Finding 405897 (2023-001)

Significant Deficiency
Requirement
I
Questioned Costs
$1
Year
2023
Accepted
2024-07-01
Audit: 311455
Organization: Wiyn Consortium, Inc. (AZ)

AI Summary

  • Core Issue: WIYN lacked complete documentation for one procurement file, missing the required cost and price analysis for a $50,615 transaction.
  • Impacted Requirements: This finding violates WIYN’s policy and 2 CFR 200 Uniform Guidance, which mandate detailed records for procurement processes.
  • Recommended Follow-Up: Management should review procurement processes to identify gaps and ensure all files comply with policies and regulations.

Finding Text

Criteria: In accordance with 2 CFR 200 Uniform Guidance (UG), General Procurement Standards require a non-Federal entity to maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: Rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. WIYN’s policy for cost and price analysis of procurements under $150,000 is as follows: In the case where there is adequate competition (at least two quotes, and ideally three or more quotes, for procurements under $150,000), documentation of the different proposed prices received and the basis for vendor selection shall be deemed to be an adequate price analysis. Condition/Context: For 1 of the 5 procurement files selected, WIYN did not have the complete procurement file documentation available for review. Documentation was provided of the process and results related to the vendor selected, however, evidence of the cost and price analysis required under WIYN’s policy for a procurement under $150,000 was not provided. It seemed likely that these steps were performed but not documented. Questioned costs: $50,615 Cause: WIYN worked with an insurance broker during the selection and renewal process and documentation shows the timing and elements of the process as well as the results but did not include documentation of the cost and price analysis required under WIYN’s policy. Repeat Finding: No Recommendation: We recommend management review the process in place to identify any gaps and inconsistencies with procurement files in comparison to WIYN’s policies and UG requirements and ensure relevant controls are properly designed and operating effectively. In addition, management should ensure all active procurement files are in compliance with WIYN’s policies. Views of responsible officials: See corrective action plan.

Corrective Action Plan

Mathematical and Physical Sciences – Assistance Listing No. 49.049 Recommendation: We recommend management review the process in place to identify any gaps and inconsistencies with procurement files in comparison to WIYN’s policies and UG requirements and ensure relevant controls are properly designed and operating effectively. In addition, management should ensure all active procurement files are in compliance with WIYN’s policies. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action planned/taken in response to finding: WIYN utilizes Marsh as an insurance brokerage service to evaluate, recommend best value, and negotiate policies with the insurance carriers. WIYN stated a preference to renew with Hartford during renewal strategy sessions with Marsh because of the requirements for continuity of service, quality of service, and the understanding of WIYN’s operations. The price/quote was assessed against market trends, but evidence of this comparison was not maintained by Marsh or WIYN. In response to the finding, WIYN will require Marsh to provide evidence that policies are marketed to multiple carriers at least once every 3-years, including an explanation of market conditions when carrier availability is limited. Name(s) of the contact person(s) responsible for corrective action: John Salzer Planned completion date for corrective action plan: 10/01/2024

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 982339 2023-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
47.049 Mathematical and Physical Sciences, Cooperative Agreement No. Ast-1546092 - Csa Ast-1559596 $2.35M