Finding - The District did not always maintain required documentation to support the adjustments to the high school cohort graduation rate.
Criteria - Title 20, Section 7801(25), United States Code, requires that the District maintain appropriate documentation to support the removal of a student’s count from the 4‑year cohort (defined as a group of students on the same schedule to graduate) used to calculate the high school graduation rate. To remove a student’s count from the cohort, the District must confirm, in writing, that the student transferred from the District, emigrated to another country, transferred to a prison or juvenile facility, or is deceased.
Additionally, a student who is retained in the same grade, enrolls in a General Educational Development (GED) Program, or leaves school for any other reason may not be counted as having transferred from the District for the purpose of calculating the graduation rate and must remain in the cohort. To confirm that a student transferred out, official documentation must be obtained from the receiving school or program that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma.
Condition - To determine whether the District maintained appropriate documentation to support the removal of 2,781 students from the 2022‑23 fiscal year cohort graduation rate, we requested District records to support 30 selected students who were removed from the cohort. Our review disclosed that District records did not comply with the Federal documentation requirements for the removal of 5 students from the cohort. Specifically, the District provided withdrawal forms for 5 students that typically indicated the students’ intentions at the time of withdrawal; however, although we requested, documentation was not provided to evidence that the students eventually enrolled in another school or program.
Cause - District personnel indicated that school personnel misunderstood some of the requirements to remove students from the cohort and did not adequately document student withdrawals. In addition, monitoring procedures were not performed to ensure that appropriate records were maintained and that all students removed from the cohort graduation rate were removed for reasons allowed by Federal regulations.
Effect - While the noncompliance was the result of a significant deficiency, the noncompliance does not have a direct impact on funding. Notwithstanding, without appropriate documentation supporting adjustments to the 4-year cohort and related graduation rate calculation, the District cannot demonstrate that the calculation was accurate, limiting the usefulness of the graduation rate as an academic indicator.
Recommendation - The District should enhance procedures to ensure that documentation supporting adjustments to the 4-year cohort and related graduation rate calculation is obtained before adjustments are made. Such enhancements should include appropriate training and monitoring to ensure that the required documentation is maintained and supports that all students removed from the cohort graduation rate were removed for the reasons allowed by Federal regulations.
District Response - The district will develop procedures to ensure that the proper withdraw codes are utilized and that proper documentation is maintained.
Finding - District controls did not always ensure compliance with the Davis-Bacon Act for Federally funded construction projects exceeding $2,000, resulting in questioned costs totaling $433,295.
Criteria - The ES Fund provides Federal funds for school facility repairs and improvements to reduce the risk of virus transmission and exposure to environmental health hazards, and to support student health needs.
Title 29, Section 5.5, Code of Federal Regulations (Davis-Bacon Act), requires the District to include prevailing wage rate clauses in any construction contract exceeding $2,000 that is financed either wholly or in part by Federal funds and ensure that contractors pay workers the prevailing wage rates established by the United States Department of Labor. This includes a requirement for the contractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). The United States Department of Labor established “prevailing wages” by geographic area and interprets the Davis-Bacon Act to apply to construction, alteration, or repair of public buildings or public work.
Condition - During the 2022-23 fiscal year, the District expended $53,667,312 from the ES Fund. The expenditures included $438,019 for projects related to seven construction contracts totaling $961,711 for heating, ventilation, and air-conditioning renovation, playground installation, and playground fence installation. While the contracts included a general requirement to comply with the Davis-Bacon Act provisions, the contracts did not explicitly require, and the contractors did not submit, weekly certified payrolls to the District demonstrating prevailing wage rates were paid.
Subsequent to our inquiry, District personnel obtained certified payrolls for two contracts for playground fence installation totaling $4,724, demonstrating that prevailing wage rates were paid for these projects.
Cause - Construction contracts did not specifically require contractors to submit to the District weekly payrolls and District personnel relied upon contractors to ensure wage rates paid by contractors were in compliance with Davis-Bacon Act.
Effect - Absent specific contract clauses and weekly certified payrolls, there is an increased risk that construction contractors paid with Federal moneys will not pay workers the prevailing wage rates established by the United States Department of Labor. Although we requested, the District did not provide from certain contractors certified payrolls demonstrating that the prevailing wage rates were paid. Consequently, the $433,295 (i.e., $438,019 expended by the District from the ES Fund minus $4,724 supported by certified payrolls) are questioned costs.
Recommendation - The District should enhance procedures to ensure compliance with all Davis-Bacon Act requirements. Such procedures should ensure that applicable Federally funded construction contracts require submittal of weekly certified payrolls and that District personnel verify that the payrolls were received and demonstrated that prevailing wage rates were paid. In addition, the District should document to the FDOE the allowability of the questioned costs or contact the FDOE regarding necessary corrective action.
District Response - The District's procedures will be enhanced to ensure compliance with the Davis-Bacon Act prevailing wage requirements. The District is currently working with the contractors to obtain the required documents to be in compliance with the Davis-Bacon Act.
Finding - District controls did not always ensure compliance with the Davis-Bacon Act for Federally funded construction projects exceeding $2,000, resulting in questioned costs totaling $433,295.
Criteria - The ES Fund provides Federal funds for school facility repairs and improvements to reduce the risk of virus transmission and exposure to environmental health hazards, and to support student health needs.
Title 29, Section 5.5, Code of Federal Regulations (Davis-Bacon Act), requires the District to include prevailing wage rate clauses in any construction contract exceeding $2,000 that is financed either wholly or in part by Federal funds and ensure that contractors pay workers the prevailing wage rates established by the United States Department of Labor. This includes a requirement for the contractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). The United States Department of Labor established “prevailing wages” by geographic area and interprets the Davis-Bacon Act to apply to construction, alteration, or repair of public buildings or public work.
Condition - During the 2022-23 fiscal year, the District expended $53,667,312 from the ES Fund. The expenditures included $438,019 for projects related to seven construction contracts totaling $961,711 for heating, ventilation, and air-conditioning renovation, playground installation, and playground fence installation. While the contracts included a general requirement to comply with the Davis-Bacon Act provisions, the contracts did not explicitly require, and the contractors did not submit, weekly certified payrolls to the District demonstrating prevailing wage rates were paid.
Subsequent to our inquiry, District personnel obtained certified payrolls for two contracts for playground fence installation totaling $4,724, demonstrating that prevailing wage rates were paid for these projects.
Cause - Construction contracts did not specifically require contractors to submit to the District weekly payrolls and District personnel relied upon contractors to ensure wage rates paid by contractors were in compliance with Davis-Bacon Act.
Effect - Absent specific contract clauses and weekly certified payrolls, there is an increased risk that construction contractors paid with Federal moneys will not pay workers the prevailing wage rates established by the United States Department of Labor. Although we requested, the District did not provide from certain contractors certified payrolls demonstrating that the prevailing wage rates were paid. Consequently, the $433,295 (i.e., $438,019 expended by the District from the ES Fund minus $4,724 supported by certified payrolls) are questioned costs.
Recommendation - The District should enhance procedures to ensure compliance with all Davis-Bacon Act requirements. Such procedures should ensure that applicable Federally funded construction contracts require submittal of weekly certified payrolls and that District personnel verify that the payrolls were received and demonstrated that prevailing wage rates were paid. In addition, the District should document to the FDOE the allowability of the questioned costs or contact the FDOE regarding necessary corrective action.
District Response - The District's procedures will be enhanced to ensure compliance with the Davis-Bacon Act prevailing wage requirements. The District is currently working with the contractors to obtain the required documents to be in compliance with the Davis-Bacon Act.
Finding - The District did not always maintain required documentation to support the adjustments to the high school cohort graduation rate.
Criteria - Title 20, Section 7801(25), United States Code, requires that the District maintain appropriate documentation to support the removal of a student’s count from the 4‑year cohort (defined as a group of students on the same schedule to graduate) used to calculate the high school graduation rate. To remove a student’s count from the cohort, the District must confirm, in writing, that the student transferred from the District, emigrated to another country, transferred to a prison or juvenile facility, or is deceased.
Additionally, a student who is retained in the same grade, enrolls in a General Educational Development (GED) Program, or leaves school for any other reason may not be counted as having transferred from the District for the purpose of calculating the graduation rate and must remain in the cohort. To confirm that a student transferred out, official documentation must be obtained from the receiving school or program that the student enrolled in another school or in an educational program that culminates in the award of a regular high school diploma.
Condition - To determine whether the District maintained appropriate documentation to support the removal of 2,781 students from the 2022‑23 fiscal year cohort graduation rate, we requested District records to support 30 selected students who were removed from the cohort. Our review disclosed that District records did not comply with the Federal documentation requirements for the removal of 5 students from the cohort. Specifically, the District provided withdrawal forms for 5 students that typically indicated the students’ intentions at the time of withdrawal; however, although we requested, documentation was not provided to evidence that the students eventually enrolled in another school or program.
Cause - District personnel indicated that school personnel misunderstood some of the requirements to remove students from the cohort and did not adequately document student withdrawals. In addition, monitoring procedures were not performed to ensure that appropriate records were maintained and that all students removed from the cohort graduation rate were removed for reasons allowed by Federal regulations.
Effect - While the noncompliance was the result of a significant deficiency, the noncompliance does not have a direct impact on funding. Notwithstanding, without appropriate documentation supporting adjustments to the 4-year cohort and related graduation rate calculation, the District cannot demonstrate that the calculation was accurate, limiting the usefulness of the graduation rate as an academic indicator.
Recommendation - The District should enhance procedures to ensure that documentation supporting adjustments to the 4-year cohort and related graduation rate calculation is obtained before adjustments are made. Such enhancements should include appropriate training and monitoring to ensure that the required documentation is maintained and supports that all students removed from the cohort graduation rate were removed for the reasons allowed by Federal regulations.
District Response - The district will develop procedures to ensure that the proper withdraw codes are utilized and that proper documentation is maintained.
Finding - District controls did not always ensure compliance with the Davis-Bacon Act for Federally funded construction projects exceeding $2,000, resulting in questioned costs totaling $433,295.
Criteria - The ES Fund provides Federal funds for school facility repairs and improvements to reduce the risk of virus transmission and exposure to environmental health hazards, and to support student health needs.
Title 29, Section 5.5, Code of Federal Regulations (Davis-Bacon Act), requires the District to include prevailing wage rate clauses in any construction contract exceeding $2,000 that is financed either wholly or in part by Federal funds and ensure that contractors pay workers the prevailing wage rates established by the United States Department of Labor. This includes a requirement for the contractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). The United States Department of Labor established “prevailing wages” by geographic area and interprets the Davis-Bacon Act to apply to construction, alteration, or repair of public buildings or public work.
Condition - During the 2022-23 fiscal year, the District expended $53,667,312 from the ES Fund. The expenditures included $438,019 for projects related to seven construction contracts totaling $961,711 for heating, ventilation, and air-conditioning renovation, playground installation, and playground fence installation. While the contracts included a general requirement to comply with the Davis-Bacon Act provisions, the contracts did not explicitly require, and the contractors did not submit, weekly certified payrolls to the District demonstrating prevailing wage rates were paid.
Subsequent to our inquiry, District personnel obtained certified payrolls for two contracts for playground fence installation totaling $4,724, demonstrating that prevailing wage rates were paid for these projects.
Cause - Construction contracts did not specifically require contractors to submit to the District weekly payrolls and District personnel relied upon contractors to ensure wage rates paid by contractors were in compliance with Davis-Bacon Act.
Effect - Absent specific contract clauses and weekly certified payrolls, there is an increased risk that construction contractors paid with Federal moneys will not pay workers the prevailing wage rates established by the United States Department of Labor. Although we requested, the District did not provide from certain contractors certified payrolls demonstrating that the prevailing wage rates were paid. Consequently, the $433,295 (i.e., $438,019 expended by the District from the ES Fund minus $4,724 supported by certified payrolls) are questioned costs.
Recommendation - The District should enhance procedures to ensure compliance with all Davis-Bacon Act requirements. Such procedures should ensure that applicable Federally funded construction contracts require submittal of weekly certified payrolls and that District personnel verify that the payrolls were received and demonstrated that prevailing wage rates were paid. In addition, the District should document to the FDOE the allowability of the questioned costs or contact the FDOE regarding necessary corrective action.
District Response - The District's procedures will be enhanced to ensure compliance with the Davis-Bacon Act prevailing wage requirements. The District is currently working with the contractors to obtain the required documents to be in compliance with the Davis-Bacon Act.
Finding - District controls did not always ensure compliance with the Davis-Bacon Act for Federally funded construction projects exceeding $2,000, resulting in questioned costs totaling $433,295.
Criteria - The ES Fund provides Federal funds for school facility repairs and improvements to reduce the risk of virus transmission and exposure to environmental health hazards, and to support student health needs.
Title 29, Section 5.5, Code of Federal Regulations (Davis-Bacon Act), requires the District to include prevailing wage rate clauses in any construction contract exceeding $2,000 that is financed either wholly or in part by Federal funds and ensure that contractors pay workers the prevailing wage rates established by the United States Department of Labor. This includes a requirement for the contractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). The United States Department of Labor established “prevailing wages” by geographic area and interprets the Davis-Bacon Act to apply to construction, alteration, or repair of public buildings or public work.
Condition - During the 2022-23 fiscal year, the District expended $53,667,312 from the ES Fund. The expenditures included $438,019 for projects related to seven construction contracts totaling $961,711 for heating, ventilation, and air-conditioning renovation, playground installation, and playground fence installation. While the contracts included a general requirement to comply with the Davis-Bacon Act provisions, the contracts did not explicitly require, and the contractors did not submit, weekly certified payrolls to the District demonstrating prevailing wage rates were paid.
Subsequent to our inquiry, District personnel obtained certified payrolls for two contracts for playground fence installation totaling $4,724, demonstrating that prevailing wage rates were paid for these projects.
Cause - Construction contracts did not specifically require contractors to submit to the District weekly payrolls and District personnel relied upon contractors to ensure wage rates paid by contractors were in compliance with Davis-Bacon Act.
Effect - Absent specific contract clauses and weekly certified payrolls, there is an increased risk that construction contractors paid with Federal moneys will not pay workers the prevailing wage rates established by the United States Department of Labor. Although we requested, the District did not provide from certain contractors certified payrolls demonstrating that the prevailing wage rates were paid. Consequently, the $433,295 (i.e., $438,019 expended by the District from the ES Fund minus $4,724 supported by certified payrolls) are questioned costs.
Recommendation - The District should enhance procedures to ensure compliance with all Davis-Bacon Act requirements. Such procedures should ensure that applicable Federally funded construction contracts require submittal of weekly certified payrolls and that District personnel verify that the payrolls were received and demonstrated that prevailing wage rates were paid. In addition, the District should document to the FDOE the allowability of the questioned costs or contact the FDOE regarding necessary corrective action.
District Response - The District's procedures will be enhanced to ensure compliance with the Davis-Bacon Act prevailing wage requirements. The District is currently working with the contractors to obtain the required documents to be in compliance with the Davis-Bacon Act.