Finding 640944 (2022-001)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2022
Accepted
2023-03-27
Audit: 75144
Organization: Northwest Nazarene University (ID)

AI Summary

  • Core Issue: The University lacks documentation to confirm that vendors are not suspended or debarred, risking compliance violations.
  • Impacted Requirements: This finding relates to procurement standards outlined in the Uniform Guidance, specifically sections 200.317 to 200.326.
  • Recommended Follow-Up: Implement a process to check vendors on SAM.gov before payment and ensure a supervisor conducts a second review of this documentation.

Finding Text

2022-001: Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: Higher Education Emergency Relief Funds Assistance Listing Number: 84.425F Award Period: July 01, 2021 - June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance and Other Matters Criteria or Specific Requirement: The CRF subsections 200.317 through 200.326 address procurement standards within the Uniform Guidance. These standards include elements that should be included in a written procurement policy. Additionally, non-federal entities are prohibited from contracting with or making subawards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet other criteria as specified in 2 CFR section 180.220. All non-procurement transactions entered into by a pass-through entity (i.e., subawards to subrecipients), irrespective of award amount, are considered covered transactions, unless they are exempt as provided in 2 CFR section 180.215?. Condition: During testing, it was noted there was no documentation to ensure the vendors were not suspended or debarred. In addition, there was no documentation of a second review to ensure the vendors were not suspended or debarred. Questioned Costs: None Context: During testing, it was noted there was no documentation to ensure certain vendors were not suspended or debarred. Cause: The University?s control system to document the prevention of contracting with a suspended and barred vendor was not in place. Effect: The University could have paid a vendor who was suspended or barred at the time of payment. Repeat Finding: Yes, see 2021-001 Recommendation: We recommend documenting the vendor was checked on the SAM.gov website prior to payment. In addition, We also recommend a supervisor review the documentation prior to payment as a second review. Views of Responsible Officials: Management agrees with finding.

Categories

Procurement, Suspension & Debarment Subrecipient Monitoring

Other Findings in this Audit

  • 64497 2022-002
    Significant Deficiency
  • 64498 2022-002
    Significant Deficiency
  • 64499 2022-002
    Significant Deficiency
  • 64500 2022-002
    Significant Deficiency
  • 64501 2022-002
    Significant Deficiency
  • 64502 2022-001
    Significant Deficiency Repeat
  • 640939 2022-002
    Significant Deficiency
  • 640940 2022-002
    Significant Deficiency
  • 640941 2022-002
    Significant Deficiency
  • 640942 2022-002
    Significant Deficiency
  • 640943 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $12.65M
84.425E Higher Education Emergency Relief Funds $2.18M
84.425F Higher Education Emergency Relief Funds $1.77M
84.063 Federal Pell Grant $1.76M
84.007 Federal Supplemental Education Opportunity Grants $180,812
84.033 Federal Work-Study Program $139,032
93.859 Inbre Grant $91,501
93.859 Inbre Grant - Pilot $48,093
43.008 Rocksat-X Program $25,421
84.379 Teacher Education Assistance for College and Higher Education Grants $24,521
10.170 2020 Specialty Crop Block Grant $14,482
93.859 Inbre Grant - Rain $7,238
10.170 2018 Specialty Crop Block Grant $4,004
47.083 Epscor Rii Track-1 $760
10.170 2021 Specialty Crop Block Grant $633