Finding Text
2022-001 Department of Education CFDA # 84.425F ? Education Stabilization Fund - Institutional Award Number P425F202362 2021-2022 Award Year Procurement, Suspension and Debarment Significant Deficiency in Internal Controls over Compliance Criteria: Uniform Guidance and 2 CFR sections 200.318 through 200.326 set forth the procurement standards non-federal entities other than states must follow when operating federal programs and the procurement procedures required depending on the amount of the transaction. Condition: In our testing of procurement, suspension, and debarment it was identified that there was no observable control documentation to directly indicate that a cost or price analysis was performed. Cause: Based on limited federal funding previously received that would require a written policy and lack of awareness or understanding of all of the specific requirements under the Uniform Guidance specific to written policy requirements over procurement, suspension and debarment. Effect: A lack of established controls increases the overall risk that employees are not aware of the specific requirements with contracting and awarding contracts to lower-tier entities. Questioned Costs: None reported. Context/Sampling: A nonstatistical sample of 3 vendors out of 5 vendors that meet thresholds required for procurement and suspension debarment testing. Repeat Finding from Prior Year(s): No. Recommendation: We recommend that the University implement a procurement policy as required under Uniform Guidance with the required components that can be used if future federal assistance is received. Views of Responsible Officials: Management agrees with the finding.