Finding 1181784 (2025-001)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-20
Audit: 393068
Organization: Moberly Area Community College (MO)

AI Summary

  • Core Issue: The College did not provide documentation showing that it checked for suspended or debarred parties before making grant disbursements.
  • Impacted Requirements: This violates 2 CFR 200.213, which mandates checks against SAM.gov or equivalent documentation for compliance.
  • Recommended Follow-Up: The College should improve its procedures to ensure that suspension and debarment checks are conducted and documented before contracts are finalized.

Finding Text

Federal Agency: US Department of Treasury Federal Program Title: Coronavirus State and Local Fiscal Recovery Funds Assistance Listing Number: 21.027 Federal Award Identification Number and Year: Various Award Period: July 1, 2024, to June 30, 2025 Type of Finding: • Compliance, Other Matter • Significant Deficiency in Internal Control Over Compliance Criteria or specific requirement: Per 2 CFR 200.213, non-federal entities are prohibited from contracting with or making subawards to parties that are suspended, debarred, or otherwise excluded from participation in federal programs. Verification must be performed through SAM.gov, a written certification, or inclusion of the appropriate clause in the agreement. Condition: During our review of grant disbursements, the College was unable to provide formal documentation to demonstrate that a suspension and debarment check was completed for all disbursements selected for testing. Context: For all (two) of the transactions selected for testing, the College was unable to provide documentation to support the date suspension and debarment checks were verified. Questioned costs: None Cause: The absence of formal documentation suggests that either the check was not performed or was performed but not properly documented Effect: Failure to document suspension and debarment checks could result in noncompliance with federal regulations and institutional policy, increasing the risk of disallowed costs and potential reputational or financial consequences. Repeat finding: No Recommendation: We recommend the College evaluate its procedures and policies around suspension and debarment to ensure that checks are both performed and formally documented prior to entering into the contract. View of responsible official: There is no disagreement with the audit finding.

Corrective Action Plan

Coronavirus State & Local Recovery Funds – Assistance Listing No. 21.027 Recommendation: We recommend the College evaluate its procedures and policies around suspension and debarment to ensure that checks are both performed and formally documented prior to entering into the contract. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The College verified the status of all vendors utilized in federal grant disbursements during the year ended June 30, 2025. A spreadsheet was maintained during that year which documented this. Since June 30, 2025, a procedure has been added to retain copies of the sam.gov verifications for additional documentation. Name(s) of the contact person(s) responsible for corrective action: Susan Spencer, Vice President for Finance Planned completion date for corrective action plan: Completed March 2026 If the United States Department of Treasury has questions regarding this plan, please call Susan Spencer at 660-263-4100, ext. 11274.

Categories

Procurement, Suspension & Debarment

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $7.94M
84.268 FEDERAL DIRECT STUDENT LOANS $3.75M
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $1.73M
84.002 ADULT EDUCATION - BASIC GRANTS TO STATES $512,425
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $282,874
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $171,683
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $125,007
84.033 FEDERAL WORK-STUDY PROGRAM $53,498
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $6,437