Finding Text
Assistance Listing Number, Federal Agency, and Program Name - 84.425F, 84.425M, 84.425N; U.S. Department of Education; HEERF Institutional Portion, HEERF Strengthening Institutions Program (SIP), HEERF Fund for Improvement of Postsecondary Education (FIPSE) Formula Grant. Federal Award Identification Number and Year - P425F204736, P425M201046-20A , P425N200748 Pass-through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - Per 2 CFR 200.318 - The non-Federal entity must have and use documented procurement procedures, consistent with State, local, and tribal laws and regulations and the standards of this section, for the acquisition of property or services required under a Federal award or subaward. The non-Federal entity's documented procurement procedures must conform to the procurement standards identified in ?? 200.317 through 200.327. Condition - The Corporation's procurement procedures does not fully conform to the procurements standards identified in ?? 200.317 through 200.327. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - During testing we did not identify any instances of noncompliance related to procurement. However, during the review of the policies we discovered the following provisions of the standards were not in conformity with Uniform Guidance: * ? 200.318 - general procurement standard: the policy excluded a written standard of conduct covering conflicts of interest, including organizational conflicts of interest * ? 200.320 - methods of procurement: the policy does not appear to conform to the standards specific to non-construction purchases in excess of the small acquisition threshold * ?? 200.321 - 300.326 are not addressed in the policies Cause and Effect - Controls in place did not ensure the procurement policies and procedures conformed to the procurement standards identified in ?? 200.317 through 200.327. The lack of controls could result in acquisition of property or services that does not provide full and open competition and could result in disallowed costs. Recommendation - The Corporation should review the procurement standards identified in ?? 200.317 through 200.327 to identify policy deficiencies and work to establish policy that will confirm to the standards. Views of Responsible Officials and Planned Corrective Actions - Management concurs with the finding and will be conducting a thorough review of the current policies to ensure compliance with Uniform Guidance, as well as providing additional training and education to those responsible for procurement.