Finding 2022-004 ? Insufficient Procurement Policy The Institution?s documented Procurement Policy did not contain the required elements set forth by the Department. The Institution agrees with the finding. The Institute agrees that while they thought that they were following the Department?s guidance in-regards-to the procurement of HERFF funds, they misinterpreted the information which created the findings. Now that the Institute has a better understanding of the process of HERFF procurement and disbursement, and if additional funding is available in the future, the Institute will change its procedures to match those of the Department as learned from the errors found in this audit.