Finding 24825 (2022-001)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-30
Audit: 23899
Organization: Rockhurst University (MO)
Auditor: Rubinbrown LLP

AI Summary

  • Core Issue: The University failed to keep proper documentation for vendor selection on three contracts under federal grant requirements.
  • Impacted Requirements: This violates 2 CFR section 200.3018, which mandates documented procurement procedures for federal grants.
  • Recommended Follow-Up: Management should create clear procurement policies and provide training to ensure compliance with federal grant documentation requirements.

Finding Text

Finding 2022-001 ? Material Weakness, Procurement Federal Assistance Listing No. 84.425F U.S. Department Of Education ESF Section 2 ? Higher Education (Higher Education Emergency Relief Fund (HEERF)) Criteria: 2 CFR section 200.3018 requires grantees to have and use documented procurement procedures in accordance with the Uniform Guidance for the acquisition of property or services under a federal grant. Condition: In our nonstatistical sample of 3 contracts, we noted 3 contracts for which the University did not retain documentation of their selection of qualified vendors under the simplified acquisition threshold. Cause: Management charged with oversight over the federal grant could not support their compliance with these procurement requirements under the Uniform Guidance. Additionally, controls over compliance were not designed effectively to ensure compliance with such grant requirements. Effect: Instances of noncompliance were not detected by management. Questioned Costs: Not applicable Context: 3 individual contracts ranging in amounts from $87,548 to $137,840 were purchased under the federal grant without maintaining proper documentation related to the requirements of the simplified acquisition threshold. Identification As A Repeat Finding: Not applicable. Recommendation: We recommend that management document its procurement policies for purchases under federal grants and hold training specific to these documented policies for those responsible for grant compliance. Views Of Responsible Officials/Corrective Action Plan (Unaudited): See the corrective action plan provided by management included with this report. Completion Date: June 2023 Contact Person: Kris Pace, Controller

Corrective Action Plan

Finding No. 2022-001 Corrective Action Plan University Response: The University concurs with the finding that proper procurement practices were not followed for one of the three purchases identified as non-compliant. For one of the other two purchases identified as non-compliant, the University sourced the expenditure from the largest provider for higher education audio and visual products nationally, which competitively offer special discounting and pricing to private and public institutions of higher education when possible. On the other purchase, the University sourced with one of three vendors previously used for this type of work that was able to provide the services needed in the required timeframe during the pandemic, when other vendors could not meet the demand. These services were needed for additional cleaning and sanitizing to avoid contacting a life threatening virus. Corrective Action: The University will develop specific procurement policies to be utilized when Federal funds are used and appropriate staff will be trained on these policies. Responsible Official: Kris Pace, Controller Anticipated Completion Date: June 30, 2023

Categories

Procurement, Suspension & Debarment Material Weakness

Other Findings in this Audit

  • 24826 2022-002
    Significant Deficiency
  • 601267 2022-001
    Material Weakness
  • 601268 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $19.40M
84.425 Education Stabilization Fund $4.44M
84.063 Federal Pell Grant Program $2.66M
84.038 Federal Perkins Loan Program $1.45M
93.364 Nursing Student Loans $217,960
84.007 Federal Supplemental Educational Opportunity Grants $210,796
84.033 Federal Work-Study Program $189,582
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $58,173
47.076 Education and Human Resources $37,911