Finding Text
US Department of Education
Education Stabilization Fund
Program Name: Higher Education Emergency Relief Fund (HEERF), Institutional Aid Portion
Assistance Listing #: 84.425F
Finding: 2022 – 001
MATERIAL NONCOMPLIANCE / SIGNIFICANT DEFICIENCY
Procurement
Condition: The College does not have documented procurement procedures.
Cause: The College has not previously received funds that allowed for institutional spending that would have required documented procurement procedures.
Effect: The College used their guiding principles and internal purchasing review policies to guide procurement which does not meet the requirement of 2 CFR 200.318(i) to keep record of the “rationale for the method of procurement.”
Questioned Costs: $231,484 . This amount was determined by totaling all the related grant expenditures that required procurement procedures.
Criteria: 2 CFR section 200.318 requires that non-federal entities other than states must follow the procurement standards set out at 2 CFR sections 200.318 through 200.326. These entities must use their own documented procurement procedures which must reflect applicable state and local laws and regulations as well as the procurement requirements identified in 2 CFR Part 200.
Recommendation: Before being awarded additional federal monies available for procurement expenditure, the College should document procurement policies and procedures that meet all compliance requirements in 2 CFR Part 200.
Views of responsible personnel and planned corrective actions: The College agrees with this finding while maintaining that the entirety of the questioned costs were for allowable expenditures under HEERF Institutional Aid compliance. Prior to expending federal funds for future procurement expenditures, the College will implement documented procurement procedures. Please refer to corrective action plan on page 13.