Finding Text
(2022-001) Federal Agencies: U.S. Department of Education Programs: Education Stabilization Fund - Reimagine Workforce Preparation Award Numbers: M64479-7100 Award Years: 2021-2023 Repeat Finding: No Condition: For the federal grant activities, the Organization follows their internal written policies which are similar to the Uniform Guidance. However, there are certain requirements under the Uniform Guidance that are not included in the Organization?s current policies such as thresholds for informal and formal procurement policies. Criteria: Title 2 U.S. Code of Federal Regulations, Part 200, Uniform Administration Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) require nonfederal entities, that received federal awards, to have written policies, procedures and standards of conduct that include financial management, federal payments, general procurement standards, compensation and other matters with specific minimum requirements. Questioned Costs: None. Cause: The Organization was unaware they had to formally document their internal procurement and other policies relating to federal awards. Effect: The Organization?s internal procurement policies are not in compliance with the Uniform Guidance. Perspective Information: There was only one procurement policy (no specific federal awards policy) related to the above grant awards with the Organization. Recommendation: We recommend that the Organization adopt separate written policies relative to federal awards with the requirements under the Uniform Guidance. Management?s Response: Management was unaware of the Uniform Guidance written policy requirements and agrees with the finding. We are currently working on separate written policies specifically for federal awards to be in compliance with the Uniform Guidance.