2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The District did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. In addition, the District did not have internal controls in place to identify that certified payrolls were not obtained. Questioned Costs: Unknown. Context: There was one construction project charged to the grant during the year. We tested the one contractor and six subcontractor assigned to this project and noted the following: - The District did not obtain any certified payrolls for the contractor and subcontractors tested. - One of the subcontractor agreements did not include the required wage requirement clauses within the subcontract. - The District did not have a process in place to track certified payrolls received and to compare them to prevailing wage rates. Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The District was unaware of the wage rate requirements as it applied to this grant and as such, there was no assigned department or employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable.Recommendation: We recommend the District implement internal controls over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The District did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. In addition, the District did not have internal controls in place to identify that certified payrolls were not obtained. Questioned Costs: Unknown. Context: There was one construction project charged to the grant during the year. We tested the one contractor and six subcontractor assigned to this project and noted the following: - The District did not obtain any certified payrolls for the contractor and subcontractors tested. - One of the subcontractor agreements did not include the required wage requirement clauses within the subcontract. - The District did not have a process in place to track certified payrolls received and to compare them to prevailing wage rates. Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The District was unaware of the wage rate requirements as it applied to this grant and as such, there was no assigned department or employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable.Recommendation: We recommend the District implement internal controls over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The District did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. In addition, the District did not have internal controls in place to identify that certified payrolls were not obtained. Questioned Costs: Unknown. Context: There was one construction project charged to the grant during the year. We tested the one contractor and six subcontractor assigned to this project and noted the following: - The District did not obtain any certified payrolls for the contractor and subcontractors tested. - One of the subcontractor agreements did not include the required wage requirement clauses within the subcontract. - The District did not have a process in place to track certified payrolls received and to compare them to prevailing wage rates. Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The District was unaware of the wage rate requirements as it applied to this grant and as such, there was no assigned department or employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable.Recommendation: We recommend the District implement internal controls over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The District did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. In addition, the District did not have internal controls in place to identify that certified payrolls were not obtained. Questioned Costs: Unknown. Context: There was one construction project charged to the grant during the year. We tested the one contractor and six subcontractor assigned to this project and noted the following: - The District did not obtain any certified payrolls for the contractor and subcontractors tested. - One of the subcontractor agreements did not include the required wage requirement clauses within the subcontract. - The District did not have a process in place to track certified payrolls received and to compare them to prevailing wage rates. Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The District was unaware of the wage rate requirements as it applied to this grant and as such, there was no assigned department or employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable.Recommendation: We recommend the District implement internal controls over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The District did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. In addition, the District did not have internal controls in place to identify that certified payrolls were not obtained. Questioned Costs: Unknown. Context: There was one construction project charged to the grant during the year. We tested the one contractor and six subcontractor assigned to this project and noted the following: - The District did not obtain any certified payrolls for the contractor and subcontractors tested. - One of the subcontractor agreements did not include the required wage requirement clauses within the subcontract. - The District did not have a process in place to track certified payrolls received and to compare them to prevailing wage rates. Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The District was unaware of the wage rate requirements as it applied to this grant and as such, there was no assigned department or employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable.Recommendation: We recommend the District implement internal controls over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The District did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. In addition, the District did not have internal controls in place to identify that certified payrolls were not obtained. Questioned Costs: Unknown. Context: There was one construction project charged to the grant during the year. We tested the one contractor and six subcontractor assigned to this project and noted the following: - The District did not obtain any certified payrolls for the contractor and subcontractors tested. - One of the subcontractor agreements did not include the required wage requirement clauses within the subcontract. - The District did not have a process in place to track certified payrolls received and to compare them to prevailing wage rates. Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The District was unaware of the wage rate requirements as it applied to this grant and as such, there was no assigned department or employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable.Recommendation: We recommend the District implement internal controls over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The District did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. In addition, the District did not have internal controls in place to identify that certified payrolls were not obtained. Questioned Costs: Unknown. Context: There was one construction project charged to the grant during the year. We tested the one contractor and six subcontractor assigned to this project and noted the following: - The District did not obtain any certified payrolls for the contractor and subcontractors tested. - One of the subcontractor agreements did not include the required wage requirement clauses within the subcontract. - The District did not have a process in place to track certified payrolls received and to compare them to prevailing wage rates. Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The District was unaware of the wage rate requirements as it applied to this grant and as such, there was no assigned department or employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable.Recommendation: We recommend the District implement internal controls over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The District did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. In addition, the District did not have internal controls in place to identify that certified payrolls were not obtained. Questioned Costs: Unknown. Context: There was one construction project charged to the grant during the year. We tested the one contractor and six subcontractor assigned to this project and noted the following: - The District did not obtain any certified payrolls for the contractor and subcontractors tested. - One of the subcontractor agreements did not include the required wage requirement clauses within the subcontract. - The District did not have a process in place to track certified payrolls received and to compare them to prevailing wage rates. Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The District was unaware of the wage rate requirements as it applied to this grant and as such, there was no assigned department or employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable.Recommendation: We recommend the District implement internal controls over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The District did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. In addition, the District did not have internal controls in place to identify that certified payrolls were not obtained. Questioned Costs: Unknown. Context: There was one construction project charged to the grant during the year. We tested the one contractor and six subcontractor assigned to this project and noted the following: - The District did not obtain any certified payrolls for the contractor and subcontractors tested. - One of the subcontractor agreements did not include the required wage requirement clauses within the subcontract. - The District did not have a process in place to track certified payrolls received and to compare them to prevailing wage rates. Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The District was unaware of the wage rate requirements as it applied to this grant and as such, there was no assigned department or employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable.Recommendation: We recommend the District implement internal controls over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.
2022-002 Finding: Special Tests - Wage Rate Requirements Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund (ESSER) Passed-through Colorado Department of Education Award Number - 4420; Award Year 2022 Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141?3144, 3146, and 3147). Non-Federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the Non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). In addition, according to 2 CFR Part 200.303, the non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. Condition: The District did not obtain certified payrolls for contractor or subcontractor work performed during the fiscal year ended June 30, 2022. In addition, the District did not have internal controls in place to identify that certified payrolls were not obtained. Questioned Costs: Unknown. Context: There was one construction project charged to the grant during the year. We tested the one contractor and six subcontractor assigned to this project and noted the following: - The District did not obtain any certified payrolls for the contractor and subcontractors tested. - One of the subcontractor agreements did not include the required wage requirement clauses within the subcontract. - The District did not have a process in place to track certified payrolls received and to compare them to prevailing wage rates. Effect: Certified Payrolls were not obtained or reviewed for the project so laborers and mechanics employed by contractors or subcontractors may not have been paid prevailing wage rates. Cause: The District was unaware of the wage rate requirements as it applied to this grant and as such, there was no assigned department or employee to monitor, review and obtain certified payrolls during the year from contractors and subcontractors. Identification as a Repeat Finding: Not applicable.Recommendation: We recommend the District implement internal controls over wage rate requirements, including facilities staff on-site weekly where projects are occurring to determine if work was completed towards the project, tracking certified payrolls or notification of no work performed and reviewing to help ensure wages are equal to or in excess of the prevailing wage rates. Views of Responsible Officials: Agree. See separate report for planned corrective actions.
2022-001 Finding: Allowable Costs and Allowable Activities Federal Assistance Listing Number 84.425D - COVID-19 Elementary and Secondary School Emergency Fund Federal Assistance Listing Number 84.425U - COVID-19 American Rescue Plan - Elementary and Secondary School Emergency Relief Federal Assistance Listing Number 84.425W - COVID-19 American Rescue Plan ? Elementary and Secondary School Emergency Relief ?Homeless Children and Youth Passed-through Colorado Department of Education Award Number - 4425, 5425, 4420, 4419, 4414, 9414, 4413, 8425, 9019; Award Year 2022 Criteria: According to 2 CFR Part 200.303 - The non-Federal entity must (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in ?Standards for Internal Control in the Federal Government? issued by the Comptroller General of the United States or the ?Internal Control Integrated Framework?, issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). (b) Comply with the U.S. Constitution, Federal statutes, regulations, and the terms and conditions of the Federal awards. (c) Evaluate and monitor the non-Federal entity's compliance with statutes, regulations and the terms and conditions of Federal awards. Condition: The District's internal control policy (DE-R-2) requires that the District complete semiannual time and effort certifications for employees with wages and/or benefits that are charged to a federal grant. We noted that no time and effort certifications were completed for fiscal year 2022. In addition, we noted that there were no internal control checklists or procedures manuals for the grants department staff to follow while administering the various grants of the District. Questioned Costs: None. Context: We tested 65 payroll and nonpayroll transactions for the grants identified above for the year ended June 30, 2022 and noted 17 instances in which time and effort certification was required and could not be provided. The tested population covered expenditures of $2.9 million and the total population of expenditures were approximately $11.9 million. A non-statistical sampling methodology was used to select the sample. Effect: The District did not have adequate internal controls in place over the ESSER program, which could result in inaccurate or unallowable expenditures being applied against the grant. Cause: The District's grants department had 100% turnover during fiscal year 2022. As there were no checklists or procedures manuals in place, the new grants department staff were unaware of the internal controls in place over the ESSER program they were required to follow. In addition, the District's process to ensure that all required time and effort certifications are completed does not allow for timely recognition of uncompleted certifications.Identification as a repeat finding: Not Applicable Recommendation: We recommend the District's grants department create a checklist or procedures manual to ensure that all required internal controls are completed. In addition, the District's grants department should work with other District departments to ensure they are aware of all internal control policies effecting grants. Finally, the District should cross-train employees to allow for better continuity in the event of turnover. Views of responsible officials and planned corrective actions: Agree. See separate report for planned corrective actions.