Finding Text
2023-005 Failure to Comply with Procurement Policy
Finding Type: Material Weakness in Internal Control over Major Programs
CFDA#: 84.031B
Title III Part B, Strengthening Historically Black Colleges and Universities
Award Year: 2023
CFDA#: 84.425F/84.425J
CARES Act: Higher Education Emergency Relief Fund (HEERF)
Award Year: 2023
Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $250,000 and three quotes for purchases over $10,000.
Condition: The College did not follow its procurement policy for the year ended June 30, 2023. We found that disbursements over $10,000 did not have competitive quotes nor purchases of $250,000 were not put out for bid when required.
Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $872,309 for Title III and $556,022 for HEERF.
Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College’s policy meets the standards as noted above.
Recommendation: We recommended that management be familiar with procurement polices and ensure they are being adhered to.
View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to the procurement policy