Finding Text
Finding #: 2022-002 Funding Year(s): 7/1/2021 ? 6/30/2022 Education Stabilization Fund (ESF) (FAL #84.425L, 84,425F, 84,825E) Award Numbers: P425L200075-20C; P425F201063-20B; P425E200786-20B Federal Agency: U.S. Department of Education Type of Finding: Procurement - Internal Control (Material Weakness) Criteria: In accordance with 2 CFR section 200.318, the entity must establish policies for procurement of equipment, real property and other services funded by federal funds. The procurement records and files for purchases in excess of the micro purchase threshold shall include at the minimum the following items: the basis for contractor selection, justification for lack of competition when competitive bids are not obtained, and basis for award cost or price. In addition, award recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. To ensure this is done, recipients should utilize the Excluded Parties List System website. Condition/Context: From a non-statistical sample of two (2) vendors subjected to testing, we determined that rate quotations and rationale for limited competition were not retained for either vendor. It was also determined that there was no documentation retained regarding verification of vendor suspension or debarment for either vendor. Cause/Effect: Per discussion with Management, the entity has the processes designed via the Policies and Procedures provided, however, there is not a formal process established to document the performance of such controls. We note that inadequate controls could result in a reasonable possibility that the entity would not be able to detect and correct noncompliance in a timely manner. Questioned Costs: None noted. Identification as a Repeat Finding: Repeat finding. See prior year finding 2021-002. Recommendation: We recommend implementing a system of review and approval controls to complement the design of processes over the procurement, suspension, and debarment compliance requirements. In addition, we recommend that the University retain documentation regarding procurement decisions including rate quotations and verification of vendor suspension and debarment checks. Views of Responsible Official: Management agrees with finding.