Finding Text
2024-005 — Procurement – Material Weakness in Internal Control Over Compliance and Noncompliance (Repeat of Finding 2023-006 and 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 will follow its policies as required.