Finding 609605 (2022-002)

Significant Deficiency
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-29
Audit: 29857
Organization: Prescott College, Inc. (AZ)

AI Summary

  • Core Issue: The College lacks documented procurement procedures that comply with federal regulations, risking noncompliance.
  • Impacted Requirements: Failure to meet criteria from the Code of Federal Regulations and Uniform Guidance regarding vendor verification and procurement documentation.
  • Recommended Follow-Up: Implement documented suspension and debarment procedures for vendors over $25,000, update procurement policies, and retain documentation as per compliance requirements.

Finding Text

2022-002 Procurement Federal Agency: Department of Education Federal Program Title: Higher Education Emergency Relief Funds ALN Numbers: 84.425F Award Period: July 1, 2021 through June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or specific requirement: The Code of Federal Regulations section 215.44 states written selection procedures require solicitations for goods or services incorporate a clear and accurate description of the technical requirements for the material, product, or service to be procured, identify all requirements for the material, product, or service to be procured, identify all requirements that the offerors must fulfill, and include all other factors to be used in evaluating bids or proposals. In addition, per Uniform Guidance 2 CFR sections 200.212 and 200.318(h); 2 CFR section 180.300; 48 CFR section 52.209-6, a non-federal entity must have procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Condition: During our testing, we noted the College did not have properly documented procurement regulations that met the federal requirements. We were unable to verify any procurement methods used for the vendor tested. In addition, during our testing, we noted for one out of the one vendors over $25,000 tested, there was not documented suspension and debarment procedures. Questioned costs: None Context: The College did not have documented procurement procedures or procedures in place to verify vendors had not been suspended or debarred. They were not following procurement requirements under Uniform Guidance. Cause: The College was not aware of the requirements of the Uniform Guidance. Effect: The lack of documented procurement regulations and policies over these compliance requirements provides an opportunity for noncompliance. In addition, the College could enter into a covered transaction with a vendor who is suspended or debarred. Repeat Finding: No Recommendation: We recommend the College document suspension and debarment procedures going forward for any vendors with federal expenditures over $25,000. We also recommend a procurement policy be implemented that meets the requirements of Uniform Guidance as well as the conflict of interest policy is updated to conform with Uniform Guidance. Lastly, we recommend documentation be retained as it relates to the methodology chosen for procurement in accordance with the procurement policy. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 33159 2022-003
    Significant Deficiency Repeat
  • 33160 2022-003
    Significant Deficiency Repeat
  • 33161 2022-003
    Significant Deficiency Repeat
  • 33162 2022-003
    Significant Deficiency Repeat
  • 33163 2022-002
    Significant Deficiency
  • 609601 2022-003
    Significant Deficiency Repeat
  • 609602 2022-003
    Significant Deficiency Repeat
  • 609603 2022-003
    Significant Deficiency Repeat
  • 609604 2022-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $11.55M
84.063 Federal Pell Grant Program $898,030
84.425E Heerf Student Aid Portion $579,228
84.425F Heerf Institutional Portion $503,249
84.031A Title Iii: Making A Difference: Transforming the Undergraduate Experience $368,364
84.007 Federal Supplemental Educational Opportunity Grants $108,079
10.310 Agriculture and Food Research Initiative (afri) $105,909
94.013 Volunteers in Service to America $88,099
84.033 Federal Work-Study Program $72,978
84.425M Heerf Strengthening Institutions $46,156
94.006 Americorps $23,012
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $21,020
15.637 Migratory Bird Joint Ventures $8,400
84.425N Heerf Fund for the Improvement of Postsecondary Education (fipse) Formula Grant $0