Finding Text
Finding 2022-002: COVID-19 Education Stabilization Fund, Higher Education Emergency Relief Funds, Procurement, Suspension and Disbarment Federal Program - COVID-19 Education Stabilization Fund (ESF) - Institutional Portion Federal Agency - U.S. Department of Education Pass-Through Entity - Not Applicable AL Number - 84.425F, 84.425N Federal Award Identification Numbers - P425F205088 Federal Award Year - June 30, 2022 Criteria: General procurement standards outlined in 2 CFR 200.318(a) state that a non-Federal entity. Must use its own documented procurement procedures which reflect applicable State, local, and tribal laws and regulations, provided that the procurements conform to the applicable Federal law and the standards identified by the Uniform Guidance (sections 200.318 ? 200.326). The Uniform Guidance outlines requirements over the proper oversight of contractors, having written standards of conduct for employees involved in contracting, awarding contracts to responsible contractors, maintaining records documenting the history of procurements including cost price analysis, conducting all transactions in a manner which provides full and open competition, having procedures for verifying that an entity with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded, utilizing the methods of procurement outlined in the Uniform Guidance, and ensuring every purchase order or contract includes the applicable provisions in Appendix II. Condition: The School?s policies and procedures over procurement generally comply with the requirements outlined by the Uniform Guidance, which establishes methods of procurement to be utilized related to the acquisition of both goods and services. However, the School?s policies do not fully adhere to the requirements, as there is no policy or procedure in place related to the verification of vendor suspension or debarment prior to contracting with the vendor. Additionally, the auditors reviewed one procurement transaction over the micro-purchase threshold and noted that the School?s policies were not followed with regard to ensuring full and open competition by obtaining bids or quotes. The School did check for suspension/disbarment following our identification of the finding, and there were no issues. Questioned Costs: Not applicable. Context: Not applicable. Cause: The School's policies were not compared to Uniform Guidance to ensure all elements were incorporated prior to entering into a contract with a vendor for which federal funds were the source of the expenditure. Additionally, the School?s procedures were not followed appropriately with regard to vendor bids/selection. Effect: The School is at risk of procuring goods and services that are not in compliance with the requirements of the Uniform Guidance, which increases the risk of federal funds being used improperly or the School entering into a covered transaction with a vendor that is suspended or debarred. Recommendation: The School should revise its policies and procedures to comply with the requirements of the Uniform Guidance and ensure that they are followed to verify that a vendor with which it plans to enter into a covered transaction is not debarred, suspended, or otherwise excluded. Additionally, all employees involved in procurement should be trained on the School?s procurement policies and procedures to avoid a break down of internal controls designed to reduce the risk of improper expenditures. Management's Response: Management did review all HEERF-related contracts and expenditures for reasonableness to ensure that the school was being prudent with its financial resources. Management agrees with the finding and will draft a ?Federal Grants Management Policy Manual? and implement related procedures which will be in compliance with 2 CFR 200.318(a). Policy and procedures will address all applicable compliance requirements.