Finding Text
2022 ? 002: Procurement Federal agency: U.S. Department of Education Federal program title: Education Stabilization Fund: Higher Education Emergency Relief Fund Student Portion and Institutional Portion ALN Number: 84.425E, 84.425F Pass-Through Agency: N/A Pass-Through Number(s): N/A 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: Tile 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Universities to have a written procurement policy that includes certain requirements as it relates to procuring good and services using federal dollars. Additionally, 2 CFR 180.995 requires that the University has a written policy where Universities should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the University has a written procurement policy in place, however, the University did not adhere to the policy when acquiring goods with the HEERF funding. Also, it was noted during testing that there is no written policy that requires the University to verify that vendors are suspended or debarred. Questioned costs: None Context: The University did not have appropriate documentation that met the procurement, and suspension and debarment federal requirements. Cause: The University was unaware of this federal requirement. Effect: Without written policies it is likely that required steps in the process may be missed. Repeat Finding: The finding is a repeat of a finding in the immediately prior year. Prior year finding number was 2021-002. Recommendation: We recommend that the University review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.