Finding 32338 (2022-003)

-
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-29

AI Summary

  • Core Issue: The Organization failed to monitor subcontractor performance, relying on an unverified online list instead of proper oversight.
  • Impacted Requirements: This lack of monitoring violates contract terms and federal guidelines requiring oversight of all contracts.
  • Recommended Follow-Up: Provide additional training for staff to improve compliance and ensure proper monitoring of subcontractors.

Finding Text

SECTION 3 ? FEDERAL AWARD FINDINGS AND QUESTIONED COSTS (continued) Finding 2022-003 Monitoring Subcontractors Performance Condition: The Organization did not develop and perform procedures to verify the subcontractor?s adherence to contract terms (provide contract services), condition and contract specifications. The Organization relied on what they considered to be pre-approval Pacific Mountain Development Councils? website as meeting the criteria. The PacMnt contracts do not reference the website, or that placement on the website waives oversite by the grantee. Cause: The Organization?s internal controls were inadequate to perform and document the performance monitoring of the subcontractors. The Pacific Mountain Workforce Development Council provided an on-line ?Eligible Training Provider List? which the Organization accepted and relied upon as a pre-approval that the contracted services required no further monitoring. Criteria: Pacific Mountain Workforce Development Council, Contracts 102-TCC-BS-PY21, 102-TC-PEC-PY21, 102-TCC-CY-BS-PY21: 31.6 Oversite Grantee must maintain oversight over all contracts. This includes, but is not limited to, monitoring contractor performance regarding contract terms, conditions, and specifications. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. Effect: The Organization did not monitor the contactors for adherence to contract terms, condition and specifications. Recommendation: To ensure compliance with governmental grant programs, additional training and education should be obtained by associated staff. Management?s response: Management agrees with the recommendation and have scheduled training for key personnel. Person Responsible: Program Managers

Corrective Action Plan

CORRECTIVE ACTION PLAN Finding 2022-001 Internal Control over Bank Reconciliation and Vendor Invoice Management Response: Management agrees with this recommendation and have taken steps to implement proper review and documentation for bank reconciliations and vendor invoice approvals. Person Responsible: President/CEO, Finance Officer, and Program Managers Finding 2022-02 Debarred and Suspended Vendors Management Response: Management agrees with this recommendation and have taken steps to develop and implement proper internal controls. Person Responsible: Finance Officer and Program Managers Finding 2022-03 Monitoring Subcontractor Performance Management response: Management agrees with the recommendation and have scheduled training for key personnel. Person Responsible: Program Managers Finding 2022-04 Written Approval of Subcontractors Management Response: Management agrees with this recommendation and have scheduled training for key personnel. Person Responsible: President/CEO and Program Managers Finding 2022-005 Indirect Cost Allocation ? Questioned Costs Management Response: Management agrees with the need for additional grant training, especially as it applies to calculating and allocating indirect costs. However, we do have issues with the classification of expenses within the original contract and hope we can reconcile those prior to the finalization of the grant award. Person Responsible: President/CEO Finance Officer

Categories

Internal Control / Segregation of Duties Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
17.277 Workforce Investment Act (wia) National Emergency Grants $424,000
17.258 Wia Adult Program $205,828