Finding Text
2022-002 U.S. Department of Education Financial Assistance Listing No. 84.425E, 84.425F, and 84.425M COVID-19 ? Higher Education Emergency Relief Funds ? Student, COVID-19 ? Higher Education Emergency Relief Funds ? Institutional, and COVID-19 ? Strengthening Institutions Program Procurement, Suspension, and Debarment Significant Deficiency in Internal Control Criteria: Entities expending federal monies are required to have a written procurement policy that is compliance with Uniform Guidance, 2 CFR Section 200.318-327. Condition: While the University does have a written compliance policy, elements that are required by Uniform Guidance, 2 CFR Section 200.318-327, are missing from the written policy. Cause: The University previously had not received federal awards, other than Student Financial Assistance monies. As a result, they did not have a written procurement policy in place. Management worked on creating a policy in the prior fiscal year, however the policy does not include all the required elements. Effect: The University?s written procurement policy is not compliant with Uniform Guidance, 2 CFR Section 200.318-327. Questioned Costs: None. Context/Sampling: HEERF was not selected as a major program in the current year, as such no sampling occurred. The Auditor obtained a copy of the newly written procurement policy to test the policy?s compliance with Uniform Guidance. Repeat Finding from Prior Year(s): Yes, finding 2021-003 Recommendation: Management should review their procurement policy in combination with the language of Uniform Guidance, 2 CFR Section 200.318-327, to ensure the required elements from the guidance are included in the written procurement policy. Views of Responsible Officials: Management agrees with the finding.