Finding Text
2023 – 005
Federal Agency: Department of Education
Federal Program Name: Higher Education Aid – Title III
Assistance Listing Numbers: 84.031
Federal Award Identification Number and Year: P031E200019, P031B170023 and P031B220048, grants were awarded within the 2022-23 award year.
Award Period: July 1, 2022, through June 30, 2023
Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters
Criteria or Specific Requirement:
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. This verification may be accomplished by (1) checking the System for Award Management (SAM) Exclusions maintained by the General Services Administration (GSA) and available at SAM.gov, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300).
Condition:
During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested.
Questioned Costs:
N/A
Context:
During our testing of suspension and debarment, we noted the University did not have support for debarment checks two of the six vendors tested.
Cause:
The University did not have support to verify debarment checks were completed before entering into agreements or occurring expenditures for two of the six vendors selected.
Effect:
Suspended or debarred vendors could have been charged to the grant, resulting in unallowable expenditures occurring.
Repeat Finding:
No.
Recommendation:
The University should evaluate their procedures surrounding the maintenance of suspension and debarment checks.