Finding Text
Finding 2022-004 Department of Education Education Stabilization Fund - Higher Education Emergency Relief Fund ? Institutional Federal Financial Assistance Listing #84.425F P425F200756-20A and P425F200756-20B Procurement, Suspension and Debarment Material Weakness in Internal Control over Compliance Criteria: 2 CFR 200.303(a) of Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) establishes that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and conditions of the federal award. The nonfederal entity?s documented procurement procedures must conform to the procurement standards identified in 2 CFR 200.317 through 200.327. 2 CFR 200 Appendix II requires certain provisions be included in contracts if criteria are met. As outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition: The University?s procurement policy did not include all the required elements as outlined in the Uniform Guidance. Additionally, the University did not retain documentation to support the procedures it performed to ensure compliance with procurement, suspension, and debarment. Cause: The University does not typically use federal financial assistance to procure goods and services; consequently, certain elements required by the Uniform Guidance were missing. Effect: Lack of complete procurement, suspension, and debarment policies and not retaining documentation to support compliance with procurement, suspension, and debarment could result in procurements that do not conform with Uniform Guidance. Questioned Costs: None reported Context: A non-statistical sample of 4 ($291,493) out of 21 ($392,941) purchases / contracts with expenditures over the micropurchase threshold of $3,000 were tested for procurement. In addition, suspension and debarment was applicable to two vendors. Repeat Finding from Prior Year: Yes, prior year finding 2021-003 Recommendation: We recommend that management develop a written procurement policy that conforms with Uniform Guidance. In addition, we recommend that management implement procedures and control processes to retain documentation supporting compliance with major federal program compliance requirements. Views of Responsible Officials: Management agrees with the finding and the recommendation.