Finding Text
Finding 2022-001 ? Suspension and Debarment Verification Federal Awarding Agency: Department of Education Award Name: COVID-19 ? Education Stabilization Fund ? Institutional Portion Award Number: ED-GRANTS-042120-004 Award Year: June 1,2021 - May 31,2022 Assistant Listing Title: HEERF Institutional Portion Assistant Listing Number: 84.425F Pass-through entities: Not applicable Criteria Per 2 CFR 180.220, suspension and debarment checks are required to be performed for covered transactions that equal or exceed $25,000. Condition As discussed in the Summary Schedule of Prior Audit Findings and Status, we identified a finding in fiscal year 2021 related to suspension and debarment checks not being performed in advance of making the determination to seek reimbursement of an expenditure with federal funding. In December 2021, management took corrective actions to address the finding. During fiscal year 2022, we selected five of the University?s procurements which equalled or exceeded the covered transaction threshold. Two samples totaling $313,500 which were purchased prior to December 2021 had no documentation to evidence that a suspension and debarment check was performed prior to utilizing federal funding to reimburse the University for the expenditure. No exceptions were noted related to the three samples that were made during the period of time after management?s corrective actions were taken in December 2021. Cause The University has a process to ensure that suspension and debarment verifications are performed for expenditures that will be reimbursed by federal award funding within the Office for Research & Sponsored Projects. However, at the time these procurements were made, the decision to utilize federal award funding to reimburse the University for the expenditures had not been made. As a result, these procurements were made through the University?s standard operational procurement process, and suspension and debarment procedures were not performed. Effect Procurements could be improperly entered into with vendors that are suspended or debarred. In the case above, the entities were not found to be suspended or debarred at the time of testing. Questioned Costs None noted. Recommendation We recommend management continue to ensure suspension and debarment checks are performed on a timely basis consistent with the policies and procedures implemented in December 2021. Management?s Corrective Action Plan Management?s response is reported on ?Management?s Views and Corrective Action Plan? at the end of this report.