Finding Text
Assistance Listing Number, Federal Agency, and Program Name - Research and Development Cluster - National Science Foundation Computer and Information Science and Engingeering, Department of Education State Energy Program, Department of Commerce Economic Adjustment Assistance - ALN 47.070, 81.041, 11.307 Federal Award Identification Number and Year - Various Pass through Entity - N/A Finding Type - Significant deficiency Repeat Finding - No Criteria - A non federal entity must conduct all procurement transactions in a manner providing full and open competition, in accordance with 2 CFR section 200.319. Condition - The University could not support full and open competition for 10 of the 18 samples tested. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A Context - The University utilized recommended or existing vendors and could not evidence full and open competition existed prior to selection of the vendor. Cause and Effect - Purchasing policies in place are not followed in all circumstances. For expenditures at or below certain thresholds, project investigators have the ability to circumvent controls and contract with vendors and/or make purchases prior to receiving necessary approvals. Recommendation - The University should implement controls to ensure all grant funded expenditures are appropriately subject to full and open competition, in accordance with 2 CFR section 200.319, and conclusions to award contracts are memorialized. Views of Responsible Officials and Planned Corrective Actions - Management will revise its Procurement Policy to require documentation supporting the rational for why a noncompetitive bid is utilized in a procurement decision using federal funds.