Finding Text
Federal Program Information:
Higher Education Institutional Aid: Strengthening Historically Black Colleges and Universities Program (ALN: 84.031B and 84.031E)
Criteria or Specific Requirement (Including Statutory, Regulatory or Other Citation):
I. Procurement and Suspension and Debarment – The Uniform Guidance requires recipients of federal awards to have adequate procedures and controls in place to ensure that the procurement transactions are properly documented in the entity’s files, provide full and open competition supported by a cost or price analysis, provide a vendor debarment or suspension certification, provide for retention of files, and that supporting documentation corroborates compliance with these requirements. All procurement transactions are required to be conducted in a manner to provide, to the maximum extent practical, open and free competition. Additionally, procurement records and files for purchases in excess of the small purchase threshold ($25,000) shall include a) a basis for contractor selection, b) justification for the lack of competition when competitive bids or offers are not obtained, and c) a basis for award cost or price. Organizations are also required to be alert to any organizational conflicts of interest (2 CFR 215.40 – 215.48).
Condition:
The University was unable to provide documentation supporting an appropriate competitive bidding process, sole source justification and/or appropriate review of the federal suspension and debarment database prior to the disbursement of funds.
Cause:
Insufficient administrative oversight and internal controls over procurement compliance requirements.
Effect or Potential Effect:
The University was not in compliance with procurement compliance requirements.
Questioned Costs:
None.
Context:
For 5 of 5 procurement transactions tested, the University was unable to provide documentation supporting an appropriate competitive bidding process, sole source justification and/or appropriate review of the federal suspension and debarment database prior to the disbursement of funds.
Identification as a Repeat Finding:
No similar findings noted in the prior year.
Recommendation:
We recommend the University enhance its internal controls and implement formal policies and procedures to ensure that its personnel, especially those responsible for making procurement decisions, are aware of and comply with all federal purchasing rules and regulations.
Views of Responsible Officials:
The University eliminated the position of Procurement Manager several years back, which decentralized the responsibility for procurement. The change led to a loss of institutional knowledge, and interrupted policy and process enforcement campus wide.
GSPAR will enhance its internal controls and implement formal policies and procedures to ensure that those responsible for procurement activities are aware of, and comply with, all federal purchasing rules and regulations. The GSPAR will ensure the appropriate documentation related to debarment, sole source justification and bidding process are received, or attached to the purchasing requisition, prior to approving purchases. In addition, the grant onboarding process will be revised to emphasize key federal regulations and emphasize the importance of compliance. Reminders will also be provided during GSPAR’s semi-annual grant compliance workshops.