Finding 45113 (2022-005)

Significant Deficiency
Requirement
I
Questioned Costs
$1
Year
2022
Accepted
2023-02-10

AI Summary

  • Core Issue: The University did not follow the correct small purchase threshold, missing quotes for purchases between $10,000 and $20,000.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303(a) and 2 CFR 200.320(a) regarding internal controls and procurement procedures.
  • Recommended Follow-up: Update the procurement policy to align with current thresholds and ensure regular reviews for compliance.

Finding Text

Funding Agency: United States Department of Agriculture Federal Award Agreement Number: 20-DG-11030000-004 & 21-DG-11030000-020 Award Year: All Title: Southwest Forest Health and Wildfire Prevention Assistance Listing Number: 10.694 Pass-through Agency: Not Applicable Pass-through Identification Number: Not Applicable Questioned Costs: $43,747 Condition - The University did not apply the correct small purchase threshold for identifying purchases that need to obtain quotes in their policy. The population between $10,000 and $20,000 not included in policy included 3 transactions totaling $43,747. Criteria ? 2 CFR 200.303(a) requires non-Federal entities to establish and maintain effective internal controls over compliance with Federal statutes, regulations, and the terms and conditions of grant agreements. 2 CFR 200.320(a) sets the micro-purchase threshold at $10,000 and requires purchases over the micro-purchase threshold to use small purchase procedures, whereby price or rate quotations must be obtained. Cause ? The University was unaware that the policy amount had changed to a threshold of $10,000. Effect ? The University may unintentionally use a higher-cost vendor when failing to obtain price or rate quotations for items over the micro-purchase threshold. Auditors? Recommendation ? The procurement policy should be updated to comply with all relevant state and local procurement requirements and reviewed for necessary revisions regularly.

Corrective Action Plan

Views of Responsible Officials and Planned Corrective Action ? The Purchasing Director will update policies and procedures to specifically address procurement for federal awards. The University will also ensure that Purchasing Department and Business Office staff participate in annual federal compliance training. Timeline and Estimated Completion Date: December 2022 Responsible Party: Aaron Flure, Purchasing Director and Stephanie Gonzales, Comptroller

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 45114 2022-005
    Significant Deficiency
  • 621555 2022-005
    Significant Deficiency
  • 621556 2022-005
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $8.17M
84.063 Federal Pell Grant Program $3.78M
84.425 Covid-19: Education Stabilization Fund - Heerf: Student Aid Portion $3.03M
93.658 Foster Care_title IV-E $1.44M
10.694 Southwest Forest Health and Wildfire Prevention $728,023
47.049 Mathematical and Physical Sciences $334,750
84.031 Higher Education_institutional Aid $327,605
84.033 Federal Work-Study Program $276,049
84.425 Covid-19: Education Stabilization Fund - Heerf: Institutional Aid Portion $269,264
47.076 Education and Human Resources $237,537
84.365 English Language Acquisition State Grants $228,309
84.007 Federal Supplemental Educational Opportunity Grants $129,863
93.959 Block Grants for Prevention and Treatment of Substance Abuse $114,055
10.223 Hispanic Serving Institutions Education Grants $54,710
47.083 Integrative Activities $49,670
84.425 Covid-19: Education Stabilization Fund - Geer $45,623
47.079 Office of International Science and Engineering $40,003
93.243 Substance Abuse and Mental Health Services_projects of Regional and National Significance $36,809
47.074 Biological Sciences $36,554
10.202 Cooperative Forestry Research $34,777
47.076 Trans-Nsf Recovery Act Research Support $24,899
93.859 Biomedical Research and Research Training $16,582
10.751 Rural Energy Savings Program (resp) $14,231
45.129 Promotion of the Humanities_federal/state Partnership $8,280
10.326 Capacity Building for Non-Land Grant Colleges of Agriculture (nlgca) $6,905
12.598 Centers for Academic Excellence $6,255
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $5,659
15.945 Cooperative Research and Training Programs ? Resources of the National Park System $3,550
10.699 Partnership Agreements $2,545
10.707 Research Joint Venture and Cost Reimbursable Agreements $124