Finding Text
Department of Education
COVID-19 Higher Education Emergency Relief Fund (HEERF) – Assistance Listing #84.425E, #84.425F
#2023-002 – Major Federal Award Finding – Procurement and Suspension and Debarment
Material Weakness in Internal Controls over Compliance
This is a repeat of prior year finding #2022-002.
Conditions: We noted during testing of procurement for the HEERF program (Institutional Aid) that the University’s procurement policy was not being followed. 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 two transactions over the micro purchase threshold. These transactions were subject to the procurement processes required by the Uniform Guidance as it relates to price quotations. We tested two transactions for a vendor over the simplified acquisition threshold. These transactions were not 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: The University agrees with the recommendations put forth by the auditors. The University will review its current procurement policy to include federal regulations 2 CFR Section 200.317-200.326. Proper oversight will be provided over the procurement process. See also attached Corrective Action Plan.