Northwest CollegeHigher Education

See Schedule of Findings and Questioned Costs for chart/table 2022-001: Procurement and Suspension and Debarment Criteria: Per 2 CFR 200.318(i), the non-Federal entity must maintain records sufficient to detail the history of procurement. These records will include, but are not necessarily limited to, the following: the rationale for the method of procurement, selection of contract type, contractor selection or rejection, and the basis for the contract price. Per 2 CFR 200.214, non-Federal entities are subject to the nonprocurement debarment and suspension regulations implementing Executive Orders 12549 and 12689, 2 CFR Part 180. The regulations in 2 CFR Part 180 restrict awards, sub-awards, and contracts with certain parties that are debarred, suspended, or otherwise excluded from, or ineligible for, participation in Federal Assistance programs or activities. Per 2 CFR 180.220, non-Federal entities are prohibited from contracting with or making sub-awards under covered transactions to parties that are suspended or debarred or whose principals are suspended or debarred. Covered transactions include contracts for goods and services awarded under a nonprocurement transaction that are expected to equal or exceed $25,000 or meet certain other criteria as specified in 2 CFR Section 180.220. All nonprocurement transactions entered into by a pass-through entity (i.e., sub-awards to subrecipients), irrespective of award amount, are considered covered transactions unless they are exempt as provided in 2 CFR Section 180.215. Condition/context: Five transactions were subject to the requirements of procurement based on the transaction price. Of the three transactions tested during the audit, all three were identified as not having the proper documentation supporting the procurement method. Five vendors were subject to the requirements of suspension and debarment. Of the three vendors tested during the audit, all three were identified as not having the proper documentation supporting the review of the suspension and debarment requirements prior to funds being expended. None of the entities were suspended or debarred. Questioned costs: $0 Cause: While the College has a procurement policy in place that appropriately addresses procurement, suspension and debarment, the policy was not properly followed, resulting in a lack of supporting documentation for the procurement and review of the suspension and debarment of vendors in the fiscal year. When the pandemic originally began, exceptions from competitive procurement requirements of the Uniform Guidance could be accepted if a public emergency would not permit a delay; however, the flexibility from competitive procurement has been reduced as it is unlikely the same circumstances would be occurring. The College was still operating under this previous flexibility and utilized prior vendors through sole source contracts. Effect: Per 2 CFR 200.339, if a non-Federal entity fails to comply with the U.S. Constitution, Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency or pass-through entity may impose additional conditions, as described in ? 200.208. If the Federal awarding agency or pass-through entity determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency or pass-through entity may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency or pass-through entity. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Identification as a repeat finding: No. Recommendation: We recommend that management ensure it is staying updated with changes in guidance and program requirements. In addition, for more consistent application, we recommend that the procurement policy be modified to more clearly state that documentation will be maintained to identify and maintain proper supporting documentation for the method of procurement utilized and for the review of the suspension and debarment requirement. Furthermore, we recommend that the procurement policy be modified to more clearly state vendors with a transaction, in the aggregate, greater than the micro-purchase threshold are required to be procured under approved procurement methods. Views of responsible officials and planned corrective actions: Management concurs with the finding. See Exhibit I.

See Schedule of Findings and Questioned Costs for chart/table 2021-001: Reporting Criteria: 2 CFR 200.327 ? Financial Reporting; and the laws, regulations, and the provisions of contract or grant agreements pertaining to the specific programs require that reports be complete, accurate, and supported by accounting records (if applicable) and be submitted in compliance with the appropriate deadlines. Per various guidance published by ED, the Higher Education Emergency Relief Fund (HEERF) portion of the ESF requires the following with respect to reporting: ? Annual reporting: The HEERF Data Collection Form was required to be submitted to ED via the Annual Report Data Collection System on February 8, 2021 and applied to the reporting period from March 13, 2020 through December 31, 2020. ? Quarterly public reporting (student portion): Institutes of Higher Education (IHE) was required to publicly post certain information on its website no later than 30 days after award and update that information every 45 days thereafter. However, on August 31, 2020, ED revised the requirement by decreasing the frequency of reporting after the initial 30-day period from every 45 days thereafter to every calendar quarter. Instead of posting a 45-day report on or after August 31, 2020, IHE should post a report every calendar quarter, with the first calendar quarter report due by October 10, 2020, and covering the period from after its last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020. IHE may have until the end of the second calendar quarter, June 30, 2021, to post these retroactive reports if it has not already done so. ? Quarterly public reporting (institutional portion): A new, separate form was to be posted covering aggregate amounts spent for all HEERF funds each quarterly reporting period. IHE must post this quarterly report form no later than 10 days after the end of each calendar quarter apart from the first report, which was due on October 30, 2020, and the report covering the first quarter of 2021, which was due on July 10, 2021. The forms are required to be conspicuously posted on the institution?s primary website on the same page the reports of IHE?s activities as to the emergency financial aid grants to students (Student Portion) are posted. Condition/context: A total of five reports were selected for testing, including one annual report, two quarterly reports related to the Student Portion and two quarterly reports related to the Institutional Portion. Of these five reports, two of the reports contained errors, including: ? The Annual Report for the period ended December 31, 2020 did not properly report the expenditure balance in the correct expenditure category nor within the correct Coronavirus Aid, Relief, and Economic Security (CARES) Act section. ? The Quarterly Institutional report for the period ended December 31, 2020 reported cumulative expenditures and not the expenditures incurred during the period reported. Questioned costs: $0 Cause: The required reports were new within the fiscal year and guidance related to the reports was issued continuously. The College?s internal control system did not have a sufficient control process in place to review the reports for propriety to identify errors. Effect: If a non-Federal entity fails to comply with Federal statutes, regulations, or the terms and conditions of a Federal award, the Federal awarding agency may impose additional conditions, which include requiring payments as reimbursements rather than advance payments; withholding authority to proceed to the next phase until receipt of evidence of acceptable performance within a given period of performance; requiring additional, more detailed financial reports; requiring additional project monitoring; requiring the non-Federal entity to obtain technical or management assistance; and establishing additional prior approvals. If the Federal awarding agency determines that noncompliance cannot be remedied by imposing additional conditions, the Federal awarding agency may take one or more of the following actions, as appropriate in the circumstances: (a) Temporarily withhold cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency. (b) Disallow (that is, deny both use of funds and any applicable matching credit for) all or part of the cost of the activity or action not in compliance. (c) Wholly or partly suspend or terminate the Federal award. (d) Initiate suspension or debarment proceedings as authorized under 2 CFR Part 180 and Federal awarding agency regulations (or in the case of a pass-through entity, recommend such a proceeding be initiated by a Federal awarding agency). (e) Withhold further Federal awards for the project or program. (f) Take other remedies that may be legally available. Identification as a repeat finding: No. Recommendation: We recommend the College revise its procedures to include an independent review of reports for accuracy before they are submitted and posted. Views of responsible officials and planned corrective action: Management concurs with the finding. See Exhibit I.