Finding Text
2025 – 004 – Procurement and Suspension & Debarment Federal Agency: U.S. Department of Education Federal Program Name: Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement Assistance Listing Number: 84.031C Federal Award Identification Number and Year: P031C210072 - 2024 Award Period: July 01, 2024 - June 30, 2025 Type of Finding: • Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: The University had not consistently performed requirements for procurement and suspension and debarment as outlined in the Uniform Grant Guidance. Questioned costs: None Context: During our testing, suspension and debarment procedures were not performed for 4 of 5 vendors tested. As a result of timing of when the University formalized their written procurement policy, there were no formal procurement procedures performed for 1 of 5 vendors tested. Cause: The University was not following a formalized procurement policy. Effect: Procurements are not being made and suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance. Repeat finding: Yes, 2024-005. Recommendation: We recommend the University follow their policy for procurement and suspension & debarment to ensure they are aligned with Uniform Grant Guidance. Views of responsible officials: There is no disagreement with the audit finding.