Finding Text
Department of Education COVID-19 Higher Education Emergency Relief Fund (HEERF) ? Assistance Listing #84.425E, #84.425F #2022-002 ? Major Federal Award Finding ? Procurement and Suspension and Debarment Material Weakness in Internal Controls over Compliance Conditions: We noted during testing of procurement for the HEERF program (Institutional Portion) that the University?s procurement policy was not being followed. Multiple price quotations were not obtained for projects over the micro purchase threshold, and competitive bids were not obtained for projects over the simplified acquisition threshold. Criteria: Federal regulations 2 CFR Section 200.317- 200.326 provide that the University must have and use documented procurement procedures and follow written standards that promote full and open vendor competition. Methods included in written standards covering the acquisition of property or services under a Federal award or sub-award must be consistent with specific thresholds as set forth in CFR 200.320. There are five allowable procurement methods described in ?200.320, depending upon the dollar value of the purchase or contract. Cause/Context: We tested five transactions over the micro purchase threshold. None of these transactions were subject to the procurement processes required by the Uniform Guidance as it relates to price quotations and/or competitive bids. Recommendation: Management should review the University?s procurement policy and update appropriately to reference Uniform Guidance and specific purchasing thresholds. The University should ensure that it follows the requirements outlined in its procurement policy in accordance with the Uniform Guidance. Views of Responsible Officials and Planned Corrective Actions: Finding has been reviewed and addressed. See attached Corrective Action Plan.