Finding Text
Finding 2022-004 Written Approval of Subcontractors Condition: The Organization did not develop and perform procedures to obtain required written approval of the subcontractors they contracted with. Cause: The Organization did not develop and perform procedures to document written approval of subcontractors from the grantor. The Pacific Mountain Workforce Development Council provided an on-line ?Eligible Training Provider List? which the Organization accepted as an authorization that the contracted services would be provided without further written approval. Criteria: Criteria: Pacific Mountain Workforce Development Council, Contracts 102-TCC-BS-PY21, 102-TC-PEC-PY21, 102-TCC-CY-BS-PY21: 36. Subcontracting The Contractor shall not subcontract work or services contemplated under the Contract and/or use an outside consultant except as provided for in the Scope of Work without obtaining the prior written approval of PACMTN for the authority to enter into subcontracts. Contractor acknowledgers that such approve for any subcontract does not relieve the Contractor of its obligations to perform hereunder. PACMTN retains the author to review and approve or disapprove all subcontracts. 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 obtain written authorization to subcontract work as they relied upon the PACMTN on-line ?Eligible Training Provider List? to be such approval. Recommendation: To ensure compliance with governmental grant programs, additional training and education should be obtained by associated staff. Management?s response: Management agrees with this recommendation and have scheduled training for key personnel. Person Responsible: President/CEO and Program Managers