as outlined in the Uniform Grant Guidance. Questioned Costs: None. Context: The University did not implement a formal, written policy and procedure that aligned with the Uniform Grant Guidance requirements for suspension and debarment. Cause: The University did not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for suspension and debarment until May of 2025. Effect: Suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2024-003. Auditors’ Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Bienestar (Wellbeing) For All; ESNMS: Title V DOE Grant (Ensuring Success for the New Majority Student) – Assistance Listing No. 84.031S Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University implemented a formal policy and procedure to verify that a vendor is not debarred or suspended in the System for Award Management (SAM) database. The procedure, effective May 2025, outlines roles, responsibilities, and documentation requirements to ensure consistent compliance. Name(s) of the contact person(s) responsible for corrective action: Diane DiStaulo, Director of Accounting Operations, (201) 761-7415 Planned completion date for corrective action plan: Completed

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 1179854 2025-001
    Material Weakness Repeat
  • 1179855 2025-001
    Material Weakness Repeat
  • 1179856 2025-001
    Material Weakness Repeat
  • 1179857 2025-001
    Material Weakness Repeat
  • 1179858 2025-001
    Material Weakness Repeat
  • 1179859 2025-001
    Material Weakness Repeat
  • 1179860 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $9.54M
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $597,430
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $572,486
64.027 POST-9/11 VETERANS EDUCATIONAL ASSISTANCE $422,486
84.031 HIGHER EDUCATION INSTITUTIONAL AID $417,661
84.033 FEDERAL WORK-STUDY PROGRAM $356,432
84.268 FEDERAL DIRECT STUDENT LOANS $355,331
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $283,866
84.042 TRIO STUDENT SUPPORT SERVICES $278,361
64.125 VOCATIONAL AND EDUCATIONAL COUNSELING FOR SERVICEMEMBERS AND VETERANS $218,028
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS $185,792
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $99,653
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $85,635
84.126 REHABILITATION SERVICES VOCATIONAL REHABILITATION GRANTS TO STATES $8,613
94.014 AMERICORPS MARTIN LUTHER KING JR. DAY OF SERVICE GRANTS 94.014 $1,500