Finding: The District did not always maintain required documentation to support the adjustments to the high school graduation rate cohort. 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 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 55 students from the 2021-22 fiscal year graduation rate cohort, we requested District records to support 20 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: . For 2 students, the District could not provide any documentation to support removal from the cohort. . For 1 student, the District provided parent-signed copies of school withdrawal forms that typically indicated the student?s intentions at the time of withdrawal; however, although we requested, documentation was not provided to evidence that the student eventually enrolled in another school or program. . For 2 students, the District provided parent-signed copies of school withdrawal forms that indicated intentions to transfer to other educational programs, such as GED or technical programs, which did not appear to culminate in the award of a regular high school diploma. 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 graduation rate cohort were removed for reasons allowed by Federal regulations. Effect: 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 graduation rate cohort were removed for the reasons allowed by Federal regulations. District Response: The district has met with the staff responsible for handling withdrawals of students and transfer of their records to different institutions. Formal training is being developed for principals, registrars, and data entry staff about the process for withdrawing a student from school and from a cohort; using the correct withdrawal codes; maintaining proper records; following up with transfer agencies to get the appropriate documentation, and how to ensure that any new staff is provided training related to withdrawals and student records. The district will monitor regularly to ensure established protocols are met and being done correctly.
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 $1,465,428. Criteria: The ESSER 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, CFR (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 a public building or public work. Condition: During the 2021-22 fiscal year, the Board entered into nine construction contracts totaling $1,810,203 with one contractor for heating, ventilation, and air-conditioning (HVAC) repairs and upgrades at five District schools. As of June 30, 2022, the District had expended ESSER funds totaling $1,465,428. In response to our inquiry, District personnel indicated that the contractor did not submit to the District weekly certified payrolls demonstrating prevailing wage rates were paid. In addition, we noted that the purchase orders, requests for proposal, bid specifications, and contracts for the projects did not contain clauses that required compliance with the Davis-Bacon Act provisions. Cause: District personnel were not aware that the Davis-Bacon Act applied to these projects and, therefore, did not include the appropriate wage rate clauses in the applicable procurement documents. In addition, according to District personnel, District procedures did not require them to verify that the contractor submitted weekly certified payrolls demonstrating prevailing wage rates were paid. Effect: Absent the required 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 the certified payrolls from the contractor demonstrating that the prevailing wage rates were paid for the projects. Consequently, the District incurred questioned costs totaling $1,465,428. 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 contain the prevailing wage rate clauses and require submittal of weekly certified payrolls and that District personnel verify the payrolls were received. 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 has met virtually and in person with all staff involved in these transactions and the contractor who facilitated the renovation projects. Discussions with CEOs, attorneys, and others responsible for maintaining payroll records have been held. System of Award Management (SAM) Wage determination documents have been sent to the vendor and the vendor is in the process of revising purchasing agreements/contracts to include language related to Davis-Bacon Act. The vendor has agreed to provide the wage determinations and updated documents as soon as possible. The district will not expend any further federal dollars on construction projects unless there is a completed contract with all the required Davis-Bacon Act clauses and requires the vendor to provide weekly wage statements to the district as they work on the project. The district is working with legal and other larger school districts to develop its own contract document that contains all the required Davis-Bacon language. That document will be used in the future for any federally funded construction projects. The Finance Department will ensure that no contracts are approved without the correct language and requirements in them and will revise the purchasing documents to include references to Davis-Bacon Act.
Finding: The District did not always maintain required documentation to support the adjustments to the high school graduation rate cohort. 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 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 55 students from the 2021-22 fiscal year graduation rate cohort, we requested District records to support 20 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: . For 2 students, the District could not provide any documentation to support removal from the cohort. . For 1 student, the District provided parent-signed copies of school withdrawal forms that typically indicated the student?s intentions at the time of withdrawal; however, although we requested, documentation was not provided to evidence that the student eventually enrolled in another school or program. . For 2 students, the District provided parent-signed copies of school withdrawal forms that indicated intentions to transfer to other educational programs, such as GED or technical programs, which did not appear to culminate in the award of a regular high school diploma. 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 graduation rate cohort were removed for reasons allowed by Federal regulations. Effect: 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 graduation rate cohort were removed for the reasons allowed by Federal regulations. District Response: The district has met with the staff responsible for handling withdrawals of students and transfer of their records to different institutions. Formal training is being developed for principals, registrars, and data entry staff about the process for withdrawing a student from school and from a cohort; using the correct withdrawal codes; maintaining proper records; following up with transfer agencies to get the appropriate documentation, and how to ensure that any new staff is provided training related to withdrawals and student records. The district will monitor regularly to ensure established protocols are met and being done correctly.
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 $1,465,428. Criteria: The ESSER 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, CFR (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 a public building or public work. Condition: During the 2021-22 fiscal year, the Board entered into nine construction contracts totaling $1,810,203 with one contractor for heating, ventilation, and air-conditioning (HVAC) repairs and upgrades at five District schools. As of June 30, 2022, the District had expended ESSER funds totaling $1,465,428. In response to our inquiry, District personnel indicated that the contractor did not submit to the District weekly certified payrolls demonstrating prevailing wage rates were paid. In addition, we noted that the purchase orders, requests for proposal, bid specifications, and contracts for the projects did not contain clauses that required compliance with the Davis-Bacon Act provisions. Cause: District personnel were not aware that the Davis-Bacon Act applied to these projects and, therefore, did not include the appropriate wage rate clauses in the applicable procurement documents. In addition, according to District personnel, District procedures did not require them to verify that the contractor submitted weekly certified payrolls demonstrating prevailing wage rates were paid. Effect: Absent the required 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 the certified payrolls from the contractor demonstrating that the prevailing wage rates were paid for the projects. Consequently, the District incurred questioned costs totaling $1,465,428. 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 contain the prevailing wage rate clauses and require submittal of weekly certified payrolls and that District personnel verify the payrolls were received. 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 has met virtually and in person with all staff involved in these transactions and the contractor who facilitated the renovation projects. Discussions with CEOs, attorneys, and others responsible for maintaining payroll records have been held. System of Award Management (SAM) Wage determination documents have been sent to the vendor and the vendor is in the process of revising purchasing agreements/contracts to include language related to Davis-Bacon Act. The vendor has agreed to provide the wage determinations and updated documents as soon as possible. The district will not expend any further federal dollars on construction projects unless there is a completed contract with all the required Davis-Bacon Act clauses and requires the vendor to provide weekly wage statements to the district as they work on the project. The district is working with legal and other larger school districts to develop its own contract document that contains all the required Davis-Bacon language. That document will be used in the future for any federally funded construction projects. The Finance Department will ensure that no contracts are approved without the correct language and requirements in them and will revise the purchasing documents to include references to Davis-Bacon Act.