Finding Text
Criteria and Condition: FOA-ETA-22-06, Apprenticeship Building America (ABA) Grant Program states “individuals served must be at least 16 years of age who are not already enrolled in a RAP at the time of initial grant service”. Training and Employment Guidance Letter 23-19, Guidance for Validating Required Performance Data Submitted by Grant Recipients of U.S. Department of Labor (DOL) Workforce Programs allows “Self-Attestation” as source documentation for participant date of birth.
For nine of the forty disbursement samples selected, CareerWise was unable to provide adequate source documentation validating date of birth for the selected items. CareerWise is using selfattestation as source documentation, however the signed agreements attesting to date of birth were not included in the case files. As a result, the auditor was unable to determine whether the eligibility requirements for these sample selections were met under the ABA grant.
Cause: The condition was caused by a lack of internal controls over the ABA grant. Supporting documentation was not maintained for all apprentices. In addition, the New York State Department of Labor, the State Apprenticeship Agency, is backlogged with processing Registered Apprenticeship Program agreements and, as such, has not provided CareerWise with copies of all signed agreements.
Effect: CareerWise could receive federal funding for apprentices that are ineligible.
Context: During testing procedures over ABA eligibility requirements, the auditor was unable to obtain source documents from management for nine of the forty samples. Identification of Repeat Findings: This is not a repeat finding.
Recommendation: CareerWise should develop a consistent process to obtain the required source documentation, incorporate it into the participant case files, and confirm that eligibility documentation is complete for all apprentices. In addition, CareerWise should review all case files associated with this grant to ensure the files have the required eligibility documentation.