Finding Text
Finding 2020-005: Procurement
Federal Program: Research and Development Cluster (Education and Human Resources)
Assistance Listing Number and Title: 47.076 STEM Education
Name of Federal Agency, Pass Through Entity (when applicable), Award Number and Year: National Science Foundation: 1431638 (9/1/2014 – 8/31/2022), 1524963 (11/1/2015 – 9/30/2021), 1500529 (9/1/2015 – 8/31/2022), 1624185 (9/16/2016 – 8/31/2022), 1640791 (9/15/2016 – 8/31/2022), 1720869 (5/15/2017 – 4/30/2022), 1726113 (8/1/2017 – 9/30/2023), 1645003 (3/15/2017 – 2/29/2020), 1821462 (7/1/2018 – 6/30/2024), 1812860 (9/1/2018 – 8/31/2020), 1940925 (1/15/2020 – 12/31/2023), 1907950 (7/1/2019 – 6/30/2024), 2015205 (4/1/2020 – 3/31/2022), 2021059 (10/1/2020 – 9/30/2024)
Federal Program: Research and Development Cluster (Mathematical and Physical Sciences)
Assistance Listing Number and Title: 47.049 Mathematical and Physical Sciences
Name of Federal Agency, Pass Through Entity, Award Number and Year: National Science Foundation: 1821372 (10/1/2018 – 9/30/2024 pass through entity American Physical Society), 1834530 (9/1/2018 – 8/31/2025 pass through entity American Physical Society), 1938815 (8/1/2020 – 7/31/2024)
Federal Program: Research and Development Cluster (Science)
Assistance Listing Number and Title: 43.001 Science
Name of Federal Agency, Pass Through Entity: NNX16AR36A (8/24/2016 – 8/23/2021 pass through entity Temple University of the Commonwealth System of Higher Education)
Significant Deficiency in Internal Controls Over Compliance, Other matters
Criteria or Specific Requirement (Including Statutory, Regulatory, or Other Citation): Procedures articulated in 2 CFR 200.317-326, requires that for all procurement of goods and services, some form of cost or price analysis shall be made and documented in the procurement files in connection with every procurement action based on the dollar thresholds sited in the compliance code.
Condition: AAPT did not consistently adhere to written policies with respect to the procurement process, as bids/quotes were not obtainable or the conclusion for selection was not documented.
Cause: AAPT’s internal policies and procedures governing procurement were not consistently applied. Effect or Potential Effect: Without proper and complete procurement documentation, there is a risk that AAPT will not perform proper evaluation of each element of cost to determine reasonableness.
Questioned Costs: None noted.
Context: Our audit procedures consisted of internal control testwork over the cash disbursement cycle over a sample population of expenditures. We consider our sample to be representative of the population. The condition appeared to be systematic in nature.
Identification as a Repeat Finding, if Applicable: 2019-004.
Recommendation: We recommend that all procurement records for purchases in excess of the purchase threshold include the following, at a minimum: (a) basis for contractor/goods selection or (b) justification for lack of competition when competitive bids or offers are not obtained. Additionally, the conclusion should be clearly documented and accompanying the procurement documentation.
Views of Responsible Officials and Planned Corrective Actions: Management will update current policies and procedures and review and enforce the polices.
Management will be responsible for proper documentation and confirmation that all policies and procedures are followed.
Management will confirm that all agreements, mou’s and contracts are property, reviewed signed and documented.
Management will require all departments to document all procurements for goods and services with written cost and price analysis based on AAPT's dollar thresholds.
Anticipated Completion Date: November 2024
Responsible Official: Dr. Beth Cunningham CEO, Michael Brosnan CFO