Finding 31604 (2022-002)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-27
Audit: 30718
Organization: Eastern Oregon University (OR)

AI Summary

  • Core Issue: The University failed to document the rationale for contractor selection in one of six procurement samples involving federal funds.
  • Impacted Requirements: Noncompliance with Uniform Guidance 2 CFR sections 200.320 and 200.318(i) regarding procurement procedures.
  • Recommended Follow-Up: Revise procurement processes to ensure compliance and proper documentation for all federal fund disbursements.

Finding Text

Criteria or specific requirement: Per Uniform Guidance 2 CFR sections 200.320 and 200.318(i); a nonfederal entity must have procedures that document the rationale for the method of procurement, selection of the contract type, basis for contractor selection, and the basis for the contract price. In addition, the guidance for the micro-purchase threshold is $10,000 unless other provisions have been followed allowing a higher threshold. Condition: During our testing of procurement procedures, we noted one item for which procurement procedures required for items purchased with federal funding were not followed. Questioned costs: None reported. Context: One of six samples tested did not have documentation to support the basis for the contractor selected for a small purchase transaction. Cause: The University did not follow procurement procedures required to be used when purchasing goods or services with federal funds because initially the item was purchased with non-federal funding. At a later time, a portion of the purchases was paid for with HEERF institutional funding. Effect: The University is not in compliance with procurement requirements to properly document the procurement rationale for goods or services paid for with federal funds. Repeat Finding: Yes. Prior year finding 2021-002 Recommendation: We recommend the University revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds. View of Responsible Official: The University agrees with the finding.

Corrective Action Plan

Recommendation: We recommend the University revise their processes to establish procedures that will ensure procurement policies are properly followed and documented for all general disbursements paid for by federal funds. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: EOU is currently reviewing the institutional procurement process to determine if a single set of guidelines should be in place, rather than federal vs non-federal funding. Using a single set of guidelines would create a uniform procurement process, no matter the funding source, however additional options are currently being investigated. Name(s) of the contact person(s) responsible for corrective action: Haley Evans, Controller Planned completion date for corrective action plan: October 2023

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 31603 2022-001
    Significant Deficiency
  • 608045 2022-001
    Significant Deficiency
  • 608046 2022-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Direct Student Loans $12.38M
84.063 Federal Pell Grant Program $4.52M
93.600 Head Start $2.17M
84.425 Covid-19 - Education Stabilization Fund - Student Aid $1.87M
84.425 Covid-19 - Education Stabilization Fund - Institutional Support $1.74M
84.425 Covid-19 - Education Stabilization Fund - Geer $202,396
17.600 Mine Health and Safety Grants $164,176
10.558 Child and Adult Care Food Program $158,811
84.031 Higher Education Institutional Aid $146,394
84.425 Covid-19 - Education Stabilization Fund - Sip $140,106
47.076 National Science Foundation $123,945
84.007 Federal Supplemental Educational Opportunity Grants $115,477
84.033 Federal Work-Study Program $109,157
47.074 National Science Foundation $66,237
16.575 Crime Victim Assistance $64,124
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $60,463
59.037 Small Business Development Centers $26,417
84.379 Teacher Education Assistance for College Ad Higher Education Grants $3,772
93.243 Substance Abuse and Mental Health Services - Projects of Regional and National Significance $2,339