Finding Text
Criteria
Per OMB guidance and contractual terms, the non-federal entity (the "Organization") is
required to conduct criminal background checks and maintain related policies, procedures
and personnel files consistent with the requirements of RCW 43.43 and WAC 246-341.
Condition
The Organization was not able to produce evidence that background checks in accordance
with the criteria described above were conducted in certain instances in relation to personnel
involved in carrying out the activities of the federal program.
Context
Per our testing of the internal controls surrounding the direct and material compliance
requirements in relation to payroll and human resource policies and processes in
conjunction with the delivery of goods and service associated with the Federal program,
there was insufficient documentation supporting whether background checks were
completed for certain employees.
Cause
Background checks were either not completed, or the entity's record keeping was not
sufficient to provide evidence that background checks had been completed appropriately.
Effect
The Organization would possibly employ and assign duties in performing services under
the federal program with individuals that potentially may have had a criminal record, which
is in violation of the contract.
Auditor's Recommendations
The Organization should ensure human resource policies and procedures are sufficient and
in compliance with all applicable laws, regulations and compliance requirements of
contracts.