Finding 22100 (2022-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-09

AI Summary

  • Core Issue: The College did not have adequate controls to review covered transactions for suspension and debarment before making payments over $25,000.
  • Impacted Requirements: This violates 2 CFR 200.303, which mandates effective internal controls to ensure compliance with federal regulations regarding suspended or debarred parties.
  • Recommended Follow-Up: Implement stronger monitoring and documentation processes to ensure compliance with suspension and debarment requirements for all vendors.

Finding Text

Item 2022-001 ? Suspension and Debarment Higher Education Emergency Relief Fund (HEERF) ? ALN # 84.425E, 84.425F, & 84.425M U.S. Department of Education WIA/WIOA Dislocated Worker National Reserve Demonstration Grants ? ALN # 17.280 U.S. Department of Labor Criteria ? 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement 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 section 180.220. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Condition ? Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment prior to payment being made. Cause ? The College lacked sufficient controls to ensure evidence of compliance with suspension and debarment. Questioned Costs ? Not determinable Effect ? Failure to properly verify that a party has not been suspended or debarred prior to expenditure being made could result in unallowable expenditures and disallowed costs. Recommendation ? We recommend that controls should be put into place to better monitor and document the compliance of vendors for suspension and debarment.

Corrective Action Plan

The Lurleen B. Wallace Community College (the College) respectfully submits the following corrective action plan for the year ended September 30, 2022. Carr, Riggs & Ingram, LLC 1117 Boll Weevil Circle Enterprise, AL 36330 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. FINDINGS ? FINANCIAL STATEMENT AUDIT No such findings in the current year. FINDINGS ? FEDERAL AWARDS PROGRAM AUDITS Item 2022-001 ? Suspension and Debarment Higher Education Emergency Relief Fund (HEERF) ? CFDA # 84.425E, 84.425F, & 84.425M U.S. Department of Education Recommendation: 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? Non-Federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement 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 section 180.220. All nonprocurement transactions entered into by a recipient (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215. Adequate controls were not in place to provide for proper review of covered transactions for suspension and debarment. Covered transactions, over $25,000 paid with grant funding were not reviewed for suspension and debarment prior to payment being made. We recommend management implement procedures to monitor and document the compliance of vendors for suspension and debarment. The Chief Financial Officer, Lisa Carnley, should review documentation for suspension and debarment monitoring as part of the bid process prior to expenditures being made. Action Taken: Management has reviewed the requirements of 2 CFR Section 200.303 relating to covered transactions and ensuring no such transactions are made with parties that are suspended or debarred and agrees with the recommendation. Management has implemented additional procedures, effective November 14, 2022, stating that the Chief Financial Officer will review documentation for suspension and debarment monitoring as part of the bid process prior to expenditures being made.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 22101 2022-001
    Material Weakness
  • 22102 2022-001
    Material Weakness
  • 22103 2022-001
    Material Weakness
  • 598542 2022-001
    Material Weakness
  • 598543 2022-001
    Material Weakness
  • 598544 2022-001
    Material Weakness
  • 598545 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $3.66M
17.280 Workforce Investment Act (wia) Dislocated Worker National Reserve Demonstration Grants $1.16M
84.425 Covid-19, Education Stabilization Fund $198,006
84.007 Federal Supplemental Educational Opportunity Grants $127,002
84.048 Career and Technical Education -- Basic Grants to States $122,639
17.259 Wia Youth Activities $85,935
84.033 Federal Work-Study Program $66,281
17.258 Wia Adult Program $44,882
84.002 Adult Education - Basic Grants to States $6,883
10.699 Partnership Agreements $5,006