Finding 537453 (2024-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2024
Accepted
2025-03-26

AI Summary

  • Core Issue: The University failed to consistently check if vendors are suspended or debarred, violating compliance requirements.
  • Impacted Requirements: Non-federal entities must verify that parties involved in covered transactions are not suspended or debarred as per Uniform Grant Guidance.
  • Recommended Follow-up: The University should create and implement formal policies and procedures to ensure compliance with suspension and debarment requirements.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Name: STEM - PODER Assistance Listing Number: 84.031C Federal Award Identification Number and Year: P031C210076-23; 2023-2024 Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. 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. Condition: The University did not consistently perform requirements for suspension and debarment as outlined in the Uniform Grant Guidance. Questioned Costs: None. Context: The University did not implement a formal, written policy and procedure that aligned with the Uniform Grant Guidance requirements for suspension and debarment. Cause: The University does not have a formal written policy and procedures to align with the Uniform Grant Guidance requirements for suspension and debarment. Effect: Suspension and debarment of vendors is not being checked in accordance with the Uniform Guidance. Repeat Finding: No. Auditors’ Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

STEM - PODER – Federal Assistance Listing Number 84.031C Recommendation: We recommend the University document and implement policies and procedures that are aligned with Uniform Grant Guidance for suspension and debarment to ensure the University is following requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The University is in the process of developing and implementing a formal policy and procedure to verify that a vendor is not debarred or suspended in the System for Award Management (SAM) database. The procedure, which will be in place by the end of FY 2025, will outline roles, responsibilities, and documentation requirements to ensure consistent compliance. Name(s) of the contact person(s) responsible for corrective action: Diane DiStaulo, Director of Accounting Operations, (201) 761-7415 Planned completion date for corrective action plan: by the end of FY2025

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring Significant Deficiency

Other Findings in this Audit

  • 537443 2024-001
    Significant Deficiency Repeat
  • 537444 2024-001
    Significant Deficiency Repeat
  • 537445 2024-001
    Significant Deficiency Repeat
  • 537446 2024-001
    Significant Deficiency Repeat
  • 537447 2024-002
    Significant Deficiency Repeat
  • 537448 2024-002
    Significant Deficiency Repeat
  • 537449 2024-002
    Significant Deficiency Repeat
  • 537450 2024-002
    Significant Deficiency Repeat
  • 537451 2024-002
    Significant Deficiency Repeat
  • 537452 2024-002
    Significant Deficiency Repeat
  • 1113885 2024-001
    Significant Deficiency Repeat
  • 1113886 2024-001
    Significant Deficiency Repeat
  • 1113887 2024-001
    Significant Deficiency Repeat
  • 1113888 2024-001
    Significant Deficiency Repeat
  • 1113889 2024-002
    Significant Deficiency Repeat
  • 1113890 2024-002
    Significant Deficiency Repeat
  • 1113891 2024-002
    Significant Deficiency Repeat
  • 1113892 2024-002
    Significant Deficiency Repeat
  • 1113893 2024-002
    Significant Deficiency Repeat
  • 1113894 2024-002
    Significant Deficiency Repeat
  • 1113895 2024-003
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $6.81M
84.287 Twenty-First Century Community Learning Centers $468,785
84.007 Federal Supplemental Educational Opportunity Grants $380,885
84.033 Federal Work-Study Program $377,763
64.027 Post-9/11 Veterans Educational Assistance $353,205
84.042 Trio Student Support Services $270,957
84.268 Federal Direct Student Loans $182,544
64.125 Vocational and Educational Counseling for Servicemembers and Veterans $157,022
84.215 Innovative Approaches to Literacy; Promise Neighborhoods; Full-Service Community Schools; and Congressionally Directed Spending for Elementary and Secondary Education Community Projects $129,429
84.116 Fund for the Improvement of Postsecondary Education $108,000
84.031 Higher Education Institutional Aid $105,908
47.076 Stem Education (formerly Education and Human Resources) $67,693
84.425 Education Stabilization Fund $51,282
97.024 Emergency Food and Shelter National Board Program $19,293
84.184 School Safely National Activities $16,080
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $13,138