Finding 968100 (2022-002)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2024-04-01
Audit: 302106
Auditor: Forvis LLP

AI Summary

  • Core Issue: The Organization failed to monitor compliance with key personnel provisions in federal contracts, leading to noncompliance.
  • Impacted Requirements: The Organization must maintain controls to ensure compliance with contract terms, specifically regarding key personnel changes.
  • Recommended Follow-Up: Implement a review step for key personnel requirements in contracts and establish controls for ongoing compliance monitoring, including timely communication with the Contracting Officer.

Finding Text

Special Tests and Provisions Material Weakness in Internal Control over Compliance and Material Noncompliance Research and Development Cluster Criteria: The Organization is required to maintain controls to ensure compliance with the terms of the contracts and/or grants which it negotiated with the federal government and is required to comply with the terms of the contract or grant agreements. Condition: Two (2) of the four (4) contracts selected for testing contained a key personnel provision in the contract. The key person was not required to work a specified amount of hours, but the Organization was required to inform the Contracting Officer regarding any changes to the key personnel listing. During the period of the contracts with these provisions, the Organization did not have a control structure in place to monitor compliance with these key personnel provisions. Consequently, for one (1) of the contracts that contained a key personnel provision, the identified key person was removed from the contract and not replaced. The Contracting Officer was not informed of this change. Cause: The Organization did not have controls in place to monitor compliance with the key personnel provisions. Effect or potential effect: The Organization did not comply therefore with the provisions of the contract. Questioned costs: None. Context: Our sample was not intended to be statistically valid. Recommendation: The Organization should incorporate a step in their contract review process that identifies any key personnel requirements. The Organization should discuss with the Contracting Officer prior to signing the contract the reasonableness of the provision. Additionally, for any key personnel provisions in contracts negotiated with the federal government, the Organization should ensure that it has controls in place to monitor compliance with these provisions. This control apparatus should include regular review of the Organization’s compliance with these provisions and documented instances of noncompliance should be communicated to the Contracting Officer as soon as practicable. Views of responsible officials and planned corrective actions: Management's response is reported in "Management's Views and Corrective Action Plan" included at the end of this report. Identification of prior year finding: 2021-004

Categories

Special Tests & Provisions Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 391658 2022-002
    Material Weakness Repeat
  • 391659 2022-003
    Material Weakness Repeat
  • 391660 2022-004
    Material Weakness Repeat
  • 968101 2022-003
    Material Weakness Repeat
  • 968102 2022-004
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
12.RD S&t Awareness $3.57M
12.RD Graces Quarters $2.62M
12.RD McKinsey Effort $1.76M
12.RD Ihd - Tech Inst Sbir $1.18M
12.RD Md&i Follow on (option Years) $1.11M
12.RD Xtechsearch $150,804
12.RD Ihd - Stem $135,814
12.RD Ihd - Tech Insight $127,761
12.RD Indian Head Mems $91,821
12.RD Air Force Research Lab $12,305