Finding Text
2022 ? 004 ? Procurement and Suspension and Debarment Policy Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund ? Higher Education Emergency Relief Fund ? Institutional Portion Federal Assistance Listing Number: 84.425F Award Period: 7/1/21-6/30/22 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or specific requirement: When procuring property and services under a Federal award, entities must follow the procurement standards outlined in 2 CFR 200.218 through 200.327. Included in these requirements, a non-Federal entity must 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. Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. When a non-federal entity enters into a covered transaction, 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 University has implemented formal, written policies and procedures to align with the requirements for procurement and suspension and debarment but did not maintain documentation that these policies were followed during the year. Questioned costs: Unknown. Context: We selected a sample of 5 transactions for procurement and suspension and debarment testing and noted the University did not maintain any documentation to support adherence to the University?s procurement and suspension and debarment policies. Cause: The University experienced turnover during the year and documentation could not be located. Effect: Supporting documentation could not be located to support required procurement and suspension and debarment standards were followed. Repeat Finding: No. Recommendation: We recommend the University ensure a process is put in place to maintain appropriate supporting documentation as evidence that the University?s procurement, suspension and debarment policies were followed. Views of responsible officials: Management agrees with the finding.