Finding 391957 (2023-008)

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Requirement
I
Questioned Costs
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Year
2023
Accepted
2024-04-01
Audit: 302137
Organization: Presbyterian College (SC)
Auditor: Bdo USA PC

AI Summary

  • Core Issue: The College lacks a formal procurement policy that meets federal standards.
  • Impacted Requirements: This non-compliance with 2 CFR 200 procurement standards could lead to issues with federal funding.
  • Recommended Follow-Up: The College should create and implement a documented procurement policy that aligns with federal guidelines.

Finding Text

Federal Program Information: COVID – Coronavirus State and Local Fiscal Recovery Funds (ALN #21.027) Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation): Procurement: The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of 2 CFR 200.318, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. Condition: The College did not have a formal procurement policy in place documenting procedures that conform to the procurement standards in the Uniform Guidance. Cause: Lack of administrative oversight with respect to procurement process. Effect or Potential Effect: The College is not in compliance with procurement standards. Questioned Costs: None. Context: The College did not have a formal procurement policy in place documenting procedures that conform to the procurement standards in the Uniform Guidance. Identification as a Repeat Finding: There was no similar finding identified during the prior year. Recommendation: We recommend the College develop and implement a procurement policy conforming to procurement standards. Views of Responsible Officials:

Corrective Action Plan

Individuals Responsible for Corrective Action Plan Daniel Hall (Interim Vice President for Finance and Administration) Libby Shull, CPA (Controller) April Baur (Director of Student Financial Aid) Kevin Crider (Chief Information Officer) Vicky Wilson (Registrar) Finding 2023-008 The College did not have a formal procurement policy in place documenting procedures that conform to the procurement standards in the Uniform Guidance. Corrective Action Plan: The College obtained multiple quotes for a Wi-Fi refresh project. The Chief Information Officer, under the guidance of the Vice President of Finance and Administration, analyzed these quotes and determined that one of them most closely met the needs of the College. This quote was submitted to Laurens County as part of the ARP Infrastructure Application, prepared by the College’s Corporate & Foundation Relations Officer. After Laurens County granted the funding for the Wi-Fi project to the College, the College moved forward with the vendor and scope of work laid out in the quote. However, the College does recognize that it did not adhere to all aspects of the Federal Procurement Policy. The Vice President of Finance and Administration, along with the Controller, will both implement a procurement policy for any purchases made with Federal funds that satisfies the requirements laid out in the Federal Procurement Policy and also educate any faculty/staff involved in purchasing products/services involving Federal funds.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
10.766 Community Facilities Loans and Grants $58.41M
84.268 Federal Direct Student Loans $15.54M
84.063 Federal Pell Grant Program $1.45M
21.027 Coronavirus State and Local Fiscal Recovery Funds $593,347
84.033 Federal Work-Study Program $129,877
93.859 Biomedical Research and Research Training $121,441
84.007 Federal Supplemental Educational Opportunity Grants $107,905
47.050 Geosciences $52,754
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $7,544
43.008 Undergraduate Student Research Award $7,500
43.008 Space Grant Campus Director $1,500
84.038 Federal Perkins Loan Program $0