Finding Text
2022 ? 003: Suspension and Debarment Federal Agency: U.S. Department of Agriculture Federal Program Name: Rural Business Development Grant Assistance Listing Number: 10.351 Federal Award Identification Number and Year: Borrower ID: 32-087-295542779 - Year Ended June 30, 2022 Award Period: 7/1/2021 ? 6/30/2022 ____________________________________________________ Federal Agency: U.S. Department of Interior Federal Program Name: Assistance to Tribally Controlled Community Colleges and Universities Assistance Listing Number: 15.027 Federal Award Identification Number and Year: A19AP00124 ? Year Ended June 30, 2022 Award Period: 7/1/2019 ? 6/30/2024 ____________________________________________________ Federal Agency: U.S. Department of Education Federal Program Name: COVID-19 Education Stabilization Fund: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425K Federal Award Identification Number and Year: P425K200020-20B -Year Ended June 30, 2022 Award Period: 05/28/2020 ? 06/30/2024 Type of Finding: ? Significant Deficiency in Internal Control over Compliance ? Other Matters Criteria or specific requirement: Section 200.303, Internal Controls, states that the College shall ?establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. Condition: The College had not established a policy or an effective internal control system related to the grant agreements and the Procurement, Suspension, and Debarment compliance requirement. The College?s current procurement policy does not include a documented process to ensure vendors meet suspension and debarment requirements. In addition, there was no documentation that the Authority had searched all applicable vendors on the System for Award Management (SAM) to ensure that the College?s vendors were not suspended or debarred. Questioned costs: None Context: Procurement policies were followed, but no documented process to ensure suspension and debarment noted. Cause: The current policy and internal control structure does not include a process for ensuring suspension and debarment requirements are met for all required vendors. Effect: The College may contract with or make subawards under covered transactions to parties that are suspended or debarred. Repeat Finding: No Recommendation: The College should consider updating their current procurement policy to include suspension and debarment processes and implement appropriate internal controls to ensure the processes are followed. Views of responsible officials: The College agrees with the auditor?s comments and has taken corrective action to ensure suspension and debarment consideration is added to policies and procedures.