Finding 49829 (2022-002)

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Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-02-19
Audit: 42091
Organization: Adler Graduate School (MN)

AI Summary

  • Core Issue: The School's procurement policies lack a process to verify vendor suspension or debarment, risking non-compliance with federal guidelines.
  • Impacted Requirements: Failure to ensure full and open competition and verify vendor eligibility violates the procurement standards set by the Uniform Guidance.
  • Recommended Follow-Up: Revise procurement policies to include vendor verification, and train staff on compliance to strengthen internal controls and reduce risks.

Finding Text

Finding 2022-002: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds, Procurement, Suspension and Disbarment Federal Program - COVID-19 Education Stabilization Fund (ESF) - Institutional Portion Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable AL Number - 84.425F, 84.425N Federal Award Identification Numbers - P425F205088 Federal Award Year - June 30, 2022 Criteria: General procurement standards outlined in 2 CFR 200.318(a) state that a non-Federal entity. Must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to the applicable Federal law and the standards identified by the Uniform Guidance (sections 200.318 ? 200.326). The Uniform Guidance outlines requirements over the proper oversight of contractors, having written standards of conduct for employees involved in contracting, awarding contracts to responsible contractors, maintaining records documenting the history of procurements including cost price analysis, conducting all transactions in a manner which provides full and open competition, having procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded, utilizing the methods of procurement outlined in the Uniform Guidance, and ensuring every purchase order or contract includes the applicable provisions in Appendix II. Condition: The School?s policies and procedures over procurement generally comply with the requirements outlined by the Uniform Guidance, which establishes methods of procurement to be utilized related to the acquisition of both goods and services. However, the School?s policies do not fully adhere to the requirements, as there is no policy or procedure in place related to the verification of vendor suspension or debarment prior to contracting with the vendor. Additionally, the auditors reviewed one procurement transaction over the micro-purchase threshold and noted that the School?s policies were not followed with regard to ensuring full and open competition by obtaining bids or quotes. The School did check for suspension/disbarment following our identification of the finding, and there were no issues. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School's policies were not compared to Uniform Guidance to ensure all elements were incorporated prior to entering into a contract with a vendor for which federal funds were the source of the expenditure. Additionally, the School?s procedures were not followed appropriately with regard to vendor bids/selection. Effect: The School is at risk of procuring goods and services that are not in compliance with the requirements of the Uniform Guidance, which increases the risk of federal funds being used improperly or the School entering into a covered transaction with a vendor that is suspended or debarred. Recommendation: The School should revise its policies and procedures to comply with the requirements of the Uniform Guidance and ensure that they are followed to verify that a vendor with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Additionally, all employees involved in procurement should be trained on the School?s procurement policies and procedures to avoid a break down of internal controls designed to reduce the risk of improper expenditures. Management's Response: Management did review all HEERF-related contracts and expenditures for reasonableness to ensure that the school was being prudent with its financial resources. Management agrees with the finding and will draft a ?Federal Grants Management Policy Manual? and implement related procedures which will be in compliance with 2 CFR 200.318(a). Policy and procedures will address all applicable compliance requirements.

Corrective Action Plan

2022-002 ? COVID-19 ? Education Stabilization Fund ? Institutional Portion Recommendation: The School should revise its policies and procedures to comply with the requirements of the Uniform Guidance and ensure that they are followed to verify that a vendor with which its plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Additionally, all employees involved in procurement should be trained on the School?s procurement policies and procedures to avoid a break down of internal controls designed to reduce the risk of improper expenditures. Planned Action Management agrees with the finding and is committed to strengthening its procedures to avoid similar issues in the future. Members of the College did not appropriately follow federal procurement guidelines related to costs that were included in the institutional reimbursement portion of HEERF funding. This was an oversight and occurred as a result of the timing of when the purchases were made, or the contracts were entered into, and when the HEERF funding and applicable guidance was communicated by the Department of Education. At the time the contracts were entered into, members of the College did appropriately review all contracts and the related costs for reasonableness to ensure that the College was being prudent with its financial resources, whether from the federal government or not. Members of the College have also reviewed SAM to ensure that these vendors were not suspended or debarred. The College?s federal procurement policies and procedures will be updated to ensure that all items from the Uniform Guidance are included and followed for all federal grants. Proposed Completion Date: The School will review processes to ensure we are in compliance by March 15, 2023.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 49828 2022-001
    Significant Deficiency Repeat
  • 49830 2022-001
    Significant Deficiency Repeat
  • 49831 2022-002
    -
  • 49832 2022-001
    Significant Deficiency Repeat
  • 49833 2022-002
    -
  • 49834 2022-003
    Significant Deficiency
  • 49835 2022-003
    Significant Deficiency
  • 49836 2022-003
    Significant Deficiency
  • 626270 2022-001
    Significant Deficiency Repeat
  • 626271 2022-002
    -
  • 626272 2022-001
    Significant Deficiency Repeat
  • 626273 2022-002
    -
  • 626274 2022-001
    Significant Deficiency Repeat
  • 626275 2022-002
    -
  • 626276 2022-003
    Significant Deficiency
  • 626277 2022-003
    Significant Deficiency
  • 626278 2022-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $3.40M
84.425 Education Stabilization Fund $107,825