Finding Text
2022-001 Higher Education Emergency Relief Funds (HEERF) Procurement, Suspension and Debarment Federal Agency: U.S. Department of Education Federal Program Title: HEERF Assistance Listing Number: 84.425 Award Period: July 1, 2021 to June 30, 2022 Type of Finding: - Significant Deficiency in Internal Control Over Compliance - Other Matters Criteria or Specific Requirement: Title 2, Subtitle A, Chapter 2 Part 200, Subpart D, section 200.318 of the Code of Federal Regulations requires Colleges to have a written procurement policy that includes certain requirements as it relates to procuring goods and services using federal dollars. Additionally, 2 CFR 180.995 requires that the College has a written policy where Colleges should perform a check to ensure vendors are not debarred. Condition: During our testing, it was noted that the College did not have a procurement policy that contained certain required elements nor did they perform all the required procurement procedures related to the HEERF expenditures. Also, it was noted during testing that there is no written policy that requires the College to verify that vendors are suspended or debarred nor did they perform any procedures related to the HEERF expenditures on such vendors. Questioned Costs: None Context: The College did not have appropriate documentation that met the procurement, and suspension and debarment federal requirements. Furthermore, they did not have written policies in place at time of procurement or entering into contracts with vendors that aligned with the uniform guidance. Cause: The College was unaware of this federal requirement since it is their first federal grant that was non-student financial aid. Effect: All requirements were met, but it is also required that the policies be documented in a written form. Without written policies it is likely that required steps in the process may be missed. Repeat Finding: No Recommendation: We recommend that the College review their Procurement and Suspension and debarment policies and ensure that any missing federal requirements are included in their written policies. Views of responsible officials: There is no disagreement with the audit finding.