Finding Text
Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F200150 - 2022 Award Period: July 01, 2021 - June 30, 2022 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: It was noted that the University has not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment. Questioned costs: None. Context: It was noted that the University has not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment. Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment which could cause the University to be in noncompliance with certain federal awards they receive. Effect: The University could potentially be in noncompliance with certain regulations. Repeat Finding: No. Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for procurement and suspension and debarment to limit the risk for noncompliance. Views of responsible officials: See corrective action plan.