Finding 20747 (2022-001)

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Requirement
I
Questioned Costs
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Year
2022
Accepted
2022-11-10
Audit: 20526
Organization: Butler University (IN)
Auditor: Forvis LLP

AI Summary

  • Core Issue: The University’s procurement policy lacks necessary documentation for compliance with federal regulations.
  • Impacted Requirements: The policy does not meet the standards outlined in 2 CFR sections 200.318 through 200.326.
  • Recommended Follow-Up: Revise procurement policies to include all required federal procurement elements.

Finding Text

Federal Program Name: Research and Development Cluster Federal Agency: National Science Foundation Federal Assistance Listing Title and Number: 47.074 Award Year: June 1, 2021 ? May 31, 2022 Criteria or Specific Requirement: Procurement, Suspension and Debarment Condition: The University?s procurement policy does not contain adequate documentation to demonstrate compliance with federal procurement regulations. (Deficiency) Questioned Costs: None. Context: The University?s documented procurement policies do not contain all the specified requirements of 2 CFR sections 200.318 through 200.326. Effect: The risks exist that the University could follow their procurement policy and procure an item with federal funds, which would not meet the federal procurement regulations. Cause: The writing of the policy did not take into account federal procurement regulations which are required to be incorporated for items procured with federal funds. Repeat Finding: No Recommendation: We recommend the University revise procurement policies to incorporate all required elements of federal procurement regulations.

Corrective Action Plan

The University will review the specified requirements of the Office of Management and Budget Guidance for Grants and Agreements with the University?s grant professionals in Finance and the Office of Sponsored Programs to recommend an appendix for federal grants expenditures to the University?s procurement policy as part of the upcoming annual review.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $37.77M
84.038 Federal Perkins Loan Program $4.77M
84.425 Education Stabilization Fund $4.01M
84.063 Federal Pell Grant Program $3.01M
47.074 Biological Sciences $735,684
84.007 Federal Supplemental Educational Opportunity Grants $465,027
59.037 Small Business Development Centers $317,694
93.859 Biomedical Research and Research Training $288,880
84.033 Federal Work-Study Program $270,647
84.365 English Language Acquisition State Grants $98,682
93.865 Child Health and Human Development Extramural Research $56,285
47.049 Mathematical and Physical Sciences $52,173
47.076 Education and Human Resources $50,246
47.075 Social, Behavioral, and Economic Sciences $40,660
93.732 Mental and Behavioral Health Education and Training Grants $35,220
93.837 Cardiovascular Diseases Research $2,969