Finding Text
2022 ? 004 ? Higher Education Emergency Relief Fund (HEERF) ? Procurement, Suspension and Debarment Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Fund Assistance Listing Numbers: 84.425F Award Period: July 1, 2021 through June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where Colleges should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College has a procurement policy, but this policy was not followed. The College failed to obtain, or document why it failed to obtain, at least two price or rate quotations from two qualified sources prior to making the purchase. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred. Questioned Costs: None Context: The College did not have appropriate documentation that met the procurement and suspension and debarment federal requirements. Cause: The College had difficulty acquiring testing supplies and purchased these whenever they were able. The College had difficulty finding multiple vendors at any given time. Effect: The College did not have appropriate documentation that met the procurement and suspension and debarment federal requirements. Repeat Finding: No Recommendation: We recommend that the College review their procurement policy to ensure a process is in place to follow it in the future. We also recommend a policy be drafted surrounding suspension and debarment that includes all federal requirements. Views of Responsible Officials: There is no disagreement with the audit finding.