Finding Text
Finding 2025-004 – Significant Deficiency, Compliance and Control Federal Award No. 84.116z U.S. Department of Education Fund for the Improvement of Postsecondary Education – Procurement Criteria: Under 2 CFR Part 200 Subpart D – Procurement Standards, entities must use competitive bidding to promote full and open competition and entities must verify that vendors in covered transactions are not suspended or debarred by checking SAM.gov, obtaining certification, or including an appropriate contract clause. Condition: The University did not document price or rate quotations for an adequate number of qualified sources for procurement transactions that were higher than the micro-purchase threshold and that did not exceed the simplified acquisition threshold. The University did not document verification that a vendor receiving federal funds was not suspended or debarred. For all vendors tested, no SAM.gov check, vendor certification, or contract clause was on file. Context: For the three vendors tested, there was no documentation retained to confirm the vendors were not suspended or debarred at the time of the transaction or evidence of price or rate quotations from an adequate number of qualified sources for procurement transactions that were higher than the micro-purchase threshold and that did not exceed the simplified acquisition threshold. Effect: Federal funds could be spent with limited competition on ineligible vendors. No suspended or debarred vendors were identified during audit procedures. Questioned Costs: There were no questioned costs to report as the vendors selected for testing were verified by the auditor to be eligible at the time of the transaction. Cause: Ottawa University did not have proper processes and related controls in place to consistently require or document suspension/debarment checks or perform and document price or rate quotations. Indication As Repeat Finding: This is not a repeat finding. Recommendation: Implement controls to ensure suspension and debarment checks and price or rate quotations are completed and documented before awarding federally funded contracts. Views Of Responsible Officials (Unaudited): Management agrees with the finding. The University will update its procurement procedures to require documented verification of vendor eligibility prior to award and when using the simplified acquisition procedure and to obtain price or rate quotations from an adequate number of qualified sources. Anticipated Completion Date: June 30, 2026 Contact Person: Tom Corley, Controller