Finding 47151 (2022-005)

Material Weakness
Requirement
I
Questioned Costs
$1
Year
2022
Accepted
2023-03-29
Audit: 52619
Organization: Morris Colllege (SC)

AI Summary

  • Core Issue: The College failed to follow its procurement policy, resulting in disbursements over $500 lacking required competitive quotes.
  • Impacted Requirements: Non-compliance with federal procurement standards, specifically 2 CFR Part 200, which mandates purchase requisitions and competitive quotes for certain purchases.
  • Recommended Follow-Up: Update the procurement policy to meet federal standards and ensure management understands and enforces these policies moving forward.

Finding Text

2022-005 Failure to Comply with Procurement Policy Finding Type: Material Weakness in Internal Control over Major Programs CFDA#: 84.031B Title III Part B, Strengthening Historically Black Colleges and Universities Award Year: 2022 CFDA#: 84.425E/84.425F/84.425J CARES Act: Higher Education Emergency Relief Fund (HEERF) Award Year: 2022 Criteria: The terms of the programs and Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), requires the use of purchase requisitions for all non-exempt purchases. With certain exceptions for sole source and emergencies, the following must be attached to the purchase requisition: Under current procedures, competitive quotes must be obtained as a prerequisite for purchases over $500. The current policy also does not meet the minimum requirement for purchases exceeding the simplified acquisition threshold (greater than $250,000). Condition: The College did not follow its procurement policy for the year ended June 30, 2022. We found that disbursements over $500 did not have competitive quotes when required. Effect of Condition and Questioned Costs: The College has not complied with its procurement policy, and it is not known whether the College has paid a reasonable and competitive rate for the services provided on the various contracts. The dollar amount of the contracts totaled $821,643 for Title III and $74,455 for HEERF. Cause: There was a lack of appropriate internal control policies and procedures implemented at the College during the fiscal year to ensure procurement policies and procedures were performed before disbursement of funds occurred. There is also a lack of understanding of minimum requirements to ensure the College?s policy meets the standards as noted above. Recommendation: We recommended updating the procurement policy to align with the procurement standards set out at 2 CFR sections 200.318 through 200.326 and management be familiar with polices and ensure they are being adhered to. View of Responsible Officials and Planned Corrective Action: The College agrees with the finding and management will take necessary steps to adhere to and update the procurement policy.

Corrective Action Plan

2022-005 Failure to Comply with Procurement Policy Name of contact person responsible for Corrective Action Plan: Robert Eaves, Director of Business Affairs Corrective Action Plan: The plan has commenced and the dollar minimum for Quotes has been increased from $500 to $25,000. When purchases are for $25,000 or more, three quotes will be obtained if vendors can be located for the goods or services requested. The dollar minimum will be input in the Office of Business Affairs Accounting Manual and correspondence sent to all employees via written memorandum and e-mail. Anticipated Completion Data: This process has started and we expect compliance before June 30, 2023.

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

  • 47152 2022-006
    Material Weakness
  • 47153 2022-005
    Material Weakness
  • 47154 2022-006
    Material Weakness
  • 52128 2022-005
    Material Weakness
  • 52129 2022-006
    Material Weakness
  • 52130 2022-005
    Material Weakness
  • 52131 2022-006
    Material Weakness
  • 52132 2022-007
    Material Weakness
  • 52133 2022-005
    Material Weakness
  • 52134 2022-006
    Material Weakness
  • 52135 2022-007
    Material Weakness
  • 52136 2022-005
    Material Weakness
  • 52137 2022-006
    Material Weakness
  • 52138 2022-007
    Material Weakness
  • 623593 2022-005
    Material Weakness
  • 623594 2022-006
    Material Weakness
  • 623595 2022-005
    Material Weakness
  • 623596 2022-006
    Material Weakness
  • 628570 2022-005
    Material Weakness
  • 628571 2022-006
    Material Weakness
  • 628572 2022-005
    Material Weakness
  • 628573 2022-006
    Material Weakness
  • 628574 2022-007
    Material Weakness
  • 628575 2022-005
    Material Weakness
  • 628576 2022-006
    Material Weakness
  • 628577 2022-007
    Material Weakness
  • 628578 2022-005
    Material Weakness
  • 628579 2022-006
    Material Weakness
  • 628580 2022-007
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $2.93M
84.425 Education Stabilization Fund $2.00M
84.063 Federal Pell Grant Program $1.96M
84.007 Federal Supplemental Educational Opportunity Grants $654,004
84.047 Trio_upward Bound $359,602
81.123 National Nuclear Security Administration (nnsa) Minority Serving Institutions (msi) Program $297,868
84.042 Trio_student Support Services $294,612
84.031 Higher Education_institutional Aid $225,184
84.033 Federal Work-Study Program $43,716