Finding 1154136 (2024-003)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
$1
Year
2024
Accepted
2025-09-23

AI Summary

  • Core Issue: Lack of documentation for procurement decisions related to Apprenticeship State Funds.
  • Impacted Requirements: Non-compliance with 2 CFR section 200.318, which mandates detailed records for procurement transactions.
  • Recommended Follow-Up: AACC should establish a policy to ensure proper documentation of all procurement activities.

Finding Text

Finding 2024-003 Agency: Department of Labor Program: Apprenticeship State Funds (AL No. 17.285) Material Weakness over Procurement Repeat Finding: No Condition: For all procurements related to the Apprenticeship State Funds, there was no documentation provided to support the rationale for the procurement method, contract type selection, contractor selection, or the basis for the contract price prior to the signing of the contract. Criteria: As provided in 2 CFR section 200.318: General procurement standards, the recipient or subrecipient must maintain records sufficient to detail the history of each procurement transaction. These records must include the rationale for the procurement method, contract type selection, contractor selection or rejection, and the basis for the contract price. Cause: AACC does not have a policy in place to properly document Apprenticeship State Funds procurement transactions. Effect: AACC was not in compliance with the Procurement requirements in accordance with Uniform Guidance. Questioned Costs: Unknown Recommendation: We recommend AACC implements a policy to properly document their procurements for the Apprenticeship State Funds. Auditee Response and Corrective Action Plan: Management agrees with the finding. Refer to the corrective action plan on current findings in Part V of this report.

Corrective Action Plan

To address this finding, AACC will adhere to the financial policies and procedures properly documenting procurement decisions for goods and services with a total cost of $25,000 or greater. (Financial Policies and Procedures, pages 25, 45). In the event of “Sole Service Providers”, staff will document the circumstances as such for recording. Effective immediately, all projects will be reviewed by a team assembled within the association, (Staffing to be determined by the President/CEO). A staff member, housed in the President’s Office with research and using a scorecard, assess and present potential opportunities to the President/CEO for approval to proceed. Approved opportunities will be reviewed by the team along with the department head making the request. There will be a collaborative effort of the scope of the project along with the budget necessary to implement the project. All parties will sign-off on their respective steps prior to the full package being presented to the President/Chief Executive Officer for final approval. A checklist will be used to monitor the process. All vendors written into the agreement will be vetted through a process that will include the rationale for their selection.

Categories

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring Material Weakness

Other Findings in this Audit

  • 1154131 2024-005
    Material Weakness Repeat
  • 1154132 2024-005
    Material Weakness Repeat
  • 1154133 2024-005
    Material Weakness Repeat
  • 1154134 2024-001
    Material Weakness Repeat
  • 1154135 2024-002
    Material Weakness Repeat
  • 1154137 2024-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
17.285 Apprenticeship USA Grants $1.33M
47.076 Education and Human Resources $108,736
11.307 Economic Adjustment Assistance $12,860
17.268 H-1b Job Training Grants $7,283
23.002 Appalachian Area Development $6,859