Finding Text
2023-006 — Procurement – Material Weakness in Internal Control Over Compliance and
Noncompliance (Repeat of Finding 2022-004)
Federal program information:
Funding agencies: U.S. Department of Interior and
U.S. Department of Education
Titles: Assistance to Tribally Controlled Community
Colleges; Higher Education Institutional Aid; and
Education Stabilization Fund
ALN Number: 15.027, 84.031, and 84.425
Award years: Various
Criteria: According to 2 CFR Section 200.318i, the recipient or subrecipient must maintain
records sufficient to detail the history of each procurement transaction. These records must
include the rationale for the procurement method, contract type selection, contractor
selection or rejection, and the basis for the contract price. According to 2 CFR Section
0200.319a, all procurement transactions under the federal award must be conducted in a
manner that provides full and open competition.
Condition: The College did not maintain records sufficient to detail the history of each
procurement transaction for the nine procurements contracts tested.
Cause: The College did not have sufficient procedures in place to ensure that procurement
records are maintained.
Effect: The College is not in compliance with procurement requirements.
Questioned Costs: None
Context: Procurement documents were not retained for nine out of nine transactions tested.
Recommendation: Formally document and enforce policies and procedures that will promote
adequate monitoring of the procurement and bidding process. Ensure that any contract over
the College’s threshold ($150,000) follow the sealed bid requirements listed in 2 CFR Section
200.320b1.
Management’s Response: The College concurs with this finding.