Finding 1182127 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-23
Audit: 393493
Organization: Grand Valley State University (MI)

AI Summary

  • Core Issue: The University failed to provide documentation verifying that vendors were not suspended or debarred for federal grant purchases.
  • Impacted Requirements: This violates both the University's internal purchasing policy and the Uniform Guidance standards for federal awards.
  • Recommended Follow-Up: The University should enhance its procedures to ensure proper documentation is maintained and implement a validation step in the procurement process to verify vendor status.

Finding Text

Assistance Listing, Federal Agency, and Program Name 21.027 COVID 19 Coronavirus State and Local Fiscal Recovery Funds and 84.215 Innovative Approaches to Literacy Federal Award Identification Number and Year Coronavirus State and Local Fiscal Recovery Funds SLFRP1027 Innovative Approaches to Literacy S215K230129 Pass through Entity 21.027 Michigan Strategic Fund; 20 Fathoms; Lean Rocket Lab; Talent First Inc; Lansing Economic Area Partnership; Michigan Economic Development Corporation 84.215 N/A Finding Type Significant Deficiency Repeat Finding No Criteria Recipients of federal awards are required to follow their internal purchasing policies, as well as comply with purchasing standards set forth in the Uniform Guidance. Per the University policy, all grant funded purchases in excess of $25,000 should be verified using SAM.gov the supplier is not suspended or debarred and the results should be retained in the purchase requisition. As Uniform Guidance restricts making federal awards, subawards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from receiving or participating in Federal award (CFR 200.214). Condition In accordance with the University's policy, the University was unable to provide documentation to support its consideration of the suspension and debarment for the only vendor selected within Coronavirus State and Local Fiscal Recovery Funds. In accordance with the University's policy, the University was unable to provide documentation to support its consideration of the suspension and debarment for the only vendor selected within Innovative Approaches to Literacy. Questioned Costs None If questioned costs are not determinable, description of why known questioned costs were undetermined or otherwise could not be reported N/A Identification of How Questioned Costs Were Computed N/A Context In the samples mentioned above, In accordance with University's policy the University did not maintain the appropriate documentation for the vendors to support their assessment of whether the vendors where included on Suspension or Debarment list. In either case the vendors included in the samples were not included in the Suspension and Debarment list and the University was allowed to contract with the vendor. Cause and Effect The University did not follow its policy to ensure that the documentation verifying the vendors were not suspended or debarred. Recommendation We recommend the University reviews its procedures and controls to ensure documentation of its compliance with the requirements under uniform guidance is maintained. Views of Responsible Officials and Planned Corrective Actions A new custom validation warning will be added to the requisitions business process at the buyer approval step to require the Procurement Specialist to verify SAM.gov and attach the results as required for grant funded purchases. This custom validation will ensure that each required consideration of suspension and debarment occurs and is documented in the procurement record.

Corrective Action Plan

Condition: In accordance with the University's policy, the University was unable to provide documentation to support its consideration of the suspension and debarment for the only vendor selected within Coronavirus State and Local Fiscal Recovery Funds. Additionally, the University was unable to provide documentation to support its consideration of the suspension and debarment for the only vendor selected within Innovative Approaches to Literacy. Planned Corrective Action: A new custom validation warning will be added to the requisitions business process at the buyer approval step to require the Procurement Specialist to verify SAM.gov and attach the results as required for grant funded purchases. This custom validation will ensure that each required consideration of suspension and debarment occurs and is documented in the procurement record. Contact person responsible for corrective action: Director of Procurement Services Anticipated Completion Date: Implemented as of 3/03/2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1182120 2025-002
    Material Weakness Repeat
  • 1182121 2025-002
    Material Weakness Repeat
  • 1182122 2025-002
    Material Weakness Repeat
  • 1182123 2025-002
    Material Weakness Repeat
  • 1182124 2025-002
    Material Weakness Repeat
  • 1182125 2025-002
    Material Weakness Repeat
  • 1182126 2025-002
    Material Weakness Repeat
  • 1182128 2025-003
    Material Weakness Repeat
  • 1182129 2025-003
    Material Weakness Repeat
  • 1182130 2025-003
    Material Weakness Repeat
  • 1182131 2025-003
    Material Weakness Repeat
  • 1182132 2025-003
    Material Weakness Repeat
  • 1182133 2025-003
    Material Weakness Repeat
  • 1182134 2025-001
    Material Weakness Repeat
  • 1182135 2025-001
    Material Weakness Repeat
  • 1182136 2025-001
    Material Weakness Repeat
  • 1182137 2025-001
    Material Weakness Repeat
  • 1182138 2025-001
    Material Weakness Repeat
  • 1182139 2025-001
    Material Weakness Repeat
  • 1182140 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $119.06M
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $1.30M
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $1.17M
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $813,926
93.178 NURSING WORKFORCE DIVERSITY $571,086
84.031 HIGHER EDUCATION INSTITUTIONAL AID $556,372
84.042 TRIO STUDENT SUPPORT SERVICES $546,766
93.247 ADVANCED NURSING EDUCATION WORKFORCE GRANT PROGRAM $536,531
84.044 TRIO TALENT SEARCH $481,681
93.359 NURSE EDUCATION, PRACTICE QUALITY AND RETENTION GRANTS $446,299
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $421,183
93.884 PRIMARY CARE TRAINING AND ENHANCEMENT $353,957
84.047 TRIO UPWARD BOUND $326,976
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS $304,595
84.066 TRIO EDUCATIONAL OPPORTUNITY CENTERS $287,633
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $270,288
93.323 EPIDEMIOLOGY AND LABORATORY CAPACITY FOR INFECTIOUS DISEASES (ELC) $266,428
93.364 NURSING STUDENT LOANS $231,507
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $209,791
47.083 INTEGRATIVE ACTIVITIES $188,981
59.059 CONGRESSIONAL GRANTS $187,493
84.103 TRIO STAFF TRAINING PROGRAM $160,010
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS $145,109
93.865 CHILD HEALTH AND HUMAN DEVELOPMENT EXTRAMURAL RESEARCH $133,123
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $131,894
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $117,892
84.206 JAVITS GIFTED AND TALENTED STUDENTS EDUCATION $111,969
84.184 SCHOOL SAFELY NATIONAL ACTIVITIES $107,490
66.469 GEOGRAPHIC PROGRAMS - GREAT LAKES RESTORATION INITIATIVE $94,313
15.808 U.S. GEOLOGICAL SURVEY RESEARCH AND DATA COLLECTION $90,323
47.084 NSF TECHNOLOGY, INNOVATION, AND PARTNERSHIPS $87,684
93.855 ALLERGY AND INFECTIOUS DISEASES RESEARCH $75,225
12.903 GENCYBER GRANTS PROGRAM $68,030
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $57,995
84.027 SPECIAL EDUCATION GRANTS TO STATES $43,450
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $42,783
15.608 FISH AND AQUATIC CONSERVATION - AQUATIC INVASIVE SPECIES $38,988
11.429 MARINE SANCTUARY PROGRAM $38,681
84.063 FEDERAL PELL GRANT PROGRAM $36,630
45.313 LAURA BUSH 21ST CENTURY LIBRARIAN PROGRAM $22,340
11.432 NATIONAL OCEANIC AND ATMOSPHERIC ADMINISTRATION (NOAA) COOPERATIVE INSTITUTES $19,252
93.310 TRANS-NIH RESEARCH SUPPORT $19,090
93.855 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $18,676
10.608 FOOD FOR EDUCATION $17,009
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $16,115
47.074 BIOLOGICAL SCIENCES $15,347
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $12,544
11.431 CLIMATE AND ATMOSPHERIC RESEARCH $12,141
11.463 HABITAT CONSERVATION $9,425
15.805 ASSISTANCE TO STATE WATER RESOURCES RESEARCH INSTITUTES $9,154
10.559 SUMMER FOOD SERVICE PROGRAM FOR CHILDREN $7,622
15.657 ENDANGERED SPECIES RECOVERY IMPLEMENTATION $6,876
64.027 POST-9/11 VETERANS EDUCATIONAL ASSISTANCE $5,497
66.454 WATER QUALITY MANAGEMENT PLANNING $4,516
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $4,363
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $3,855
10.903 SOIL SURVEY $2,713
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $2,260
10.699 PARTNERSHIP AGREEMENTS $2,211
10.902 SOIL AND WATER CONSERVATION $2,127
12.901 MATHEMATICAL SCIENCES GRANTS $1,940
43.001 SCIENCE $658
15.662 GREAT LAKES RESTORATION $605
47.050 GEOSCIENCES $574
66.472 BEACH MONITORING AND NOTIFICATION PROGRAM IMPLEMENTATION GRANTS $480
84.033 FEDERAL WORK-STUDY PROGRAM $64
93.135 CENTERS FOR RESEARCH AND DEMONSTRATION FOR HEALTH PROMOTION AND DISEASE PREVENTION $-8
42.010 TEACHING WITH PRIMARY SOURCES $-554