FAC Explorer

Finding 504592 (2024-001)

-
Requirement
I
Questioned Costs
$1
Year
2024
Accepted
2024-11-04
Audit: 327187
Organization: Miami University (OH)
Auditor: Forvis Mazars

AI Summary

  • Core Issue: The Office of Research and Innovation did not follow the University’s procurement policies for consulting services, leading to potential compliance violations.
  • Impacted Requirements: Expenditures over $10,000 bypassed necessary quotation and competitive bidding processes, violating both University policies and Uniform Guidance standards.
  • Recommended Follow-Up: Ensure the Office of Research and Innovation adheres to current procurement policies or establishes compliant practices for Federal awards.

Finding Text

Information on the federal program – Research and Development cluster, various assistance listing numbers Criteria or specific requirement – Procurement Condition – The University’s procurement policies were not followed by the Office of Research and Innovation for consulting services or contractors paid under external grants. Questioned costs – Unknown Context – The Office of Research and Innovation was operating under the understanding that they were exempt from following the University’s standard procurement policies. The exemption was communicated by the University’s former General Counsel. Effect – Expenditures within the Research and Development cluster that were above the $10,000 threshold for procurement procedures, as set by the University’s procurement policies, did not go through the appropriate quotation or competitive bidding process. Cause – The exemption from the University’s former General Counsel should not have been granted to the Office of Research and Innovation as it directly violates the University’s policies, which in turn violates the Uniform Guidance standards for procurement. Identification as a repeat finding, if applicable – No Recommendation – We recommend the Office of Research and Innovation follow the University’s current procurement policies or develop procurement practices under Federal awards that are in compliance with Uniform Guidance procurement standards.

Corrective Action Plan

The Vice President for Research and Innovation will work with the Vice President for Finance and Business Services and the Director of Procurement who reports to this vice president to bring procurement practices under federal awards into compliance with the Uniform Guidance Procurement Standards 2 CFR 200.300. In doing so, the following is to be undertaken: 1) Undertake review by external firm with expertise in determination of alignment of universit procurement policies and procedures to those required by Uniform Guidance. 2) Implement required elements following that review. Prior to the implementation of the recommendations by the consultant, the university's policies, which conform to the Uniform Guidance standards, will be enforced. 3) Develop and implement adequate training for impacted university employees, including, but not limited to, principal investigators, department support staff, and oversight offices (e.g., Grants & Contracts Office). 4) In conjunction with the Office of the General Counsel, the Office of Academic Personnel, and Human Resources, revise the independent contractor policies to remove the exemption that "personal services paid by external grants do not need bids regardless of the amount of payment."

Categories

Questioned Costs Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $78.91M
84.063 Federal Pell Grant Program $16.75M
84.038 Federal Perkins Loan Program $2.67M
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $899,187
84.033 Federal Work-Study Program $846,156
84.007 Federal Supplemental Educational Opportunity Grants $802,970
84.365 English Language Acquisition State Grants $515,479
93.395 Cancer Treatment Research $366,059
93.846 Arthritis, Musculoskeletal and Skin Diseases Research $336,312
84.047 Trio Upward Bound $330,494
84.042 Trio Student Support Services $329,420
21.027 Coronavirus State and Local Fiscal Recovery Funds $326,388
47.050 Geosciences $309,117
93.959 Block Grants for Prevention and Treatment of Substance Abuse $242,003
93.788 Opioid Str $217,663
84.335 Child Care Access Means Parents in School $205,975
59.037 Small Business Development Centers $180,825
93.433 Acl National Institute on Disability, Independent Living, and Rehabilitation Research $161,750
11.619 Arrangements for Interdisciplinary Research Infrastructure $150,036
17.277 Wioa National Dislocated Worker Grants / Wia National Emergency Grants $144,037
45.163 Promotion of the Humanities Professional Development $142,918
12.431 Basic Scientific Research $137,422
93.855 Allergy and Infectious Diseases Research $137,049
93.173 Research Related to Deafness and Communication Disorders $130,605
47.084 Nsf Technology, Innovation, and Partnerships $123,258
93.867 Vision Research $111,908
93.645 Stephanie Tubbs Jones Child Welfare Services Program $110,420
93.396 Cancer Biology Research $105,608
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $80,519
15.608 Fish and Wildlife Management Assistance $80,242
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $79,358
47.070 Computer and Information Science and Engineering $76,534
15.247 Wildlife Resource Management $72,816
93.048 Special Programs for the Aging, Title Iv, and Title Ii, Discretionary Projects $71,934
94.013 Americorps Volunteers in Service to America 94.013 $66,196
93.912 Rural Health Care Services Outreach, Rural Health Network Development and Small Health Care Provider Quality Improvement $65,533
93.273 Alcohol Research Programs $52,586
93.791 Money Follows the Person Rebalancing Demonstration $46,393
15.634 State Wildlife Grants $45,994
15.808 U.s. Geological Survey Research and Data Collection $42,090
81.049 Office of Science Financial Assistance Program $39,372
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $37,118
84.305 Education Research, Development and Dissemination $36,716
84.323 Special Education - State Personnel Development $34,855
15.657 Endangered Species Recovery Implementation $33,191
15.805 Assistance to State Water Resources Research Institutes $32,869
47.078 Polar Programs $32,444
12.800 Air Force Defense Research Sciences Program $31,859
93.286 Discovery and Applied Research for Technological Innovations to Improve Human Health $31,513
93.083 Prevention of Disease, Disability, and Death Through Immunization and Control of Respiratory and Related Diseases $29,717
15.807 Earthquake Hazards Program Assistance $29,463
93.470 Alzheimer�s Disease Program Initiative (adpi) $28,854
84.021 Overseas Programs - Group Projects Abroad $25,572
81.121 Nuclear Energy Research, Development and Demonstration $24,358
84.411 Education Innovation and Research (formerly Investing in Innovation (i3) Fund) $22,500
84.184 School Safely National Activities $16,377
12.006 National Defense Education Program $15,982
93.837 Cardiovascular Diseases Research $15,267
45.164 Promotion of the Humanities Public Programs $14,188
12.RD Basic Scientific Research $14,000
19.009 Academic Exchange Programs - Undergraduate Programs $13,048
93.778 Medical Assistance Program $12,908
84.027 Special Education Grants to States $10,715
45.149 Promotion of the Humanities Division of Preservation and Access $10,000
45.160 Promotion of the Humanities Fellowships and Stipends $10,000
93.110 Maternal and Child Health Federal Consolidated Programs $9,981
47.076 Stem Education (formerly Education and Human Resources) $9,846
93.865 Child Health and Human Development Extramural Research $9,279
47.075 Social, Behavioral, and Economic Sciences $8,542
10.310 Agriculture and Food Research Initiative (afri) $7,836
16.582 Crime Victim Assistance/discretionary Grants $7,703
45.024 Promotion of the Arts Grants to Organizations and Individuals $7,381
47.049 Mathematical and Physical Sciences $7,350
20.600 State and Community Highway Safety $6,836
20.U10 Department of Transportation $5,252
94.006 Americorps State and National 94.006 $5,035
45.310 Grants to States $4,999
16.838 Comprehensive Opioid, Stimulant, and Other Substances Use Program $4,266
93.RD Basic Scientific Research $4,142
66.516 P3 Award: National Student Design Competition for Sustainability $3,935
15.954 National Park Service Conservation, Protection, Outreach, and Education $3,500
12.910 Research and Technology Development $3,457
45.161 Promotion of the Humanities Research $2,878
43.008 Office of Stem Engagement (ostem) $2,500
93.866 Aging Research $2,340
47.041 Engineering $1,845
21.019 Coronavirus Relief Fund $1,530
66.RD Basic Scientific Research $647
93.242 Mental Health Research Grants $421
15.RD Basic Scientific Research $166
93.799 Cara Act � Comprehensive Addiction and Recovery Act of 2016 $164
43.001 Science $101
19.RD Basic Scientific Research $23
93.859 Biomedical Research and Research Training $-2,421
47.074 Biological Sciences $-5,779
84.425 Education Stabilization Fund $-14,913