Finding Text
COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Fund ? Institutional Aid Portion, ALN 84.425F U.S. Department of Education, Award Year 2022 Criteria or Specific Requirement ? Procurement and Suspension and Debarment ? Section 18004(a)(1) Institutional Aid Portion ? 2 CFR 200.318-326 Condition ? The University does not have a procurement policy as required under federal guidelines. No support exists to show that vendors are reviewed for suspension or debarment. No support is maintained for sole source purchases. Questioned Costs ? None Context ? The University does not have a procurement policy in place to meet the Uniform Guidance procurement requirements. No errors were specifically found in testing of purchases against federal procurement requirements, but support could not be provided to show University procedures to check suspension or debarment. While none were selected for testing, it was additionally noted that no support was maintained for sole source purchases. Effect ? It is possible that purchases may be made that are not in accordance with federal procurement requirements that could lead to material noncompliance with federal grant agreements. Cause ? The University does not have a procurement policy in accordance with Uniform Guidance in place as is required under federal guidelines. Identification as a Repeat Finding ? N/A Recommendation ? The University should draft and approve a procurement policy that covers all aspects of federal procurement requirements. Views of Responsible Officials and Planned Corrective Actions ? Management agrees with the finding and implemented a procurement policy after year-end.