Audit 21329

Finding 2022-003 - Davis-Bacon Prevailing Wage Requirement Federal program information: Funding agency: U.S. Department of Education Title: COVID-19 Education Stabilization Fund AL number: 84.425 Award year and number: 2022-133269-DPI-ESSERFII-163 Criteria: 2 CFR Appendix II to Part 200 - Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires all construction contracts in excess of $2,000 awarded by a non-federal entity to include a provision for compliance with the Davis Bacon Act in the awarding contract. Contractors are required to pay laborers a wage rate not less than prevailing wage rates specified by the U.S. Department of Labor. The non-federal agency is required to obtain documentation, including certified payrolls, from the contractor, supporting weekly payrolls, in accordance with the Davis Bacon Act prior to payment of contractor invoices. Condition: We tested a sample of 40 disbursements for the grant program. Compliance with the Davis Bacon Act was required for 2 expenditures paid for the construction of playgrounds using federal COVID-19 Education Stabilization Funds. The District's Building Services department did not include the required Davis Bacon Act language in the construction contracts. Therefore, documentation supporting payment of prevailing wages was not obtained by Building Services prior to payment of the contrator's invoices. The District grant accounting manager followed up with Building Services and the vendor to obtain the required certified payrolls for auditor review. Cause: District Building Services individuals responsible for overseeing the construction project did not follow District procedures and communications requiring inclusion of the Davis Bacon Act language in the contracts and the subsequent review of certified contractor payrolls. Effect: Eligible costs may be disallowed by the Wisconsin Department of Public Instruction, or the U.S Department of Education. Recommendation: Prevailing wage documents should be obtained and reviewed in a timely manner.

Finding 2022-004 - Activities Allowed or Unallowed Federal program information: Funding agency: Federal Communications Commission Title: Emergency Connectivity Fund AL number: 32.009 Award year and number: 2022-NA Criteria: ECF Program-funded devices and services must be used primarily for off-campus educational purposes and by students, school staff, and library patrons with otherwise unmet needs. Condition: Out of the 890 Chromebooks that the District sought reimbursement for through the ECF, 258 Chromebooks were not assigned to students, school staff, or library patrons with otherwise unmet needs. The Chromebooks were kept in classrooms for primarily in school use. Known Questioned Costs: $59,856 Cause: The individuals overseeing the ECF program at the District did not follow up with the individual classrooms to ensure that the Chromes were being used primarily for off-campus educational purposes and by students, school staff, and library patrons with otherwise unmet needs. Effect: The District may have to repay the funds received as reimbursement for the purchase of the Chromebooks in question. Recommendation: District staff should review the program requirements to ensure that they only request reimbursement for items that meet the requirements of allowable activities. Views of

Finding 2022-003 - Davis-Bacon Prevailing Wage Requirement Federal program information: Funding agency: U.S. Department of Education Title: COVID-19 Education Stabilization Fund AL number: 84.425 Award year and number: 2022-133269-DPI-ESSERFII-163 Criteria: 2 CFR Appendix II to Part 200 - Contract Provisions for Non-Federal Entity Contracts Under Federal Awards requires all construction contracts in excess of $2,000 awarded by a non-federal entity to include a provision for compliance with the Davis Bacon Act in the awarding contract. Contractors are required to pay laborers a wage rate not less than prevailing wage rates specified by the U.S. Department of Labor. The non-federal agency is required to obtain documentation, including certified payrolls, from the contractor, supporting weekly payrolls, in accordance with the Davis Bacon Act prior to payment of contractor invoices. Condition: We tested a sample of 40 disbursements for the grant program. Compliance with the Davis Bacon Act was required for 2 expenditures paid for the construction of playgrounds using federal COVID-19 Education Stabilization Funds. The District's Building Services department did not include the required Davis Bacon Act language in the construction contracts. Therefore, documentation supporting payment of prevailing wages was not obtained by Building Services prior to payment of the contrator's invoices. The District grant accounting manager followed up with Building Services and the vendor to obtain the required certified payrolls for auditor review. Cause: District Building Services individuals responsible for overseeing the construction project did not follow District procedures and communications requiring inclusion of the Davis Bacon Act language in the contracts and the subsequent review of certified contractor payrolls. Effect: Eligible costs may be disallowed by the Wisconsin Department of Public Instruction, or the U.S Department of Education. Recommendation: Prevailing wage documents should be obtained and reviewed in a timely manner.

Finding 2022-004 - Activities Allowed or Unallowed Federal program information: Funding agency: Federal Communications Commission Title: Emergency Connectivity Fund AL number: 32.009 Award year and number: 2022-NA Criteria: ECF Program-funded devices and services must be used primarily for off-campus educational purposes and by students, school staff, and library patrons with otherwise unmet needs. Condition: Out of the 890 Chromebooks that the District sought reimbursement for through the ECF, 258 Chromebooks were not assigned to students, school staff, or library patrons with otherwise unmet needs. The Chromebooks were kept in classrooms for primarily in school use. Known Questioned Costs: $59,856 Cause: The individuals overseeing the ECF program at the District did not follow up with the individual classrooms to ensure that the Chromes were being used primarily for off-campus educational purposes and by students, school staff, and library patrons with otherwise unmet needs. Effect: The District may have to repay the funds received as reimbursement for the purchase of the Chromebooks in question. Recommendation: District staff should review the program requirements to ensure that they only request reimbursement for items that meet the requirements of allowable activities. Views of