Finding 1103190 (2024-004)

Department of Labor Federal Financial Assistance Listing #17.270, YF-38599-22-60-A-19, 7/1/2023 – 6/30/2024 Reentry Employment Opportunities Procurement, Suspension & Debarment Material Weakness in Internal Control over Compliance and Noncompliance Criteria: 2 CFR 200.303(a) states that the auditee must establish and maintain effective internal control over the federal award that provides assurance that the entity is managing the federal award in compliance with federal statutes, regulations, and the terms and conditions of the federal award. 2 CFR 200.318 maintains that recipients must have and use documented procurement policies and must conform to procurement standards in sections 200.317 through 200.327. As outlined in 2 CFR 180, recipients must not utilize any vendor which is suspended or debarred or is otherwise excluded from the central contractor registry. Condition: The organization’s procurement policy did not contain all of the required procurement standards and contract provisions as required by Uniform Guidance. The organization entered into a covered transaction with a vendor before performing a review to ensure the vendor was not suspended or debarred. Cause: The Organization was unaware of the missing items from the procurement standards and contract provisions. The Organization did not follow their formal procurement policy prior to entering into a covered transaction with a vendor to ensure that vendor was not suspended or debarred. Effect: Lack of compliance with established internal control procedures may result in noncompliance with the program. Questioned Costs: None reported. Context: There was one contract subject to procurement, suspension and debarment during the year which was tested. The vendor was not included on the suspended or debarred list. Repeat Finding from Prior Year: No Recommendation: We recommend management review their procedures over procurement, suspension and debarment to ensure they align with Uniform Guidance requirements. The procedures should also be reviewed with those individuals charged with entering into contracts to ensure a complete understanding of all federal requirements. Views of Responsible Officials: Management is in agreement.