Finding 498815 (2023-002)

Significant Deficiency Repeat Finding
Requirement
I
Questioned Costs
-
Year
2023
Accepted
2024-09-27
Audit: 321537
Organization: Argentum (VA)

AI Summary

  • Core Issue: Argentum failed to verify suspension and debarment status for one of five transactions, risking noncompliance with federal requirements.
  • Impacted Requirements: Internal controls under Uniform Grant Guidance (2 CFR Part 200.303) were not effectively established or maintained.
  • Recommended Follow-Up: Implement and document procedures to verify debarment status for all transactions before procurement, using either certifications or the System for Award Management website.

Finding Text

2023-002 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 Criteria: Uniform Grant Guidance requires compliance with the provisions of internal controls. 2 CFR Part 200.303 states that recipients of Federal funds are required to establish and maintain effective internal control over the Federal awards to provide reasonable assurance that the recipient of Federal funds is following Federal statutes, regulations and the terms and conditions of the Federal award. Argentum should have internal controls designed and effectively operating to ensure compliance with those provisions. Condition: Argentum did not properly obtain suspension and debarment certification or check the System for Award Management website before entering into a transaction for 1 of 5 covered transactions tested. Questioned 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: Proper procedures must be implemented and documented 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 in a timely manner. Views of Responsible Officials of the Auditee: There is no disagreement with the audit finding.

Corrective Action Plan

FINDINGS—FINANCIAL STATEMENT AUDIT MATERIAL WEAKNESS 2023‐001 Financial Reporting Recommendation: A thorough review of significant account reconciliations should be performed and an understanding of asset capitalization requirements under generally accepted accounting principles should be obtained. We recommend that Argentum develop and implement a thorough review process to ensure proper financial reporting. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: Argentum reviews the financial statements monthly with the President & CEO, outsourced accounting team and senior management team. As part of that process, we review any assets to be capitalized each month to ensure proper recording. Name(s) of the contact person(s) responsible for corrective action: James Balda Planned completion date for corrective action plan: 09/30/2024

Categories

Procurement, Suspension & Debarment Significant Deficiency

Other Findings in this Audit

  • 1075257 2023-002
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
17.268 H-1b Job Training Grants $1.92M