Finding 6144 (2023-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2023-12-21
Audit: 7999
Organization: Grace Christian University (MI)

AI Summary

  • Core Issue: The University is not following its own procurement policy for HEERF funding, leading to a repeat finding of non-compliance.
  • Impacted Requirements: Federal regulations require documented procurement procedures and competitive bidding for purchases over certain thresholds.
  • Recommended Follow-Up: Management should update the procurement policy to align with federal regulations and ensure compliance moving forward.

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.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 6142 2023-003
    Significant Deficiency Repeat
  • 6143 2023-002
    Material Weakness Repeat
  • 6145 2023-003
    Significant Deficiency Repeat
  • 582584 2023-003
    Significant Deficiency Repeat
  • 582585 2023-002
    Material Weakness Repeat
  • 582586 2023-002
    Material Weakness Repeat
  • 582587 2023-003
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $4.88M
84.063 Federal Pell Grant Program $2.58M
84.425 Education Stabilization Fund $1.01M
84.007 Federal Supplemental Educational Opportunity Grants $50,000
84.033 Federal Work-Study Program $25,000
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $1,886