FAC Explorer

Finding 389626 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-03-29
Audit: 300523
Organization: University of Pittsburgh of the Commonwealth Sys. of Higher Education (PA)
Auditor: Kpmg LLP

AI Summary

  • Core Issue: University purchasers bypassed required competitive bidding for purchases over $10,000, violating procurement policies.
  • Impacted Requirements: Non-compliance with 2 CFR 200.320(a)(2)(i) and 2 CFR 200.303 regarding procurement procedures and internal controls.
  • Recommended Follow-up: Reinforce procurement training for all departments and evaluate limits on OPR form usage to strengthen controls by June 30, 2024.

Finding Text

Federal Program Research and Development Cluster ALNs 12.RD, 81.087, 93.RD, 93.173, 93.273, 93.336, 93.837, 93.839, 93.847, 93.855, 93.865, 93.866 Federal Agencies Department of Defense, Department of Energy, Department of Health and Human Services Pass-through Entity Various Federal Award Year Ranges from September 23, 2016 – September 30, 2025 Criteria or Requirement 2 CFR 200.320(a)(2)(i) states that small purchase procedures for non-Federal entities includes the acquisition of property or services, the aggregate dollar amount of which is higher than the micro-purchase threshold but does not exceed the simplified acquisition threshold. If small purchase procedures are used, price or rate quotations must be obtained from an adequate number of qualified sources as determined appropriate by the non-Federal entity. The University's procurement policies and procedures for small purchases requires the University's purchaser to conduct and select a supplier through a competitive bidding process for items ranging between $10,000 and $50,000. The University's procurement policies state that competitive bidding is not required when purchasing goods or services from a University contracted supplier or for directed sole source purchases. 2 CFR 200.303 requires non-Federal entities receiving Federal awards to 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. Effective internal controls should include procedures to comply with the University's purchasing policies and procedures. Condition Found, including perspective University purchasers have the ability to request payment for goods or services purchased by submitting a requisition in Panther Express for the order to be routed to the Purchasing Department for review and approval, or an other payment request (OPR) specialty form is completed and submitted with the invoice in Panther Express which bypasses the Purchasing Department to Payment Processing for review and check processing. We identified one out of the 40 procurements sampled for testing did not have the required competitive bidding documentation for purchases ranging between $10,000 and $50,000 because the University purchaser utilized the OPR form bypassing the Purchasing Department review. The Purchasing Department subsequently ran queries from its system for a list of all Research and Development cluster (R&D) expenditures exceeding $10,000 that utilized the OPR form that did not have the required competitive bidding documentation and identified 24 purchases (including our sampled item) from multiple University purchasers totaling approximately $402,000, which is 0.04% of total R&D expenditures. None of these purchases were from a University contracted supplier, and there was no directed or sole source documentation filed, which is a violation of the University procurement policies. Cause University purchasers did not follow University payment procedures for procurements exceeding $10,000 to be reviewed and approved by the Purchasing Department prior to disbursement. Effect Failure to properly follow University payment and procurement policies could result in noncompliance and/or the use of an inappropriate vendor. Questioned Costs No questioned costs were identified. Statistical Sample The sample was not intended to be, and was not, a statistically valid sample. Repeat Finding No. Recommendation We recommend that the University reinforce its procurement policies and procedures to all departments to ensure all the University’s procurement policies are being followed. Views of Responsible Officials Management agrees with the finding and the following corrective actions are being taken to minimize future risks. First, although all purchasers are required to complete training on purchasing and payment policies prior to obtaining system access, a refresher policy training will be provided to the 13 departments in which exceptions were discovered along with a reminder communication to all the approximately 4,300 department purchasers. This will be completed by June 30, 2024. Second, for certain types of purchases such as those involving intellectual property rights, suppliers may complete work in good faith and request payment in the absence of a purchase order or contract. A new procedure has been instituted requiring the department/supplier to execute a contract prior to payment in order to minimize legal risks to the University and its funding agencies. This new procedure is complete. Finally, we are analyzing legitimate uses of the OPRS form and evaluating whether placing a maximum dollar limit, such as $5,000, for the use of the form will further strengthen internal controls. The evaluation will be completed by June 30, 2024. Implementing maximum dollar limits on the OPRS form will require IT changes, and therefore implementation will not occur until December 31, 2024.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 389613 2023-001
    Significant Deficiency
  • 389614 2023-001
    Significant Deficiency
  • 389615 2023-001
    Significant Deficiency
  • 389616 2023-001
    Significant Deficiency
  • 389617 2023-001
    Significant Deficiency
  • 389618 2023-001
    Significant Deficiency
  • 389619 2023-001
    Significant Deficiency
  • 389620 2023-001
    Significant Deficiency
  • 389621 2023-001
    Significant Deficiency
  • 389622 2023-001
    Significant Deficiency
  • 389623 2023-001
    Significant Deficiency
  • 389624 2023-001
    Significant Deficiency
  • 389625 2023-001
    Significant Deficiency
  • 389627 2023-001
    Significant Deficiency
  • 389628 2023-002
    Significant Deficiency
  • 389629 2023-002
    Significant Deficiency
  • 966055 2023-001
    Significant Deficiency
  • 966056 2023-001
    Significant Deficiency
  • 966057 2023-001
    Significant Deficiency
  • 966058 2023-001
    Significant Deficiency
  • 966059 2023-001
    Significant Deficiency
  • 966060 2023-001
    Significant Deficiency
  • 966061 2023-001
    Significant Deficiency
  • 966062 2023-001
    Significant Deficiency
  • 966063 2023-001
    Significant Deficiency
  • 966064 2023-001
    Significant Deficiency
  • 966065 2023-001
    Significant Deficiency
  • 966066 2023-001
    Significant Deficiency
  • 966067 2023-001
    Significant Deficiency
  • 966068 2023-001
    Significant Deficiency
  • 966069 2023-001
    Significant Deficiency
  • 966070 2023-002
    Significant Deficiency
  • 966071 2023-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $229.31M
84.063 Federal Pell Grant Program $26.23M
93.658 Foster Care_title IV-E $10.12M
84.038 Federal Perkins Loan Program $8.39M
84.033 Federal Work-Study Program $3.11M
93.398 Cancer Research Manpower $2.59M
93.364 Nursing Student Loans $2.57M
16.560 National Institute of Justice Research, Evaluation, and Development Project Grants $1.77M
84.305 Education Research, Development and Dissemination $1.07M
93.RD Other Substance Abuse and Mental Health Services Administration $1.01M
47.079 Office of International Science and Engineering $927,730
84.015 National Resource Centers Program for Foreign Language and Area Studies Or Foreign Language and International Studies Program and Foreign Language and Area Studies Fellowship Program $893,466
93.732 Mental and Behavioral Health Education and Training Grants $874,688
84.042 Trio_student Support Services $845,346
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $841,541
93.516 Affordable Care Act (aca) Public Health Training Centers Program $773,094
93.110 Maternal and Child Health Federal Consolidated Programs $733,552
12.006 National Defense Education Program $723,481
93.185 Immunization Research, Demonstration, Public Information and Education_training and Clinical Skills Improvement Projects $699,785
93.264 Nurse Faculty Loan Program (nflp) $619,939
93.788 Opioid Str $593,403
93.837 Cardiovascular Diseases Research $591,233
17.720 Disability Employment Policy Development $589,991
93.350 National Center for Advancing Translational Sciences $521,559
43.003 Exploration $499,757
12.357 Rotc Language and Culture Training Grants $499,351
93.336 Behavioral Risk Factor Surveillance System $496,558
93.211 Telehealth Programs $480,925
98.001 Usaid Foreign Assistance for Programs Overseas $448,334
12.750 Uniformed Services University Medical Research Projects $408,595
93.456 Cdc Undergraduate Public Health Scholars Program (cups): A Public Health Experience to Expose Undergraduates Interested in Minority Health to Public Health and the Public Health Professions $402,705
93.186 National Research Service Award in Primary Care Medicine $400,734
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $393,288
93.172 Human Genome Research $385,783
93.213 Research and Training in Complementary and Integrative Health $364,257
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) $361,062
93.669 Child Abuse and Neglect State Grants $361,037
59.037 Small Business Development Centers $326,353
84.007 Federal Supplemental Educational Opportunity Grants $317,417
93.353 21st Century Cures Act - Beau Biden Cancer Moonshot $307,488
93.RD Covid-19 Other Centers for Disease Control & Prevention $296,650
17.280 Workforce Investment Act (wia) Dislocated Worker National Reserve Demonstration Grants $292,013
43.002 Aeronautics $280,262
93.884 Grants for Primary Care Training and Enhancement $271,874
77.008 U.s. Nuclear Regulatory Commission Scholarship and Fellowship Program $266,033
45.169 Promotion of the Humanities_office of Digital Humanities $262,399
93.940 Hiv Prevention Activities_health Department Based $250,060
47.074 Biological Sciences $249,881
20.701 University Transportation Centers Program $242,678
93.U03 Other Substance Abuse and Mental Health Services Administration $237,378
93.600 Head Start $213,933
16.RD Other Department of Justice $209,621
93.233 National Center on Sleep Disorders Research $209,189
45.163 Promotion of the Humanities_professional Development $202,677
93.396 Cancer Biology Research $197,360
93.104 Comprehensive Community Mental Health Services for Children with Serious Emotional Disturbances (sed) $194,484
12.RD Other Advanced Research Projects Agency $183,909
94.026 National Service and Civic Engagement Research Competition $172,508
12.630 Basic, Applied, and Advanced Research in Science and Engineering $172,041
14.RD Other Department of Housing and Urban Development $167,674
97.132 Financial Assistance for Countering Violent Extremism $165,214
43.012 Space Technology $165,192
94.006 Americorps $156,352
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $155,223
47.083 Integrative Activities $153,193
93.359 Nurse Education, Practice Quality and Retention Grants $149,288
12.RD Other Defense Threat Reduction Agency $147,702
47.084 Nsf Technology, Innovation, and Partnerships $145,730
12.RD Other Department of the Navy $133,282
12.600 Community Investment $129,040
93.225 National Research Service Awards_health Services Research Training $124,540
84.021 Overseas Programs - Group Projects Abroad $122,355
84.217 Trio_mcnair Post-Baccalaureate Achievement $118,059
93.127 Emergency Medical Services for Children $114,146
20.205 Highway Planning and Construction $112,868
98.RD Other Agency for International Development $111,081
15.670 Adaptive Science $110,363
12.U04 Other Defense Health Agency $110,154
47.050 Geosciences $109,563
81.049 Office of Science Financial Assistance Program $104,003
93.U01 Other Centers for Disease Control and Prevention $103,225
12.420 Military Medical Research and Development $101,105
47.041 Engineering $100,329
16.838 Comprehensive Opioid Abuse Site-Based Program $99,519
93.648 Child Welfare Research Training Or Demonstration $96,916
47.RD Other National Science Foundation $93,438
21.008 Low Income Taxpayer Clinics $91,586
93.859 Biomedical Research and Research Training $91,166
64.051 Specially Adapted Housing Assistive Technology Grant Program $88,830
84.016 Undergraduate International Studies and Foreign Language Programs $87,247
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $86,277
64.U10 Other Department of Veterans Affairs $81,572
93.840 Translation and Implementation Science Research for Heart, Lung, Blood Diseases, and Sleep Disorders $79,896
93.395 Cancer Treatment Research $79,110
20.RD Other Department of Transportation $77,537
93.838 Lung Diseases Research $76,298
93.351 Research Infrastructure Programs $75,534
12.U06 Other National Security Agency $75,077
10.683 National Fish and Wildlife Foundation $74,995
43.007 Space Operations $74,324
93.342 Health Professions Student Loans, Including Primary Care Loans/loans for Disadvantaged Students $72,709
15.255 Science and Technology Projects Related to Coal Mining and Reclamation $70,795
47.049 Mathematical and Physical Sciences $70,171
47.070 Computer and Information Science and Engineering $70,052
93.914 Hiv Emergency Relief Project Grants $69,458
93.317 Emerging Infections Programs $67,422
12.U05 Other Department of the Navy $67,287
93.393 Cancer Cause and Prevention Research $66,354
93.307 Minority Health and Health Disparities Research $66,300
81.087 Renewable Energy Research and Development $66,279
93.RD Administration for Community Living $65,699
93.124 Nurse Anesthetist Traineeships $65,475
45.149 Promotion of the Humanities_division of Preservation and Access $62,641
93.143 Niehs Superfund Hazardous Substances_basic Research and Education $61,666
47.078 Polar Programs $58,669
12.431 Basic Scientific Research $54,477
93.121 Oral Diseases and Disorders Research $53,786
15.808 U.s. Geological Survey_ Research and Data Collection $50,756
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $50,425
93.670 Child Abuse and Neglect Discretionary Activities $49,496
45.161 Promotion of the Humanities_research $49,208
66.511 Office of Research and Development Consolidated Research/training/fellowships $49,068
43.008 Education $48,941
93.855 Allergy, Immunology and Transplantation Research $47,515
93.779 Centers for Medicare and Medicaid Services (cms) Research, Demonstrations and Evaluations $47,039
12.800 Air Force Defense Research Sciences Program $43,213
11.609 Measurement and Engineering Research and Standards $43,060
93.408 Nursing Faculty Loan Program - Arra $43,021
39.RD Other General Services Administration $41,967
93.113 Environmental Health $40,691
93.129 Technical and Non-Financial Assistance to Health Centers $39,993
43.RD Other National Aeronautics and Space Administration $39,312
93.426 Improving the Health of Americans Through Prevention and Management of Diabetes and Heart Disease and Stroke $39,301
12.300 Basic and Applied Scientific Research $39,275
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $38,090
93.226 Research on Healthcare Costs, Quality and Outcomes $37,720
93.399 Cancer Control $36,166
45.313 Laura Bush 21st Century Librarian Program $34,897
93.865 Child Health and Human Development Extramural Research $32,533
81.RD Other Department of Energy $31,951
93.315 Rare Disorders: Research, Surveillance, Health Promotion, and Education $31,418
84.200 Graduate Assistance in Areas of National Need $31,393
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $29,293
93.643 Children's Justice Grants to States $29,137
45.301 Museums for America $28,244
93.145 Aids Education and Training Centers $28,129
93.084 Prevention of Disease, Disability, and Death by Infectious Diseases $27,623
81.086 Conservation Research and Development $27,432
93.310 Trans-Nih Research Support $27,409
93.867 Vision Research $26,927
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $26,415
64.RD Other Department of Veterans Affairs $24,298
93.RD Other Food and Drug Administration $24,220
93.847 Diabetes, Digestive, and Kidney Diseases Extramural Research $24,082
96.007 Social Security_research and Demonstration $23,888
12.RD Other Defense Health Agency $23,330
84.022 Overseas Programs - Doctoral Dissertation Research Abroad $22,546
93.173 Research Related to Deafness and Communication Disorders $22,078
93.879 Medical Library Assistance $21,626
93.RD Other Health Resources and Services Administration $21,595
23.U07 Other Appalachian Regional Commission $21,337
19.900 Aeeca/esf Pd Programs $20,863
81.089 Fossil Energy Research and Development $19,187
93.242 Mental Health Research Grants $19,169
10.558 Child and Adult Care Food Program $18,287
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $17,528
12.330 Science, Technology, Engineering & Mathematics (stem) Education, Outreach and Workforce Program $17,356
93.103 Food and Drug Administration_research $17,342
93.368 21st Century Cures Act - Precision Medicine Initiative $17,028
81.121 Nuclear Energy Research, Development and Demonstration $16,529
93.262 Occupational Safety and Health Program $15,929
93.069 Public Health Emergency Preparedness $15,392
93.989 International Research and Research Training $15,196
93.397 Cancer Centers Support Grants $14,234
43.001 Science $11,769
47.076 Education and Human Resources $11,516
45.024 Promotion of the Arts_grants to Organizations and Individuals $11,143
93.839 Blood Diseases and Resources Research $10,955
93.421 Strengthening Public Health Systems and Services Through National Partnerships to Improve and Protect the Nation’s Health $9,869
93.136 Injury Prevention and Control Research and State and Community Based Programs $9,652
81.135 Advanced Research Projects Agency - Energy $9,296
93.083 Prevention of Disease, Disability, and Death Through Immunization and Control of Respiratory and Related Diseases $9,127
20.200 Highway Research and Development Program $8,691
12.910 Research and Technology Development $7,481
84.411 Investing in Innovation (i3) Fund $7,312
12.360 Research on Chemical and Biological Defense $7,274
93.436 Well-Integrated Screening and Evaluation for Women Across the Nation (wisewoman) $7,128
93.738 Pphf: Racial and Ethnic Approaches to Community Health Program Financed Solely by Public Prevention and Health Funds $6,886
93.945 Assistance Programs for Chronic Disease Prevention and Control $5,686
47.075 Social, Behavioral, and Economic Sciences $5,597
99.RD Other Medicaid and Chip Payment and Access Commission $5,086
23.011 Appalachian Research, Technical Assistance, and Demonstration Projects $5,000
93.RD Other Department of Health and Human Services $3,148
93.077 Family Smoking Prevention and Tobacco Control Act Regulatory Research $2,523
66.509 Science to Achieve Results (star) Research Program $2,367
93.361 Nursing Research $1,870
84.229 Language Resource Centers $1,776
81.U08 Other Department of Energy $1,145
81.U09 Other Department of Energy $999
93.325 Paralysis Resource Center $875
93.991 Preventive Health and Health Services Block Grant $717
93.RD Other Centers for Disease Control & Prevention $300
11.307 Economic Adjustment Assistance $200
84.425 Education Stabilization Fund $25
93.866 Aging Research $-113
12.RD Other Department of the Air Force $-128
93.273 Alcohol Research Programs $-380
84.126 Rehabilitation Services_vocational Rehabilitation Grants to States $-653
93.977 Preventive Health Services_sexually Transmitted Diseases Control Grants $-685
10.001 Agricultural Research_basic and Applied Research $-974
93.RD Other National Institutes of Health $-1,652
45.312 National Leadership Grants $-2,870
10.310 Agriculture and Food Research Initiative (afri) $-3,790
93.279 Drug Abuse and Addiction Research Programs $-5,065
12.351 Basic Scientific Research - Combating Weapons of Mass Destruction $-8,563
93.U02 Other Substance Abuse and Mental Health Services Administration $-9,636
93.394 Cancer Detection and Diagnosis Research $-9,710
12.RD Other Department of Army $-14,230