Finding 389450 (2023-002)

2023 – 002: Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2023 Award Period: 05/28/2020 – 06/30/2024 Type of Finding: Significant Deficiency in Internal Control over Compliance; Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall “establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in “Standards for Internal Control in the Federal Government” issued by the Comptroller General of the United States or the “Internal Control Integrated Framework”, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established an effective internal control system related to the grant agreement and the Procurement, Suspension, and Debarment compliance requirement. The College’s current procurement policy includes a documented process to ensure vendors meet suspension and debarment requirements. However, there was a noted lack of documentation that the College had timely searched all applicable vendors on the System for Award Management (SAM) to ensure that the College’s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but the documented process to ensure suspension and debarment compliance was not documented in a timely manner. Cause: The current policy and internal control structure includes a process for ensuring suspension and debarment requirements are met for all required vendors; however, the verification was not documented in a timely manner. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: Yes, 2022-003 Recommendation: We recommend that the College implement a system of internal controls over suspension and debarment that will ensure the processes are followed in a timely manner. Views of responsible officials: Management agrees with the finding.