Finding 21320 (2022-002)

2022-002 Suspension and Debarment Federal agency: U.S. Department of Labor Federal program title: H1-B Job Training Grants CFDA Number: 17.268 Award Period: March 1, 2020 - February 29, 2024 - Significant Deficiency in Internal Control over Compliance - Other Matters Critiriea: 2 CFR Part 180.220, states that recipients of federal funds are prohibited from contracting with or making sub awards under covered transactions to parties that are suspended or debarred. ?Covered transactions? include those procurement contracts for goods and services awarded under a nonprocurement transaction (e.g., grant or cooperative agreement) that are expected to equal or exceed $25,000 or meet certain other criteria. Condition: Argentum did not obtain suspension and debarment certification or check the System for Award Management website before entering into a transaction for 5 of 5 covered transactions tested. Question costs: None. Cause: Adequate procedures were not in place to verify if covered transactions with Argentum related to the federal program in excess of the threshold are not suspended, debarred, or otherwise excluded from doing business. Effect: Noncompliance with the federal award program's suspension and debarment compliance requirements could occur and not be detected and corrected timely. Repeat Finding: Yes Recommendation: Procedures must be implemented to ensure all covered transactions with Argentum have not been suspended or debarred or otherwise excluded from doing business, prior to procuring their services. In order to verify this, program management should either obtain debarment certifications from covered contractors or check the System for Award Management website. Procedures must also be implemented to maintain documentation supporting the debarment and suspension checks are performed. View of responsible officials of the auditee: There is no disagreement with the audit finding.