Finding 601587 (2022-003)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2022-12-14
Audit: 24179
Organization: Rivier University (NH)

AI Summary

  • Core Issue: The University failed to verify that vendors exceeding $25,000 were not suspended or debarred from federal programs as required.
  • Impacted Requirements: Compliance with 2 CFR, Part 200, which mandates checking the System for Award Management (SAM) for covered transactions.
  • Recommended Follow-Up: Ensure the University adheres to its verification process for vendors and maintains documentation of SAM checks.

Finding Text

Finding Number:2022-003 Information on the Federal Program: Federal Agency: United States Department of Education (ED) Program Name: COVID-19 ? Education Stabilization Funds (Part B) AL: 84.425 Federal Award Identification Number: N/A Federal Award Year: Year Ended June 30, 2022 Specific Requirement: Required by 2 CFR, Part 200 for federally funded programs, when an institution enters into a covered transaction with an entity or individual, the institution must verify that the vendor is not suspended or debarred or otherwise excluded from participating in federal programs. Generally, a covered transaction is a transaction expected to equal or exceed $25,000 and be funded with federal dollars. This verification may be accomplished by checking the System for Award Management (SAM), or by adding a clause or condition to the covered transaction. Condition Found: During our audit, we noted that management did not review the SAM for vendors and employees meeting the covered transaction threshold as is defined in their year-end close checklist. Context: We noted there were 3 vendors exceeding $25,000 funded by the program. Based on our testing, none of the vendors exceeding the $25,000 limit were included in the SAM and received payments funded by the University?s major programs. Questioned Costs: None. Cause and Effect: The University was aware of the requirement to verify vendors and employees and they have a process established as part of their year-end close, but the review was not completed. Since this process was not performed, there is a greater risk of vendors and employees that are included on the SAM being disbursed funds through federal funds Identification as a Repeat Finding, if Applicable: N/A Recommendation: We recommend that the University follow established procedures for comparing vendors and employees against the SAM and maintain documentation that the comparison has been performed. Views of a Responsible Official and Corrective Action Plan: Management agrees with the finding and the recommendation. See Corrective Action Plan.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 25142 2022-004
    Significant Deficiency Repeat
  • 25143 2022-005
    Significant Deficiency Repeat
  • 25144 2022-005
    Significant Deficiency Repeat
  • 25145 2022-003
    Significant Deficiency
  • 601584 2022-004
    Significant Deficiency Repeat
  • 601585 2022-005
    Significant Deficiency Repeat
  • 601586 2022-005
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $14.82M
84.063 Federal Pell Grant Program $1.85M
84.425 Education Stabilization Fund $1.06M
93.732 Mental and Behavioral Health Education and Training Grants $371,893
93.359 Nurse Education, Practice Quality and Retention Grants $355,522
84.038 Federal Perkins Loan Program $200,407
84.033 Federal Work-Study Program $116,905
84.007 Federal Supplemental Educational Opportunity Grants $92,698
16.525 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assault, and Stalking on Campus $80,942
93.264 Nurse Faculty Loan Program (nflp) $49,171
47.076 Education and Human Resources $44,968
93.389 National Center for Research Resources $19,635
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $13,168