Air Force Academy Athletic Corporation

Criteria or Specific Requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires that when a non-federal entity plans to enter into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During testing of a sample of seven vendors subject to AFAAC Suspension and Debarment controls, we noted two instances where there was a lack of evidence that AFAAC verified that the vendor was not suspended or debarred before entering into a covered transaction with those vendors during fiscal year 2022. We also noted two instances where the suspension and debarment check was not performed annually. Questioned Costs: None Context: Two vendors, out of our sample of seven, were found to have no evidence of verification that the vendor was not suspended or debarred. Also, two vendors were found to not have an annual verification that the vendor was not suspended or debarred. We did later verify the vendors were not suspended or debarred. Cause: Due to turnover within the procurement department, documentation supporting the performance of suspension and debarment compliance checks could not be located. Effect: Without maintaining supporting evidence that suspension and debarment procedures were performed over all applicable vendors, the Organization cannot support that the federally required procedures were performed and could potentially contract with vendors who are suspended or debarred, causing AFAAC to be out of compliance with regulations. Repeat Finding: No. Recommendation: We recommend the Organization maintain evidence of suspension and debarment procedures to support compliance to federal regulations and to ensure that all potential vendors are not suspended or debarred. Also, we recommend that the Organization expand its purchasing procedures to add suspension or debarment certification and verification to all Organization purchase orders to ensure transactions in all funds are being verified for current suspension or debarment. Views of Responsible Officials: AFAAC agrees with the finding, see the Corrective Action Plan for management?s response.

Criteria or Specific Requirement: Federal regulations require recipients of federal funds to document the history of procurement transactions, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Federal regulations also specific certain procurement methods that recipients must use in certain circumstances. These regulations allow recipients to utilize a noncompetitive procurement method if one or more of the following circumstances apply: (1) The acquisition of property or services, the aggregate dollar amount of which does not exceed the micro-purchase threshold; (2) The item is available only from a single source; (3) The public exigency or emergency for the requirement will not permit a delay resulting from publicizing a competitive solicitation; (4) The Federal awarding agency or pass-through entity expressly authorizes a noncompetitive procurement in response to a written request from the non-Federal entity; or (5) After solicitation of a number of sources, competition is determined inadequate. Condition: During our testing, we noted that for one out of 19 procurement transactions tested the Organization did not have documentation of the history of procurement transaction, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price. Questioned Costs: None Context: The history of procurement transaction, including the rationale for the method of procurement, selection of contract type, basis for contractor selection, and the basis for the contract price was not documented for one of 19 procurement transactions tested. Cause: The Organization?s procurement policy states that procurement procedures are not required for certain transactions due to the nature of the transaction. Effect: The Organization may not be in compliance with federal regulations for certain procurement transactions. Repeat Finding: No. Recommendation: We recommend that the Organization revise its procurement policy so that procurement procedures apply to all transactions using thresholds and procurement methods specified by federal regulations, and maintain documentation required by such regulations. Views of Responsible Officials: AFAAC agrees with the finding, see the Corrective Action Plan for management?s response.

Federal agency: U.S. Department of Defense, Department of Air Force, Materiel Command Federal program title: Air Force Academy Athletic Programs CFDA Number: 12.801 Award Period: September 23, 2013 through June 30, 2020 Type of Finding: ? Compliance ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR 200.430(i) states that charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must be supported by a system of internal control which provides reasonable assurance that the charges are accurate, allowable, and properly allocated. These records must reasonably reflect the total activity for which the employee is compensated and support the distribution of the employee's salary or wages among specific activities or cost objectives if the employee works on more than one federal award; a federal award and non-federal award; an indirect cost activity and a direct cost activity; two or more indirect activities which are allocated using different allocation bases; or an unallowable activity and a direct or indirect cost activity. Condition: During our testing of 42 employees with time coded to the grant, we noted two (2) instances where the approved time and effort percentage was not the same percentage used to allocate their wage to the grant. Questioned costs: $352.56, of which $316.66 management later backed out of charges to the grant. Context: Two employees, out of our sample of 42, were found to have an overstated time and effort percentage applied against the grant. Cause: Per discussion with management, AFAAC manually enters all employees approved time and effort percentages into a spreadsheet that is used to allocate department wages against the grant. Two employees time and effort percentages were entered incorrectly, thus an overallocation of wages were charged against the grant. In our discussions with management, we noted there is not a review to ensure all time and effort percentages are entered correctly. Instead, AFAAC reviews a selective sample of time and effort percentages. Effect: Current controls did not ensure time and effort records agree to the time and effort charged to the grant, causing the organization to be out of compliance with regulations. Repeat Finding: No Recommendation: We recommend the Organization enhance current review and control procedures to identify errors in the amount charged to the program versus time actually worked. In enhancing such controls, the Organization should consider a more automated process to reduce manual errors in the time allocation process. Views of responsible officials: AFAAC agrees with the finding, see the Corrective Action Plan for management?s response. AFAAC management is reviewing all the time and effort percentages claimed versus the percentages identified on the time and effort memos approved and submitted by the supervisors to ensure there is not an error in the percentages claimed for allocating the payroll costs to the federal award. In addition, AFAAC management is exploring more efficient way to automate the process in identifying and claiming the time and effort percentages for allocating the payroll costs to the federal award.

2020 ? 002: Suspension and Debarment Federal agency: U.S. Department of Defense, Department of Air Force, Materiel Command Federal program title: Air Force Academy Athletic Programs CFDA Number: 12.801 Award Period: September 23, 2013 through June 30, 2020 Type of Finding: ? Compliance ? Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: 2 CFR Part 200 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Award requires that when a non-federal entity plans to enter into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. This verification may be accomplished by (1) checking the Excluded Parties List System (EPLS) maintained by the General Services Administration (GSA) and available at https://www.sam.gov/portal/public/SAM/, (2) collecting a certification from the entity, or (3) adding a clause or condition to the covered transaction with that entity (2 CFR section 180.300). Condition: During testing of a sample of eight vendors subject to AFAAC Suspension and Debarment controls, we noted six instances where there was a lack of evidence that the Organization verified that the vendor was not suspended or debarred. Questioned costs: None Context: Six vendors, out of our sample of eight, were found to have no evidence of verification that the vendor was not suspended or debarred. We did later verify the vendors were not suspended or debarred. Cause: Due to turnover within the procurement department, documentation supporting that suspension and debarment procedures were performed could not be located. Effect: Without maintaining supporting evidence that suspension and debarment procedures were performed over all applicable vendors, the Organization cannot support that the federally required procedures were performed and could potentially contract with vendors who are suspended or debarred, causing the organization to be out of compliance with regulations. Repeat Finding: No. Recommendation: We recommend the Organization maintain evidence of suspension and debarment procedures to support compliance to federal regulations and to ensure that all potential vendors are not suspended or debarred. Views of responsible officials: AFAAC agrees with the finding, see the Corrective Action Plan for management?s response. Training was provided to the new Procurement Director to make sure this process is followed and maintained. This has been done to go along with communication to staff that all types or forms of contracts or agreements must go through our Procurement Contracting Department so that the vendor can be checked for suspension and debarment prior to execution of the contract or agreement.

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