Finding Text
COVID-19 ? Education Stabilization Fund, Assistance Listing No. 84.425 U.S. Department of Education Award Year 2021-2022 Criteria or specific requirement ? Procurement 2 CFR 200.320 Condition ? The College charged services to the institutional portion of the award that had not been procured. Questioned Costs ? ALN 84.425F - $32,061 ? Questioned costs include amounts charged to the grant for an existing contract that was not procured after the Louisiana State of Emergency for COVID-19 ended, so the noncompetitive procurement method no longer qualified. Context ? Out of $210,105 expenses that were charged to the institutional portion of the grant and were above the College?s micro-purchase threshold, 3 key items of contracts totaling $166,574, were selected for testing. Of the contracts tested, one contract was not procured in accordance with the Uniform Guidance. When the contract was originally entered into, it was not paid for with federal funds, so the College wasn?t required to follow the procurement guide lines. At the start of the pandemic, the contract was expanded to be able to provide on-line instruction, and therefore the College used the noncompetitive procurement option given the public exigency and emergency circumstance that would not permit a delay resulting from publicizing a competitive solicitation. The Louisiana State of Emergency ended in March 2022 and the College did not have a plan in place to procure the services after noncompetitive procurement flexibility ended. Effect ? Expenses were charged to the grant that were not procured in accordance with the Uniform Guidance. Cause ? The College did not follow their procurement policy for expenses charged to federal awards. Identification of repeat finding, if applicable ? N/A Recommendation ? Management should review contracts being charged to federal grants to ensure they have followed their procurement policy. Views of responsible officials and planned corrective actions ? The College concurs with the finding and recommendation and will review contracts supported by federal grants to ensure they meet institutional and federal guidelines. The College will also review our current procurement policies and make any adjustments that may be necessary.