Finding Text
Finding 2022-01 ? Procurement, Suspension and Debarment Policy U.S. Department of Education Program (ED) Federal Program ? Hispanic-Serving Institutions - Science, Technology, Engineering, or Mathematics (HSI-STEM) and Articulation Programs (84.031C) Finding: The College does not have a formal written procurement, suspension and debarment policy that encompasses all required procurement standards set out in 2 CFR Sections 200.318 through 200.326. The policy is required under Uniform Guidance for direct purchases under the federal program. Criteria: Per 2 CFR 200.303, the College must establish and maintain effective internal controls over federal awards that provide reasonable assurance that it is managing federal awards in compliance with federal statutes, regulations and provisions of contracts or grant agreements that could have a material effect on each of its federal programs. Non-federal entities other than states, must follow procurement standards set out in 2 CFR Sections 200.318 through 200.326. Entities must use their own documented procurement procedures, which reflect applicable state and local laws and regulations, provided that the procurements conform to applicable federal statutes and the procurement requirements identified in 2 CFR part 200. Condition: The College did not have a procurement, suspension and debarment policy that complied with federal requirements in place at the time they expended funds under the HSI-STEM program. Cause: The federal funds received and expended during the year were new to the College during the 2021-2022 award year. In recent years, the other programs the College has participated in did not allow for direct purchases or include procurement as a material compliance requirement. Although the College did not have a written procurement, suspension and debarment policy in place, it did have documented approval limits for expenses made over certain dollar amounts to ensure purchases are made within authority limits and followed its established procurement procedures. Effect: The College did not comply with certain applicable federal regulations that could result in the loss of future federal funding. Questioned Costs: There were no questioned costs identified. Repeat Finding: This is not a repeat finding. Recommendation: The College should create a written procurement, suspension and debarment policy to ensure expenditures made with federal funds conform to applicable federal regulations. Views of responsible officials: Management agrees with this finding and will implement the recommendation. See Corrective Action Plan.