Finding 1240495 (2025-009)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-10-15
Audit: 414959
Organization: Heritage University (WA)

AI Summary

  • Core Issue: The University lacks adequate internal controls for procurement, leading to potential noncompliance with federal standards.
  • Impacted Requirements: Non-federal entities must adhere to procurement standards (2 CFR 200.318-327) and ensure vendors are not suspended or debarred (2 CFR 180.220).
  • Recommended Follow-Up: The University should revise its procurement policies and implement controls to meet federal compliance requirements.

Finding Text

2025-009 – Procurement Suspension and Debarment – Material Weakness in Internal Controls over Compliance and Material Noncompliance Department of Education Federal Assistance Listing Number: 84.031 Federal Program Name: Higher Education Institutional Aid Federal Award Number: P031S210057, P031C210038 Award Year: 2024-25, 2023-24, 2022-23, 2021-22 Criteria – Non-federal entities other than states, including those operating federal programs as subrecipients of states, must follow the procurement standards set out at 2 CFR 200.318 through 200.327. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. “Covered transactions” include contracts for goods and services awarded under a non-procurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR 180.220 Condition/context – Out of a sample of 2 procurement transactions selected for testing, for 1 transaction management was unable to provide supporting documentation for a signed contract, review and approval of purchase, or that the correct procurement policies were followed based on the contract value. Additionally, the University was unable to provide support that either vendor was reviewed for suspension and debarment prior to contract approval. Our sample was not, and was not intended to be, statistically valid. Questioned costs – The University asserted that the amount charged to the grant for the contractor was $63,174 however we were unable to obtain a signed contract or verify the total disbursements for the year. Cause/effect – The University does not have the proper controls in place to ensure procurement transactions adhere to the standards set out in 2 CFR 200.318 through 200.327, or to ensure covered transactions are being reviewed in accordance with 2 CFR 180.220. The lack of controls increases the risk of the University entering into transactions that do not meet the applicable standards, or with entities who may be suspended or debarred from receiving payments from federal funds. Repeat finding – No Recommendation – We recommend the University review their current control policies and procedures, and ensure controls are designed and implemented that satisfy the requirements outlined in 2 CFR 200.318 through 200.327 and 2 CFR 180.220. Views of responsible officials and planned corrective actions – Heritage University agrees with the recommendation and is reviewing its current procurement policies, procedures, and internal controls as they relate to purchases made with federal funds.

Corrective Action Plan

9. 2025-009 – Procurement Suspension and Debarment – Material Weakness in Internal Controls over Compliance and Material Noncompliance Recommendation: The auditors recommend the University review their current control policies and procedures, and ensure controls are designed and implemented that satisfy the requirements outlined in 2 CFR 200.318 through 200.327 and 2 CFR 180.220. Planned corrective actions: Heritage University agrees with the recommendation and is reviewing its current procurement policies, procedures, and internal controls as they relate to purchases made with federal funds. The University is assessing existing purchasing practices to identify areas where additional documentation, clarification, or controls may be needed to support compliance with applicable federal procurement requirements. As part of this work, management will review responsibilities and coordination among Sponsored Programs, Grant Accounting, the Business Office, Purchasing, and departments responsible for initiating and approving federally funded purchases. The University plans to strengthen and document processes surrounding appropriate approvals, purchasing methods, supporting documentation, vendor review, and other applicable federal requirements. Particular attention will be given to establishing clear ownership and appropriate checkpoints within the purchasing process so that compliance considerations are addressed before federally funded purchases are completed. The Office of Sponsored Programs, in collaboration with the Business Office and other affected departments, will support the review and development of updated procedures and provide guidance and training as processes are established. Management recognizes that strengthening the University's procurement framework will be an ongoing process and will prioritize improvements based on identified risk, operational needs, and applicable federal requirements. Name of Responsible Party: Dr. Yesenia Rodriguez, Rachel Castilleja Anticipated completion date: In Progress

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 1240464 2025-002
    Material Weakness Repeat
  • 1240465 2025-002
    Material Weakness Repeat
  • 1240466 2025-003
    Material Weakness Repeat
  • 1240467 2025-003
    Material Weakness Repeat
  • 1240468 2025-004
    Material Weakness Repeat
  • 1240469 2025-004
    Material Weakness Repeat
  • 1240470 2025-004
    Material Weakness Repeat
  • 1240471 2025-004
    Material Weakness Repeat
  • 1240472 2025-004
    Material Weakness Repeat
  • 1240473 2025-004
    Material Weakness Repeat
  • 1240474 2025-004
    Material Weakness Repeat
  • 1240475 2025-004
    Material Weakness Repeat
  • 1240476 2025-004
    Material Weakness Repeat
  • 1240477 2025-004
    Material Weakness Repeat
  • 1240478 2025-005
    Material Weakness Repeat
  • 1240479 2025-005
    Material Weakness Repeat
  • 1240480 2025-005
    Material Weakness Repeat
  • 1240481 2025-006
    Material Weakness Repeat
  • 1240482 2025-006
    Material Weakness Repeat
  • 1240483 2025-006
    Material Weakness Repeat
  • 1240484 2025-006
    Material Weakness Repeat
  • 1240485 2025-007
    Material Weakness Repeat
  • 1240486 2025-007
    Material Weakness Repeat
  • 1240487 2025-008
    Material Weakness Repeat
  • 1240488 2025-008
    Material Weakness Repeat
  • 1240489 2025-008
    Material Weakness Repeat
  • 1240490 2025-008
    Material Weakness Repeat
  • 1240491 2025-008
    Material Weakness Repeat
  • 1240492 2025-008
    Material Weakness Repeat
  • 1240493 2025-008
    Material Weakness Repeat
  • 1240494 2025-009
    Material Weakness Repeat
  • 1240496 2025-010
    Material Weakness Repeat
  • 1240497 2025-010
    Material Weakness Repeat
  • 1240498 2025-011
    Material Weakness Repeat
  • 1240499 2025-011
    Material Weakness Repeat
  • 1240500 2025-011
    Material Weakness Repeat
  • 1240501 2025-011
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $3.79M
84.268 FEDERAL DIRECT STUDENT LOANS $3.25M
84.184 SCHOOL SAFELY NATIONAL ACTIVITIES $1.32M
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $535,630
84.031 HIGHER EDUCATION INSTITUTIONAL AID $495,537
84.141 MIGRANT EDUCATION HIGH SCHOOL EQUIVALENCY PROGRAM $494,528
84.149 MIGRANT EDUCATION COLLEGE ASSISTANCE MIGRANT PROGRAM $453,194
84.042 TRIO STUDENT SUPPORT SERVICES $263,859
84.217 TRIO MCNAIR POST-BACCALAUREATE ACHIEVEMENT $218,194
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $104,462
84.033 FEDERAL WORK-STUDY PROGRAM $90,480
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $48,248
10.558 CHILD AND ADULT CARE FOOD PROGRAM $33,141
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $30,407
43.001 SCIENCE $13,280
47.074 BIOLOGICAL SCIENCES $7,041