Finding 25145 (2022-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2022-12-14
Audit: 24179
Organization: Rivier University (NH)

AI Summary

  • Core Issue: The University failed to verify that vendors exceeding $25,000 were not suspended or debarred from federal programs as required.
  • Impacted Requirements: Compliance with 2 CFR, Part 200, which mandates checking the System for Award Management (SAM) for covered transactions.
  • Recommended Follow-Up: Ensure the University adheres to its verification process for vendors and maintains documentation of SAM checks.

Finding Text

Finding Number:2022-003 Information on the Federal Program: Federal Agency: United States Department of Education (ED) Program Name: COVID-19 ? Education Stabilization Funds (Part B) AL: 84.425 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2022 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, the institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted that management did not review the SAM for vendors and employees meeting the covered transaction threshold as is defined in their year-end close checklist. Context: We noted there were 3 vendors exceeding $25,000 funded by the program. Based on our testing, none of the vendors exceeding the $25,000 limit were included in the SAM and received payments funded by the University?s major programs. Questioned Costs: None. Cause and Effect: The University was aware of the requirement to verify vendors and employees and they have a process established as part of their year-end close, but the review was not completed. Since this process was not performed, there is a greater risk of vendors and employees that are included on the SAM being disbursed funds through federal funds Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the University follow established procedures for comparing vendors and employees against the SAM and maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Corrective Action Plan

Finding 2022-003 Corrective Action Plan The Controller will review and revise current processes to ensure documented review of vendors and employees against SAM prior to expending against federal awards. Updated procedures will be documented and Controller?s Office staff will be trained on the new procedures. Responsible Party: Steven Perrotta Vice President for Finance and Administration Phone: (603) 897-8215 Anticipated Completion Date: February 28, 2023

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 25142 2022-004
    Significant Deficiency Repeat
  • 25143 2022-005
    Significant Deficiency Repeat
  • 25144 2022-005
    Significant Deficiency Repeat
  • 601584 2022-004
    Significant Deficiency Repeat
  • 601585 2022-005
    Significant Deficiency Repeat
  • 601586 2022-005
    Significant Deficiency Repeat
  • 601587 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $14.82M
84.063 Federal Pell Grant Program $1.85M
84.425 Education Stabilization Fund $1.06M
93.732 Mental and Behavioral Health Education and Training Grants $371,893
93.359 Nurse Education, Practice Quality and Retention Grants $355,522
84.038 Federal Perkins Loan Program $200,407
84.033 Federal Work-Study Program $116,905
84.007 Federal Supplemental Educational Opportunity Grants $92,698
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $80,942
93.264 Nurse Faculty Loan Program (nflp) $49,171
47.076 Education and Human Resources $44,968
93.389 National Center for Research Resources $19,635
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $13,168