Finding 8496 (2023-001)

2023-001 Federal Program Name: COVID-19 Higher Education Emergency Relief Fund (HEERF) - COVID-19 HEERF Minority Serving Institutions (MSIs) Federal Assistance Listing Number: 84.425L Award Year: July 6, 2020 – June 30, 2023 Condition: The University's procurement policy does not contain adequate documentation to demonstrate compliance with federal procurement regulations (Deficiency). Questioned Costs: None. Context: The University's documented procurement policies do not contain all the specific requirements of 2 CFR sections 200.318 through 200.326. Effect: The risks exist that the University could follow their procurement policy and procure an item with federal funds, which would not meet the federal procurement regulations. Cause: The writing of the policy did not take into account the federal procurement regulations which are required to be incorporated for items procured with federal funds. Repeat Finding: No. Recommendation: We recommend that the University revise procurement policies to incorporate all required elements of the federal procurement regulations. Views of Responsible Officials and Planned Corrective Action: The University agrees with the comment and will revise procurement policies and incorporate all required elements of the federal procurement regulations.