Finding Text
Federal Agency: U.S. Department of Labor Federal Program Title: Reintegration of Ex-Offenders Assistance Listing No. 17.270 Award Periods: 2024 Type of Finding: • Material Weakness in Internal Control Over Compliance – Suspension and Debarment • Other Matter Questioned Costs: None Condition: During our testing of 5 suspension and debarment samples, CLA noted no documentation was maintained related to verifying vendors were not suspended or debared for any of the 5 samples (100%). The statement of work outlines use of all of these vendors, but inclusion in the description in the statement of work of entities does not preclude the requirement to test for suspension and debarment issues. Though verification was done at the time of the audit, no support could be provided to show the control took place prior to use of the vendor. Criteria: Uniform Grant Guidance (200.214) states the non-Federal entity is subject to the debarment and suspension regulations as 2 CFR part 180, requiring no federal funds be awarded to parties that are suspended, debarred, or otherwise excluded from federal programs. Context: The Organization did not maintain adequate documentation related to verification that vendors were not suspension and debarment prior to use of such vendor. Cause: The Organization did not have effective internal controls over compliance in place to ensure documentation of suspension and debarment procedures were followed prior to use of the vendor. Effect: Failure to properly approve contractors and maintain documentation may result in in federal funds being charged to the grant for activities related to suspended or debarred vendors. Recommendation: The Organization should strengthen controls and adherence over their policy and the UG and DOL guidelines and ensure a control is in place for verifying vendors are not suspended, debarred, or otherwise excluded per UG guidelines prior to use of the vendor. The Organization should ensure these policies are followed for all applicable vendors and that documentation related to these controls are maintained and documented. Views of Responsible Officials: There is no disagreement with the audit finding.