2022-001 Allowable Cost Federal agency: U.S. Department of Labor Federal program title: H1-B Job Training Grants CFDA Number: 17.268 Award Period: March 1, 2020 ? February 29, 2024 - Significant Deficiency in Internal Control over Compliance - Other Matters Citeria: Uniform Grant Guidance requires compliance with the provisions of internal controls. 2 CFR Part 200.303 states that recipients of federal funds are required to establish and maintain effective internal control over the Federal awards to provide reasonable assurance that the recipient of Federal funds is in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Argentum should have internal controls designed and effectively operating to ensure compliance with those provisions. Argentum?s review and approval of employee time spent and allocation to the Federal program as an allowable cost by supervisors should be consistently performed and documented as required under 2 CFR. Condition: There was no evidence of review and approval of employee time spent and allocation to the federal program for 2 of the 6 transactions selected for testing. Questioned Costs None. Cause: Increased risk of intentional and unintentional misstatements in the normal course of business. Effect: Support for payroll and the allocation of payroll charges is reviewed and approved by supervisors to identify potential misstatements on a timely basis. Repeat Finding: Yes Recommendation: We recommend that Argentum establish policies and procedures to support a system of internal control that requires the review and approval of employee time spent on a timely basis to ensure charges made to Federal awards for salaries and benefits are accurate, allowable, and properly allocated. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding
2022-002 Suspension and Debarment Federal agency: U.S. Department of Labor Federal program title: H1-B Job Training Grants CFDA Number: 17.268 Award Period: March 1, 2020 - February 29, 2024 - Significant Deficiency in Internal Control over Compliance - Other Matters Critiriea: 2 CFR Part 180.220, states that recipients of federal funds are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria. Condition: Argentum did not obtain suspension and debarment certification or check the System for Award Management website before entering into a transaction for 5 of 5 covered transactions tested. Question costs: None. Cause: Adequate procedures were not in place to verify if covered transactions with Argentum related to the federal program in excess of the threshold are not suspended, debarred, or otherwise excluded from doing business. Effect: Noncompliance with the federal award program's suspension and debarment compliance requirements could occur and not be detected and corrected timely. Repeat Finding: Yes Recommendation: Procedures must be implemented to ensure all covered transactions with Argentum have not been suspended or debarred or otherwise excluded from doing business, prior to procuring their services. In order to verify this, program management should either obtain debarment certifications from covered contractors or check the System for Award Management website. Procedures must also be implemented to maintain documentation supporting the debarment and suspension checks are performed. View of responsible officials of the auditee: There is no disagreement with the audit finding.
2022-003 Reporting Federal agency: U.S. Department of Labor Federal program title: H1-B Job Training Grants CFDA Number: 17.268 Award Period: March 1, 2020 - February 29, 2024 - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria: Uniform Grant Guidance requires compliance with the provisions of internal controls. 2 CFR Part 200.303 states that recipients of Federal funds are required to establish and maintain effective internal control over the Federal awards to provide reasonable assurance that the recipient of Federal funds is in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Argentum should have internal controls designed and effectively operating to ensure compliance with those provisions. Condition: Argentum was not able to produce audit evidence of the review and approval of its quarterly financial and performance reports. Two out of four quarterly financial reports and four out of four quarterly performance reports did not have adequate evidence to show the reports were reviewed and approved. In addition, two out of the four quarterly filings of financial and performance reports were made after the 45-day required filing period. Questioned Costs: None. Cause: Argentum does not have adequate policies and procedures in place to ensure timely and adequate review and approval of the quarterly financial and performance reports. Effect: The lack of effective internal controls over reporting compliance requirements provides an opportunity for noncompliance. Repeat Finding: Yes Recommendation: We recommend that Argentum update its policies and procedures to ensure adequate review and approval over quarterly financial reports. Procedures must also be implemented to maintain documentation supporting such procedures and submit the required report in timely manner. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.
2022-001 Allowable Cost Federal agency: U.S. Department of Labor Federal program title: H1-B Job Training Grants CFDA Number: 17.268 Award Period: March 1, 2020 ? February 29, 2024 - Significant Deficiency in Internal Control over Compliance - Other Matters Citeria: Uniform Grant Guidance requires compliance with the provisions of internal controls. 2 CFR Part 200.303 states that recipients of federal funds are required to establish and maintain effective internal control over the Federal awards to provide reasonable assurance that the recipient of Federal funds is in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Argentum should have internal controls designed and effectively operating to ensure compliance with those provisions. Argentum?s review and approval of employee time spent and allocation to the Federal program as an allowable cost by supervisors should be consistently performed and documented as required under 2 CFR. Condition: There was no evidence of review and approval of employee time spent and allocation to the federal program for 2 of the 6 transactions selected for testing. Questioned Costs None. Cause: Increased risk of intentional and unintentional misstatements in the normal course of business. Effect: Support for payroll and the allocation of payroll charges is reviewed and approved by supervisors to identify potential misstatements on a timely basis. Repeat Finding: Yes Recommendation: We recommend that Argentum establish policies and procedures to support a system of internal control that requires the review and approval of employee time spent on a timely basis to ensure charges made to Federal awards for salaries and benefits are accurate, allowable, and properly allocated. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding
2022-002 Suspension and Debarment Federal agency: U.S. Department of Labor Federal program title: H1-B Job Training Grants CFDA Number: 17.268 Award Period: March 1, 2020 - February 29, 2024 - Significant Deficiency in Internal Control over Compliance - Other Matters Critiriea: 2 CFR Part 180.220, states that recipients of federal funds are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria. Condition: Argentum did not obtain suspension and debarment certification or check the System for Award Management website before entering into a transaction for 5 of 5 covered transactions tested. Question costs: None. Cause: Adequate procedures were not in place to verify if covered transactions with Argentum related to the federal program in excess of the threshold are not suspended, debarred, or otherwise excluded from doing business. Effect: Noncompliance with the federal award program's suspension and debarment compliance requirements could occur and not be detected and corrected timely. Repeat Finding: Yes Recommendation: Procedures must be implemented to ensure all covered transactions with Argentum have not been suspended or debarred or otherwise excluded from doing business, prior to procuring their services. In order to verify this, program management should either obtain debarment certifications from covered contractors or check the System for Award Management website. Procedures must also be implemented to maintain documentation supporting the debarment and suspension checks are performed. View of responsible officials of the auditee: There is no disagreement with the audit finding.
2022-003 Reporting Federal agency: U.S. Department of Labor Federal program title: H1-B Job Training Grants CFDA Number: 17.268 Award Period: March 1, 2020 - February 29, 2024 - Significant Deficiency in Internal Control over Compliance - Other Matters Criteria: Uniform Grant Guidance requires compliance with the provisions of internal controls. 2 CFR Part 200.303 states that recipients of Federal funds are required to establish and maintain effective internal control over the Federal awards to provide reasonable assurance that the recipient of Federal funds is in compliance with Federal statutes, regulations and the terms and conditions of the Federal award. Argentum should have internal controls designed and effectively operating to ensure compliance with those provisions. Condition: Argentum was not able to produce audit evidence of the review and approval of its quarterly financial and performance reports. Two out of four quarterly financial reports and four out of four quarterly performance reports did not have adequate evidence to show the reports were reviewed and approved. In addition, two out of the four quarterly filings of financial and performance reports were made after the 45-day required filing period. Questioned Costs: None. Cause: Argentum does not have adequate policies and procedures in place to ensure timely and adequate review and approval of the quarterly financial and performance reports. Effect: The lack of effective internal controls over reporting compliance requirements provides an opportunity for noncompliance. Repeat Finding: Yes Recommendation: We recommend that Argentum update its policies and procedures to ensure adequate review and approval over quarterly financial reports. Procedures must also be implemented to maintain documentation supporting such procedures and submit the required report in timely manner. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.