Condition: Controls in place did not ensure a foreign national employee's involvement on a project were communicated to the Contracts Manager for tracking.
Planned Corrective Action: Management takes its responsibility to comply with the terms and conditions of awards seriously, and, while this part...
Condition: Controls in place did not ensure a foreign national employee's involvement on a project were communicated to the Contracts Manager for tracking.
Planned Corrective Action: Management takes its responsibility to comply with the terms and conditions of awards seriously, and, while this particular finding did not result in noncompliance with the terms of an award, a repeat occurrence could result in noncompliance. To prevent future occurrences, management will enhance internal controls to ensure consistent tracking and reporting of foreign nationals working on Department of Energy sponsored projects by taking the following corrective actions by July 31, 2025:
1) Update the company’s policy for tracking and reporting foreign nationals to include:
a) A requirement that all team members must be approved by Contract Services before starting work on a DOE project.
b) A requirement that Contract Services review a payroll report monthly to ensure all individuals who charged time to DOE projects were pre-approved.
2) Train business unit leaders, project managers, and contract services staff on the revised policy and procedures for tracking and reporting foreign nationals.
Contact person responsible for corrective action: Prerna Russell
Anticipated Completion Date: 07/31/2025