Finding 1213905 (2025-002)

Material Weakness Repeat Finding
Requirement
I
Questioned Costs
-
Year
2025
Accepted
2026-05-06

AI Summary

  • Core Issue: A significant deficiency was found in the internal controls regarding suspension and debarment checks for vendors.
  • Impacted Requirements: Compliance with 2 CFR section 180.9995 requires verification that vendors are not suspended or debarred for each new procurement.
  • Recommended Follow-Up: Enhance controls to ensure suspension and debarment checks are conducted for every new federal procurement, rather than relying on past checks.

Finding Text

Federal Agency: Department of Labor Federal Program: Apprenticeship USA Grants Assistance Listing Number: 17.285 Federal Award Identification Number and Year: 24A60AP000103 - 2024 Award Period: 07/01/2024 – 06/30/2028 Compliance Requirement Affected: Suspension and Debarment Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matter Criteria or specific requirement: When a non-federal entity enters into a covered transaction with an entity at a lower tier, the non-federal entity must verify that the entity, as defined in 2 CFR section 180.9995 and agency adopting regulations, is not suspended or debarred or otherwise excluded from participating in the transaction. Condition: Verification that vendor was not suspended or debarred was performed in a prior year for the vendor, relating to a separate procurement. Suspension and debarment procedures should be performed with each new procurement and only rely on a suspension and debarment check for a reasonable amount of time. Questioned costs: None. Context: Noncompliance identified in 1 of 4 selections tested. Entire population was tested. Vendor was not suspended/debarred. Cause: Reliance on suspension and debarment check performed in March 2023 for a procurement made in June 2025. Effect: Potential noncompliance and increased risk. Repeat finding: No Recommendation: We recommend the Organization improve controls/processes around suspension and debarment to ensure a check is performed with each new federal procurement. View of responsible officials: No disagreement noted.

Corrective Action Plan

Department of Labor – Apprenticeship USA Grants Assistance Listing No. 17.285 Recommendation: We recommend the Organization improve controls/processes around suspension and debarment to ensure a check is performed with each new federal procurement. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Management has implemented policies and procedures to ensure reporting is timely completed. These procedures include a monthly review of pending new contracts and vendors by both program and fiscal personnel. In addition, suspension and debarment language has been added to new contracts

Categories

Procurement, Suspension & Debarment

Other Findings in this Audit

  • 1213904 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.336 TEACHER QUALITY PARTNERSHIP GRANTS $1.01M
17.285 REGISTERED APPRENTICESHIP $972,366
84.116 FUND FOR THE IMPROVEMENT OF POSTSECONDARY EDUCATION $793,836