FAC Explorer

Finding 1191177 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-03-27
Audit: 395317
Organization: Eastern Michigan University (MI)
Auditor: PLANTE & MORAN PLLC

AI Summary

  • Core Issue: The University failed to follow its own procurement procedures, leading to a material weakness and noncompliance with federal regulations.
  • Impacted Requirements: Noncompliance with 2 CFR 200.318, which mandates written procurement procedures for federal awards.
  • Recommended Follow-Up: Implement ongoing procurement training for faculty and staff, ensure compliance checks for purchase orders, and enforce corrective actions for continued noncompliance.

Finding Text

Assistance Listing, Federal Agency, and Program Name - 93.332 - U.S. Department of Health and Human Services Navigator Grants Program, Various R&D Cluster Federal Award Identification Number and Year - NAVCA210431 02, NAVCA210431 03, Research and Development grants Pass through Entity - N/A Finding Type - Material weakness and material noncompliance with laws and regulations Repeat Finding - Yes 2024-003 Criteria - 2 CFR 200.318 requires that a nonfederal entity that acquires property or services under a federal award or subaward is required to adopt, maintain, and follow written procurement procedures, which comply with sections 2 CFR 200.318 through 327. Condition - The University did not follow the written procurement procedures in place. Questioned Costs - $888,816 Identification of How Questioned Costs Were Computed - Questioned costs reflect the amount of costs expended under the grant during 2025 that exceeded the procurement policy threshold. Context - The University did not follow its written policy in place over procurement methods, including using a competitive bid process and reviewing for suspension and debarment for purchases over the policy's threshold. Cause and Effect - Failure to comply with the University's written procurement policy, where controls were not in place to comply with University's policy. Recommendation - The University should ensure controls are in place to comply with the procurement policy on an ongoing basis. Views of Responsible Officials and Corrective Action Plan - It was noted that certain purchase orders and requisitions were processed after services had already been performed. To address this issue, procurement training will now be required for certain faculty and staff, emphasizing that requisitions and purchase orders must be submitted and approved prior to the initiation of any services, to ensure adherence to the University’s documented competitive bid process. The University Purchasing Department currently provides monthly procurement policy training. In the new award setup phase, the Office of Research Development and Administration will require that a Principal Investigator (PIs) with awards with direct costs greater than the University bid limit attend such training within three months of award date. PIs with multiple awards will only be required to attend such training every 24 months. Additionally, Sponsored Research Accounting will follow up with PIs on all awards opened within the first three months to confirm adherence to University purchasing policies. Continued non compliance may result in corrective actions for the applicable Principal Investigator/award team, including, but not limited to, loss of eligibility to submit future proposals, suspension of existing funding, or the requirement to use indirect cost (IDC) funds to cover any unallowable expenses.

Corrective Action Plan

Condition: The University did not follow the written procurement procedures in place. Planned Corrective Action: It was noted that certain purchase orders and requisitions were processed after services had already been performed. To address this issue, procurement training will now be required for certain faculty and staff, emphasizing that requisitions and purchase orders must be submitted and approved prior to the initiation of any services, to ensure adherence to the University’s documented competitive bid process. The University Purchasing Department currently provides monthly procurement policy training. In the new award setup phase, the Office of Research Development and Administration will require that a Principal Investigator (PIs) with awards with direct costs greater than the University bid limit attend such training within three months of award date. PIs with multiple awards will only be required to attend such training every 24 months. Additionally, Sponsored Research Accounting will follow up with PIs on all awards opened within the first three months to confirm adherence to University purchasing policies. Continued non-compliance may result in corrective actions for the applicable Principal Investigator/award team, including, but not limited to, loss of eligibility to submit future proposals, suspension of existing funding, or the requirement to use indirect cost (IDC) funds to cover any unallowable expenses. Contact person responsible for corrective action: Joel Clendenin, Grants Manager Anticipated Completion Date: 6/30/2026

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1191139 2025-002
    Material Weakness Repeat
  • 1191140 2025-002
    Material Weakness Repeat
  • 1191141 2025-002
    Material Weakness Repeat
  • 1191142 2025-002
    Material Weakness Repeat
  • 1191143 2025-002
    Material Weakness Repeat
  • 1191144 2025-002
    Material Weakness Repeat
  • 1191145 2025-002
    Material Weakness Repeat
  • 1191146 2025-002
    Material Weakness Repeat
  • 1191147 2025-002
    Material Weakness Repeat
  • 1191148 2025-002
    Material Weakness Repeat
  • 1191149 2025-002
    Material Weakness Repeat
  • 1191150 2025-002
    Material Weakness Repeat
  • 1191151 2025-002
    Material Weakness Repeat
  • 1191152 2025-002
    Material Weakness Repeat
  • 1191153 2025-002
    Material Weakness Repeat
  • 1191154 2025-002
    Material Weakness Repeat
  • 1191155 2025-002
    Material Weakness Repeat
  • 1191156 2025-002
    Material Weakness Repeat
  • 1191157 2025-002
    Material Weakness Repeat
  • 1191158 2025-002
    Material Weakness Repeat
  • 1191159 2025-002
    Material Weakness Repeat
  • 1191160 2025-002
    Material Weakness Repeat
  • 1191161 2025-002
    Material Weakness Repeat
  • 1191162 2025-002
    Material Weakness Repeat
  • 1191163 2025-002
    Material Weakness Repeat
  • 1191164 2025-002
    Material Weakness Repeat
  • 1191165 2025-002
    Material Weakness Repeat
  • 1191166 2025-002
    Material Weakness Repeat
  • 1191167 2025-002
    Material Weakness Repeat
  • 1191168 2025-002
    Material Weakness Repeat
  • 1191169 2025-002
    Material Weakness Repeat
  • 1191170 2025-002
    Material Weakness Repeat
  • 1191171 2025-002
    Material Weakness Repeat
  • 1191172 2025-002
    Material Weakness Repeat
  • 1191173 2025-002
    Material Weakness Repeat
  • 1191174 2025-002
    Material Weakness Repeat
  • 1191175 2025-002
    Material Weakness Repeat
  • 1191176 2025-002
    Material Weakness Repeat
  • 1191178 2025-003
    Material Weakness Repeat
  • 1191179 2025-003
    Material Weakness Repeat
  • 1191180 2025-003
    Material Weakness Repeat
  • 1191181 2025-003
    Material Weakness Repeat
  • 1191182 2025-003
    Material Weakness Repeat
  • 1191183 2025-003
    Material Weakness Repeat
  • 1191184 2025-003
    Material Weakness Repeat
  • 1191185 2025-003
    Material Weakness Repeat
  • 1191186 2025-004
    Material Weakness Repeat
  • 1191187 2025-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 FEDERAL DIRECT STUDENT LOANS $73.37M
84.063 FEDERAL PELL GRANT PROGRAM $24.40M
84.033 FEDERAL WORK-STUDY PROGRAM $922,272
84.287 TWENTY-FIRST CENTURY COMMUNITY LEARNING CENTERS $707,656
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $630,569
93.332 COOPERATIVE AGREEMENT TO SUPPORT NAVIGATORS IN FEDERALLY-FACILITATED EXCHANGES $613,889
84.047 TRIO UPWARD BOUND $611,080
84.038 FEDERAL PERKINS LOAN PROGRAM_FEDERAL CAPITAL CONTRIBUTIONS $583,287
84.206 JAVITS GIFTED AND TALENTED STUDENTS EDUCATION $546,648
93.732 MENTAL AND BEHAVIORAL HEALTH EDUCATION AND TRAINING GRANTS $535,738
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $274,527
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $267,740
84.042 TRIO STUDENT SUPPORT SERVICES $183,392
93.855 ALLERGY AND INFECTIOUS DISEASES RESEARCH $171,072
84.215 INNOVATIVE APPROACHES TO LITERACY; PROMISE NEIGHBORHOODS; FULL-SERVICE COMMUNITY SCHOOLS; AND CONGRESSIONALLY DIRECTED SPENDING FOR ELEMENTARY AND SECONDARY EDUCATION COMMUNITY PROJECTS $132,414
96.004 SOCIAL SECURITY SURVIVORS INSURANCE $125,834
45.163 PROMOTION OF THE HUMANITIES PROFESSIONAL DEVELOPMENT $118,303
11.008 NOAA MISSION-RELATED EDUCATION AWARDS $100,411
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $94,205
93.173 RESEARCH RELATED TO DEAFNESS AND COMMUNICATION DISORDERS $84,824
84.305 EDUCATION RESEARCH, DEVELOPMENT AND DISSEMINATION $83,863
47.074 BIOLOGICAL SCIENCES $81,924
10.558 CHILD AND ADULT CARE FOOD PROGRAM $76,048
11.429 MARINE SANCTUARY PROGRAM $75,435
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $74,720
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $56,585
84.018 OVERSEAS PROGRAMS SPECIAL BILATERAL PROJECTS $55,968
66.034 SURVEYS, STUDIES, RESEARCH, INVESTIGATIONS, DEMONSTRATIONS, AND SPECIAL PURPOSE ACTIVITIES RELATING TO THE CLEAN AIR ACT $54,100
15.904 HISTORIC PRESERVATION FUND GRANTS-IN-AID $33,380
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $32,500
93.859 BIOMEDICAL RESEARCH AND RESEARCH TRAINING $25,567
16.753 CONGRESSIONALLY RECOMMENDED AWARDS $24,296
84.048 CAREER AND TECHNICAL EDUCATION -- BASIC GRANTS TO STATES $23,000
93.264 NURSE FACULTY LOAN PROGRAM (NFLP) $19,270
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $18,570
93.959 BLOCK GRANTS FOR PREVENTION AND TREATMENT OF SUBSTANCE ABUSE $18,096
43.001 SCIENCE $16,508
84.015 NATIONAL RESOURCE CENTERS PROGRAM FOR FOREIGN LANGUAGE AND AREA STUDIES OR FOREIGN LANGUAGE AND INTERNATIONAL STUDIES PROGRAM AND FOREIGN LANGUAGE AND AREA STUDIES FELLOWSHIP PROGRAM $15,123
21.027 COVID-19 - CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $15,101
93.436 WELL-INTEGRATED SCREENING AND EVALUATION FOR WOMEN ACROSS THE NATION (WISEWOMAN) $12,900
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $12,013
16.738 EDWARD BYRNE MEMORIAL JUSTICE ASSISTANCE GRANT PROGRAM $9,272
84.334 GAINING EARLY AWARENESS AND READINESS FOR UNDERGRADUATE PROGRAMS $4,228
47.075 SOCIAL, BEHAVIORAL, AND ECONOMIC SCIENCES $3,937
93.866 AGING RESEARCH $3,829
93.865 CHILD HEALTH AND HUMAN DEVELOPMENT EXTRAMURAL RESEARCH $3,443
93.738 PPHF: RACIAL AND ETHNIC APPROACHES TO COMMUNITY HEALTH PROGRAM FINANCED SOLELY BY PUBLIC PREVENTION AND HEALTH FUNDS $2,500
12.905 CYBERSECURITY CORE CURRICULUM $2,346
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $1,171
45.310 GRANTS TO STATES $919
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $780
45.025 PROMOTION OF THE ARTS PARTNERSHIP AGREEMENTS $-581
12.810 AIR FORCE MEDICAL RESEARCH AND DEVELOPMENT $-40,821
93.674 JOHN H. CHAFEE FOSTER CARE PROGRAM FOR SUCCESSFUL TRANSITION TO ADULTHOOD $-215,453