Finding 971394 (2023-003)

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Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-04-28

AI Summary

  • Core Issue: SWAU lacks procedures to prevent contracting with suspended or debarred parties, violating federal compliance requirements.
  • Impacted Requirements: Noncompliance with 2 CFR Part 180, which mandates grantees to establish prohibitive measures against suspended or debarred entities.
  • Recommended Follow-Up: Management should create and implement a written procedure to ensure compliance with prohibitions against doing business with debarred or suspended parties.

Finding Text

Information on the federal program: Higher Education Institutional Aid - Hispanic-Serving Institutions – Science, Technology, Engineering, or Mathematics and Articulations Programs (Assistance Listing number 84.031C); United States Department of Education; Award Year 2022-23; Compliance Requirement – Procurement and Suspension & Debarment; Type of Finding – Material Noncompliance. Criteria: 2 CFR Part 180 requires that grantees establish procedures that prohibit the entity from contracting with or making subawards to parties that are suspended or debarred by the federal government. Condition: SWAU’s internal control policies and procedures do not address the prohibition of doing business with suspended or debarred parties. Cause: Although SWAU was notified of this requirement in two previous audit years, audit follow-up procedures were not put in place due to management personnel changes. Effect: Goods or services for the grant could have been provided by a debarred or suspended party, in violation of federal regulations. Questioned Costs: n/a for this finding. Context: Current year goods and services totaled $542,779 for this grant. For the nine goods and services disbursements we tested, totaling $492,896, we searched the federal list of debarred/suspended parties and did not find any of them listed. Recommendations: Management should immediately implement a written procedure that prohibits doing business with debarred or suspended parties and includes steps to ensure compliance with that prohibition. Responsible Official’s Response and Corrective Action Planned: see corrective action plan.

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $4.07M
84.063 Federal Pell Grant Program $1.67M
84.031 Higher Education_institutional Aid $596,567
84.033 Federal Work-Study Program $136,300
84.007 Federal Supplemental Educational Opportunity Grants $90,034
84.425 Education Stabilization Fund $31,861
15.364 Competitive State Wildlife Grant $17,179