Finding 398938 (2023-002)

Material Weakness
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-05-30
Audit: 307540
Organization: The Land Institute (KS)
Auditor: Forvis LLP

AI Summary

  • Core Issue: The Institute's micro-purchase threshold of $25,000 exceeds the allowable limit of $10,000 set by federal regulations, leading to non-compliance.
  • Impacted Requirements: Lack of documented compliance with procurement policies and failure to conduct suspension and debarment checks on vendors before purchases with federal funds.
  • Recommended Follow-Up: Revise procurement policies to align with federal guidelines and ensure checks on vendor eligibility are performed prior to purchases.

Finding Text

Federal Assistance Number – Research and Development Cluster, Multiple Federal Grantors, Criteria or Specific Requirement – Procurement and Suspension and Debarment In accordance with 2 CFR Section 200.320, a non-federal entity must have and use documented procurement procedures consistent with the standards of Sections 200.317 - 200.320. These standards include a micro-purchase threshold of $10,000 and policies for formal procurement and non competitive procurement. Additionally, in accordance with 2 CFR Section 180.220, 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 Institute's micro-purchase threshold of $25,000 included in the policy is in excess of 2 CFR Section 200.320, and the Institute is not eligible for the increase to the micro-purchase threshold. Formal procurement and non competitive procurement policies have been documented; however, formalized documentation supporting the Institute is in compliance with policies did not exist. Additionally, there was no suspension and debarment check completed prior to purchases made with federal funds. Questioned Costs – Total questioned costs of $45,000 were identified and represents value of equipment purchased for which the procurement process could not be supported in line with the Institute's policy and Uniform Guidance. Context – One purchase of $45,000 out of a total of three purchases totaling $152,986 subject to procurement requirements in 2023 was selected for testing. The Institute could not provide documentation supporting their purchase adhered to policies for formal procurement or non competitive procurement. Furthermore, a check of the vendor's suspension and debarment status prior to the purchase was not completed. The sample was not intended to be, and was not, a statistically valid sample. Effect – Federal funds could be used to make an unauthorized purchase including paying an entity that is suspended or debarred. Cause – The Institute's procurement policies are not in accordance with the Uniform Guidance, nor are there controls in place to ensure policies are followed, and lastly, there are no controls to ensure suspension and debarment checks are performed on vendors receiving federal funds. Identification as a Repeat Finding, if applicable – Not a repeat finding. Recommendation – Policies and procedures should be modified to ensure that procurement policies and suspension and debarment checks on vendors are performed prior to making purchases with federal funds and are in alignment with the Uniform Guidance requirements. Views of Responsible Official and Planned Corrective Actions – Management agrees with the stated finding and has implemented a corrective action plan.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 398937 2023-002
    Material Weakness
  • 398939 2023-002
    Material Weakness
  • 398940 2023-002
    Material Weakness
  • 398941 2023-002
    Material Weakness
  • 398942 2023-002
    Material Weakness
  • 398943 2023-002
    Material Weakness
  • 398944 2023-002
    Material Weakness
  • 398945 2023-002
    Material Weakness
  • 398946 2023-002
    Material Weakness
  • 398947 2023-002
    Material Weakness
  • 398948 2023-003
    Material Weakness
  • 398949 2023-003
    Material Weakness
  • 398950 2023-003
    Material Weakness
  • 398951 2023-003
    Material Weakness
  • 398952 2023-003
    Material Weakness
  • 398953 2023-003
    Material Weakness
  • 398954 2023-003
    Material Weakness
  • 398955 2023-003
    Material Weakness
  • 398956 2023-003
    Material Weakness
  • 398957 2023-003
    Material Weakness
  • 398958 2023-003
    Material Weakness
  • 398959 2023-004
    Material Weakness
  • 398960 2023-004
    Material Weakness
  • 398961 2023-004
    Material Weakness
  • 398962 2023-004
    Material Weakness
  • 398963 2023-004
    Material Weakness
  • 398964 2023-004
    Material Weakness
  • 398965 2023-004
    Material Weakness
  • 398966 2023-004
    Material Weakness
  • 398967 2023-004
    Material Weakness
  • 398968 2023-004
    Material Weakness
  • 398969 2023-004
    Material Weakness
  • 975379 2023-002
    Material Weakness
  • 975380 2023-002
    Material Weakness
  • 975381 2023-002
    Material Weakness
  • 975382 2023-002
    Material Weakness
  • 975383 2023-002
    Material Weakness
  • 975384 2023-002
    Material Weakness
  • 975385 2023-002
    Material Weakness
  • 975386 2023-002
    Material Weakness
  • 975387 2023-002
    Material Weakness
  • 975388 2023-002
    Material Weakness
  • 975389 2023-002
    Material Weakness
  • 975390 2023-003
    Material Weakness
  • 975391 2023-003
    Material Weakness
  • 975392 2023-003
    Material Weakness
  • 975393 2023-003
    Material Weakness
  • 975394 2023-003
    Material Weakness
  • 975395 2023-003
    Material Weakness
  • 975396 2023-003
    Material Weakness
  • 975397 2023-003
    Material Weakness
  • 975398 2023-003
    Material Weakness
  • 975399 2023-003
    Material Weakness
  • 975400 2023-003
    Material Weakness
  • 975401 2023-004
    Material Weakness
  • 975402 2023-004
    Material Weakness
  • 975403 2023-004
    Material Weakness
  • 975404 2023-004
    Material Weakness
  • 975405 2023-004
    Material Weakness
  • 975406 2023-004
    Material Weakness
  • 975407 2023-004
    Material Weakness
  • 975408 2023-004
    Material Weakness
  • 975409 2023-004
    Material Weakness
  • 975410 2023-004
    Material Weakness
  • 975411 2023-004
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
47.074 Biological Sciences $88,793
10.310 Agriculture and Food Research Initiative $84,682
10.307 Organic Agriculture Research and Extension Initiative $29,487
10.330 Alfalfa and Forage Research Program $24,843
10.001 Agricultural Research-Basic and Applied Research $14,315
10.215 Sustainable Agriculture Research and Education $9,322