Finding Text
2024-009 – Internal controls over compliance - CARES Institutional (HEERF) Federal Awards
Type of Finding: Significant Deficiency
Assistance Listing Number: 84.425F
Program Name: COVID-19 Education Stabilization Fund: HEERF – Institutional Portion
Pass Through Identifying Number: N/A
Award Year: 2023-2024
Federal Agency: U.S. Department of Education
Criteria: In accordance with 2 CFR.303(a) of the Uniform Guidance, which applies to the HEERF grants, non-Federal entities are required to establish and maintain effective internal controls over federal awards. Specifically, internal controls should be established to ensure the non-federal entity appropriately documents review for suspension and debarment before entering into covered transactions. In addition, 2 CFR 180 Subpart C prohibits participants in Federal awards from entering into covered transactions with suspended or debarred parties.
Condition: The College did not frequently review the vendors and did not maintain documentation that the vendors were checked against the sam.gov website for suspension or debarment.
Cause: The College did not frequently review the vendors and did not maintain documentation that the vendors were checked against the sam.gov website for suspension or debarment due to oversight by personnel.
Effect: The college could potentially enter into transactions with parties that are suspended or debarred.
Questioned costs: N/A.
Recommendation: It is recommended that the client establish controls in order to ensure that vendors are reviewed and documentation is maintained through sam.gov or similar to verify that they are not suspended or debarred.
Views of Responsible Officials: Management agrees with the findings. See corrective action plan beginning on page 108.