Talladega CollegeHigher Education

Federal Program: Higher Education Institutional Aid (Title III) Assistance Listing Number: 84.031 Compliance Requirement: Procurement, Suspension and Debarment Criteria: Per 2 CFR § 180.220 and 2 CFR § 200.318, non-federal entities are required to have written procurement policies and procedures governing the acquisition of goods and services funded by federal awards. Furthermore, a non-federal entity is prohibited from contracting with or making subawards to parties that are suspended or debarred. Recipients must verify that the entity is not excluded or disqualified by checking the System for Award Management (SAM.gov), collecting a certification from the entity, or adding a clause or condition to the contract. Condition: During our test of 51 procurement transactions, we noted that for 12 contracts (exceeding the $25,000 threshold), the College could not provide documentation that a suspension and debarment check had been performed via SAM.gov prior to the award. Additionally, the contracts did not include a provision requiring the contractor to certify their eligibility. Cause: Management had not implemented a formal, documented process requiring staff to perform and retain evidence of SAM.gov checks for all covered transactions. Staff involved in the procurement process were unaware of the specific documentation requirements under the Uniform Guidance. Effect: The College entered into contracts with vendors without verifying their eligibility to receive federal funds. While our subsequent search of SAM.gov revealed that the vendors involved were not actually suspended or debarred, the College was in violation of federal compliance requirements. Questioned Costs: None (since the vendors were not actually excluded). Recommendation: Management should draft and adopt a formal procurement manual. For every federally funded purchase exceeding the micro-purchase threshold, staff must print and file a SAM.gov "Exclusion Search" result prior to executing the contract. Views of Responsible Officials: Management agrees with the finding. We are currently implementing a new procurement checklist that requires a printed copy of the SAM.gov search result to be attached to the purchase order packet. Staff training on federal procurement requirements will be required.

Condition Documentation supporting Title III expenditures could not be located for certain transactions selected. Criteria 2 CFR Part 200.400(d) states, " [t]he accounting practices of the recipient and subrecipient must be consistent with these cost principles and support the accumulation of costs as required by these cost principles, including maintaining adequate documentation to support costs charged to the Federal Award." Further, OMB A-133 Compliance Supplement, Compliance requirement B. Allowable Costs/Cost Principles "Basic Guidelines".. require that expenses/expenditures charged to federal programs be adequately documented. Cause Controls for accumulating and maintaining supporting documentation for Federal award expenditure were not followed. Effect Costs charged to Title III program may be disallowed. Context A sample of 35 non-payroll expenditures totaling $502,650 was selected for testing from a population of 173 totaling $142,441. Testing found that 9 expenditure transactions contained inadequate or no supporting documentation. Our sample was not statistical. Recommendation We recommend the College should review the Title III expenditures charged to the program during fiscal year 2024 to determine the allowability of the costs.

2021-01 Late Submission of Audit to the Federal Audit Clearinghouse Criteria Title 2 Part 200, Uniform Administrative Requirements, Cost Principles, and Requirements of Federal Awards (Uniform Guidance), paragraph 200.512(a)(1),states that the audit must be completed and that data collection form submitted within the earlier of 30 calendar days after receipt of the auditor's report or nine months after the end of the audit period, whichever is earlier. Condition The College's audit reporting package for 2021 audit was not completed and submitted to the Federal Clearinghouse,as required. Cause Audit delays including the need for significant audit adjustments caused delay's in audit's completion and submission to the Clearinghouse. Effect The College did not comply with the terms if the Uniform Guidance Subpart F audit report submission requirements. Recommendation We recommend that management of the College make the necessary changes in personnel and examine those areas as needed to insure that all reporting requirements, and submission time frame as it relates to audited financial statements be corrected as soon as possible.