Finding Text
Federal Agency: U.S. Department of Education Federal Program Name: Higher Education Emergency Relief Fund Assistance Listing Number: 84.425F Federal Award Identification Number and Year: P425F202063-20B and 2022 Pass-Through Agency: N/A Pass-Through Number(s): N/A Award Period: 2021-2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Universities to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the University has a written policy where Universities should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the University has a written procurement policy in place starting July 2021 and revised in February 2022. During review of the procurement policy, it was noted it was missing required procedures for the procurement of goods over $250,000. Also, it was noted during testing that there was no support to show the University verified the vendors were not suspended or debarred. Questioned Costs: None. Context: A tracking and documentation system was implemented for the suspension and debarment process. However, the documentation is not retained after the SAM.gov check is performed. Cause: The University experienced turnover during the year, and supporting documentation was not accessible to provide evidence of the check being performed. evidence retained to show that as of the time of check the vendor was not debarred/suspended. Repeat Finding: Yes, 2021-002 Recommendation: We recommend that the University establish a process where when the SAM.gov check is performed, evidence is retained to show that this was completed. Views of Responsible Officials: There is no disagreement with the audit finding.