Finding Text
CRITERIA The Board adopted policies that require the collection of quotes for purchases of at least $10,000 but no more than $100,000, and formal bid procedures for purchases over $100,000. In addition, the Uniform Guidance requires employees to verify that the vendor, supplier, contractor, subcontractor, provider, or their respective principals (e.g., owners, top management, etc.) with expenditures in excess of $25,000 are not suspended, debarred or otherwise excluded by the Federal Government. The Campus should consult the Federal Excluded Parties List System (EPLS) before awarding funds and print the documentation to maintain in the contract file. This requirement is specified in 2 CFR §180.220. CONDITION The Campus did not follow its Board adopted policies or federal regulations regarding the collection of quotes and suspension and debarment. CAUSE The Campus has not implemented controls to perform the collection of quotes and suspension and debarment checks for vendors. In addition, documentation was not always maintained. EFFECT The Campus was not in compliance with the Board adopted policies. Additionally, the Campus was not compliant with 2 CFR §180.220 and as a result could have entered into a contract with a suspended or debarred party. CONTEXT For two of two purchases reviewed within the Campus’s quote range, quotes were not maintained. In addition, the Campus did not check to see if vendors were suspended or debarred. However, it was determined that vendors were not suspended or debarred. Samples were not intended to be, and were not, statistically valid samples.