Finding 507947 (2024-003)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2024-11-14
Audit: 328453
Organization: Idaho State University (ID)
Auditor: Cla

AI Summary

  • Core Issue: The University failed to verify that a vendor/subrecipient was not suspended or debarred before entering into a contract.
  • Impacted Requirements: This violates federal requirements for compliance checks as outlined in 2 CFR section 180.995 and Uniform Guidance 2 CFR 200.303.
  • Recommended Follow-Up: The University should enhance its procedures to ensure verification checks are conducted prior to contracting with any vendor/subrecipient.

Finding Text

Suspension Debarment Federal Agency: U.S. Federal Government Federal Program Title: Integrative Activities, Research and Development Cluster Assistance Listing Number: 47.083 Federal Award Identification Number and Year: 2320040-2024 Award Period: July 1, 2023 to June 30, 2024 Type of Finding: • Other Matters • Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: The Federal Government requires that when a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. In addition, per the Uniform Guidance 2 CFR 200.303, nonfederal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The University was not able to provide a verification check occurring before entering into contract with a vendor/subrecipient. Context: During our testing of 5 contracts, we identified one vendor/subrecipient that the University could not provide a verification check prior to entering the contract. Questioned costs: None. Cause: Verification check did not occur before entering into contract with vendor/subrecipient. Effect: The University entered into contract with a vendor/subrecipient prior to performing a verification check. Repeat finding: Yes, 2023-004 Recommendation: We recommend the University evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor/subrecipient. Views of responsible officials: Management agrees with the finding and has developed a plan to correct the finding.

Corrective Action Plan

Suspension Debarment Federal Program Title: Research & Development Cluster – Assistance Listing No. 47.083 Type of Finding: Significant Deficiency in Internal Control over Compliance Other MattersRecommendation: We recommend the University evaluate its procedures and implement an additional control to ensure verification checks are occurring prior to entering into contract with a vendor/subrecipient. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: ISU has implemented PaymentWorks, a third-party vendor processing system that does 24-7 suspension and debarment checking. This is conducted on all ISU vendors that onboard through PaymentWorks. All ISU contracts will be processed through Jaggaer, which requires a Banner ID#. All vendors will be initiated through PaymentWorks. Accounts Payable checks sanction alerts in PaymentWorks and follows up with issues. We are also adding the S&D clause to all contracts. Name(s) of the contact person(s) responsible for corrective action: : Lisa Leyshon, AVP Finance/Controller and Kirsten Broughton, Director of Grant Accounting Planned completion date for corrective action plan: July 1, 2024

Categories

Procurement, Suspension & Debarment Matching / Level of Effort / Earmarking Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 507948 2024-001
    Significant Deficiency Repeat
  • 507949 2024-002
    Significant Deficiency Repeat
  • 507950 2024-004
    Significant Deficiency Repeat
  • 507951 2024-004
    Significant Deficiency Repeat
  • 507952 2024-004
    Significant Deficiency Repeat
  • 507953 2024-004
    Significant Deficiency Repeat
  • 507954 2024-004
    Significant Deficiency Repeat
  • 507955 2024-004
    Significant Deficiency Repeat
  • 507956 2024-004
    Significant Deficiency Repeat
  • 507957 2024-004
    Significant Deficiency Repeat
  • 507958 2024-004
    Significant Deficiency Repeat
  • 507959 2024-004
    Significant Deficiency Repeat
  • 507960 2024-004
    Significant Deficiency Repeat
  • 507961 2024-004
    Significant Deficiency Repeat
  • 507962 2024-004
    Significant Deficiency Repeat
  • 507963 2024-004
    Significant Deficiency Repeat
  • 507964 2024-004
    Significant Deficiency Repeat
  • 507965 2024-005
    Significant Deficiency
  • 507966 2024-004
    Significant Deficiency Repeat
  • 507967 2024-005
    Significant Deficiency
  • 507968 2024-004
    Significant Deficiency Repeat
  • 507969 2024-004
    Significant Deficiency Repeat
  • 507970 2024-004
    Significant Deficiency Repeat
  • 507971 2024-004
    Significant Deficiency Repeat
  • 507972 2024-004
    Significant Deficiency Repeat
  • 507973 2024-001
    Significant Deficiency Repeat
  • 1084389 2024-003
    Significant Deficiency Repeat
  • 1084390 2024-001
    Significant Deficiency Repeat
  • 1084391 2024-002
    Significant Deficiency Repeat
  • 1084392 2024-004
    Significant Deficiency Repeat
  • 1084393 2024-004
    Significant Deficiency Repeat
  • 1084394 2024-004
    Significant Deficiency Repeat
  • 1084395 2024-004
    Significant Deficiency Repeat
  • 1084396 2024-004
    Significant Deficiency Repeat
  • 1084397 2024-004
    Significant Deficiency Repeat
  • 1084398 2024-004
    Significant Deficiency Repeat
  • 1084399 2024-004
    Significant Deficiency Repeat
  • 1084400 2024-004
    Significant Deficiency Repeat
  • 1084401 2024-004
    Significant Deficiency Repeat
  • 1084402 2024-004
    Significant Deficiency Repeat
  • 1084403 2024-004
    Significant Deficiency Repeat
  • 1084404 2024-004
    Significant Deficiency Repeat
  • 1084405 2024-004
    Significant Deficiency Repeat
  • 1084406 2024-004
    Significant Deficiency Repeat
  • 1084407 2024-005
    Significant Deficiency
  • 1084408 2024-004
    Significant Deficiency Repeat
  • 1084409 2024-005
    Significant Deficiency
  • 1084410 2024-004
    Significant Deficiency Repeat
  • 1084411 2024-004
    Significant Deficiency Repeat
  • 1084412 2024-004
    Significant Deficiency Repeat
  • 1084413 2024-004
    Significant Deficiency Repeat
  • 1084414 2024-004
    Significant Deficiency Repeat
  • 1084415 2024-001
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $15.60M
93.434 Every Student Succeeds Act/preschool Development Grants $11.49M
11.300 Public Works and Economic Development Facilities Program $1.23M
84.268 Federal Direct Student Loan $915,740
84.010 Title I Grants to Local Educational Agencies $764,531
93.516 Public Health Training Centers Program $726,663
84.007 Supplemental Educational Opportunity Grant $544,846
84.425 Education Stabilization Fund $535,521
84.141 Migrant Education High School Equivalency Program $514,358
84.044 Trio Talent Search $493,286
81.065 Nuclear Legacy Cleanup Program $474,607
93.107 Area Health Education Centers $441,664
84.149 Migrant Education College Assistance Migrant Program $440,788
47.083 Integrative Activities $346,139
94.006 Americorps State and National 94.006 $338,926
84.042 Trio Student Support Services $329,192
84.038 Perkins Loan Program $326,785
84.217 Trio McNair Post-Baccalaureate Achievement $298,330
84.047 Trio Upward Bound $279,734
84.129 Rehabilitation Long-Term Training $258,882
93.145 Hiv-Related Training and Technical Assistance $236,223
93.917 Hiv Care Formula Grants $219,739
43.001 Science $190,218
93.977 Sexually Transmitted Diseases (std) Prevention and Control Grants $189,382
84.066 Trio Educational Opportunity Centers $158,706
84.126 Rehabilitation Services Vocational Rehabilitation Grants to States $129,252
81.049 Office of Science Financial Assistance Program $127,347
93.658 Foster Care Title IV-E $122,120
93.855 Allergy and Infectious Diseases Research $111,387
93.173 Research Related to Deafness and Communication Disorders $105,836
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $101,369
59.058 Federal and State Technology Partnership Program $98,300
94.012 Americorps September 11th National Day of Service and Remembrance Grants 94.012 $97,518
93.234 Traumatic Brain Injury State Demonstration Grant Program $83,715
10.001 Agricultural Research Basic and Applied Research $64,424
93.918 Grants to Provide Outpatient Early Intervention Services with Respect to Hiv Disease $61,360
81.000 Pass Through Funding From Battelle Energy Alliance LLC $60,955
93.884 Primary Care Training and Enhancement $60,497
10.170 Specialty Crop Block Grant Program - Farm Bill $49,109
47.049 Mathematical and Physical Sciences $47,547
11.611 Manufacturing Extension Partnership $47,508
10.558 Child and Adult Care Food Program $46,937
93.988 Cooperative Agreements for Diabetes Control Programs $46,171
47.076 Stem Education (formerly Education and Human Resources) $45,273
93.236 Grants to States to Support Oral Health Workforce Activities $43,365
15.808 U.s. Geological Survey Research and Data Collection $40,533
84.325 Special Education - Personnel Development to Improve Services and Results for Children with Disabilities $36,087
93.191 Graduate Psychology Education $32,066
84.048 Career and Technical Education-Basic Grants to States $30,813
15.228 Blm Fuels Management and Community Fire Assistance Program Activities $28,984
93.959 Block Grants for Prevention and Treatment of Substance Abuse $28,257
15.815 National Land Remote Sensing Education Outreach and Research $26,326
12.002 Procurement Technical Assistance for Business Firms $26,104
93.859 Biomedical Research and Research Training $25,538
97.045 Cooperating Technical Partners $22,186
77.008 U.s. Nuclear Regulatory Commission Scholarship and Fellowship Program $21,660
93.251 Early Hearing Detection and Intervention $21,449
93.853 Extramural Research Programs in the Neurosciences and Neurological Disorders $20,520
84.002 Adult Education-Basic Grants to States $19,069
15.224 Cultural and Paleontological Resources Management $18,077
47.050 Geosciences $17,616
81.121 Nuclear Energy Research, Development and Demonstration $15,980
10.868 Rural Energy for America Program $13,092
11.431 Climate and Atmospheric Research $11,880
47.070 Computer and Information Science and Engineering $11,200
43.008 Office of Stem Engagement (ostem) $9,134
47.074 Biological Sciences $8,861
10.699 Partnership Agreements $8,236
15.810 National Cooperative Geologic Mapping $8,169
10.855 Distance Learning and Telemedicine Loans and Grants $6,846
84.033 Federal Work Study $5,938
10.559 Summer Food Service Program for Children (sfspc) $4,071
84.160 Training Interpreters for Individuals Who Are Deaf and Individuals Who Are Deaf-Blind $1,251
45.149 Promotion of the Humanities Division of Preservation and Access $250
45.129 Promotion of the Humanities Federal/state Partnership $118
59.037 Small Business Development Centers $1
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $-108
93.391 Activities to Support State, Tribal, Local and Territorial (stlt) Health Department Response to Public Health Or Healthcare Crises $-2,262
93.865 Child Health and Human Development Extramural Research $-2,834
93.426 The National Cardiovascular Health Program $-6,136