Finding 1179943 (2025-004)

Federal Agency: US Department of Education (ED) Program Names: Fund for the Improvement of Postsecondary Education; Special Education – Personnel Development to Improve Services and Results for Children with Disabilities; Child Care Access Means Parent in Schools ALNs: 84.116; 84.325K; 84.335 Award Numbers: P116Z230260; H325K180006; P335A220131; Federal Awards Year 2024 - 2025 Questioned Costs: None Repeat Finding: Yes 2025-004. Finding: Internal Controls Over Procurement Northern Illinois University (University) included incorrect documentation within purchase requisition forms for small purchases and simplified acquisition procurement transactions at the time of approval of the purchase which did not allow a reviewer to determine the appropriateness of the procurement method. Condition: Three (100%) of three small purchase procurement transactions tested in the Fund for the Improvement of Postsecondary Education program were approved based on a form that summarized the incorrect procurement method. The University incorrectly indicated on a small purchase waiver form that the transactions were exempt from procurement under the Illinois Procurement Code (30 ILCS 500 / 1-13(b)(8)). One (100%) of one transaction tested meeting the simplified acquisition threshold in the Fund for the Improvement of Postsecondary Education program was approved based on a form that summarized the incorrect procurement method. The University incorrectly utilized a small purchase waiver form to indicate that the transaction was exempt from procurement under the Illinois Procurement Code (30 ILCS 500 / 1-13(b)(8)). One (50%) of two small purchase procurement transactions tested in the Special Education – Personnel Development to Improve Services and Results for Children with Disabilities program was approved based on a form that summarized the incorrect procurement method. The University incorrectly indicated on a small purchase waiver form that the transaction was exempt from procurement under the Illinois Procurement Code (30 ILCS 500 / 1-13(b)(8)). One (50%) of two small purchase procurement transactions tested in the Child Care Access Means Parents in School program was approved based on a form that summarized the incorrect procurement method. The University incorrectly indicated on a small purchase waiver form that the transaction was exempt from procurement under the Illinois Procurement Code (30 ILCS 500 / 1-13(b)(8)). One (100%) of one transaction tested meeting the simplified acquisition threshold in the Child Care Access Means Parents in School program was approved based on a form that summarized the incorrect procurement method. The University incorrectly indicated on a small purchase waiver form that the transaction was exempt from procurement under the Illinois Procurement Code (30 ILCS 500 / 1-13(b)(8)). Based on additional information provided to us during our testing, the University did have other documentation to support the history of the procurement, including rationale for the method of procurement, and there were no indications that procurement methods used were inappropriate. The sample was not intended to be, and was not, a statistically valid sample. Criteria: Uniform Grant Guidance (2 CFR 200.303) requires nonfederal entities receiving Federal awards establish and maintain internal controls designed to reasonably ensure compliance with Federal laws, regulations, and program compliance requirements. Effective internal controls should include procedures to ensure procurement procedures are properly followed and support is properly maintained as required by 2 CFR 200.318. Cause: University officials stated that insufficient training on procurements subject to 2 CFR 200 lead to the incorrect documentation on the purchase requisition documentation. Effect: If the purchase requisition forms contain an incorrect rationale for the procurement method selected, the University could approve payments of federal funds to vendors that do not meet federal regulations. (Finding Code No. 2025-004, 2024-004) Recommendation: We recommend the University review current processes for small purchases and simplified acquisition transactions to ensure purchase requisition forms are completed correctly. University Response: Accepted. The University implemented revised procedures and targeted training in April 2025 to strengthen compliance with the 2 CFR 200 procurement requirements. The transactions identified in the condition occurred prior to full implementation and corrective action. The University will continue to monitor procurement processes to ensure accurate and complete documentation of the procurement method selected.