Finding Text
Federal Agency: U.S. Department of Education
Federal Program Name: Education Stabilization Fund – Higher Education Emergency Relief Fund – Minority Serving Institutions and Higher Education Institutional Aid – Fostering Inclusive Excellence for STEM Achievement
Assistance Listing Number: 84.425L, 84.031C
Award Period: July 01, 2022 – June 30, 2023
Type of Finding:
Material Weakness in Internal Control over Compliance, Other Matters
Criteria or specific requirement: The Uniform Administrative Guidance, Cost Principals, and Requirements for Federal Awards (Uniform Guidance) became effective for grants or incremental funding made on or after December 26, 2014. Entities are now required to have written policies and procedures in place over certain compliance requirements. Compliance requirements that have been significantly affected due to the changes in Uniform Guidance include allowable costs, procurement, and subrecipient monitoring.
Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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.
Condition: The University had not consistently performed requirements for procurement and suspension and debarment as outlined in the Uniform Grant Guidance.
Questioned costs: None.
Context: The University had not implemented formal, written policies and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment.
Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for procurement and suspension and debarment.
Effect: Procurements are not being made and suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance.
Repeat finding: Yes, 2022-003 for 84.425L only.
Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for procurement and suspension and debarment to ensure the University is following requirements.
Views of responsible officials: Management agrees with the finding.