Finding Text
2022-002 Internal Controls over Suspension and Debarment (Significant Deficiency) U.S. Department of Education COVID -19: Education Stabilization Fund: Higher Education Emergency Relief Fund 84.425F ? COVID-19 Institutional Portion 2021-2022 Funding Criteria: Under 2 CFR Section 200.303(a) and 2 CFR Section 180, Subpart C, non-federal entities must establish and maintain effective internal controls to provide reasonable assurance that the entity is managing the federal awards in compliance with statues, regulations, and the terms and conditions of the award. Condition: The College does not have documented controls to prevent purchases using federal funds from suspended or debarred vendors. Effect: Payments from federal funds made to suspended or debarred vendors may need to returned and / or impact future funding. Cause: While the College has policies and procedures for procurement, these do not encompass verifying that the potential vendor is suspended or debarred from receiving federal funding as required under 2 CFR Section 180, Subpart C. Questioned Costs: None. Perspective: Because a formal policy is not established, none of the vendors meeting the threshold were subjected to suspension and debarment testing by the College. Repeat Finding: No Auditors? Recommendation: The College should establish procedures to ensure that controls related to suspension and debarment are devised, are consistently implemented and that all written records are maintained to support that the compliance requirement is met. Views of Responsible Officials: See corrective action plan