The District?s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 0204000, 0270309, 0270595 Known Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During fiscal year 2022, the District spent $890,158 in Title I federal funding. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as federal regulations and the awarding agency require. Depending on the number and type of activities an employee performs, documentation can be a semiannual certification or a monthly personnel activity report, such as a timesheet. The Office of Superintendent of Public Instruction (OSPI) approved a plan for the District to complete and certify quarterly time-and-effort documentation based on employees? predetermined schedules. Description of Condition The District?s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the program with appropriate time-and-effort documentation. The District could not provide quarterly time-and-effort documentation for six employees. We consider this deficiency in internal controls to be material weakness, which led to a material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District had turnover among key staff responsible for recordkeeping and preparing time-and-effort documentation. As a result, current District staff were unable to locate the documents for the six employees. Effect of Condition Using a nonstatistical sample, we found six of 19 employees (36 percent) whose payroll costs totaling $95,142 did not have time-and-effort documentation to support the hours worked on the program. Without adequate time-and-effort documentation, the District cannot assure the federal grantor that payroll costs charged to the program were accurate and valid. During the audit, the District provided alternative documentation to show the employees worked in the program and the costs charged to it were for allowable activities. Therefore, we are not questioning these costs. Recommendation We recommend the District establish effective internal controls to ensure all payroll costs charged to applicable federal programs comply with federal and OSPI requirements for time-and-effort documentation. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: The Director of Finance will revise the time and effort procedure to include a verification process to ensure that all federally funded staff complete and submit time and effort forms. The Director of Finance will meet with the Grants Manager on a quarterly basis to review the staffing schedules and payroll coding to ensure that all federally funded staff are included in the Time and Effort tracking spreadsheet. We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Office of Superintendent of Public Instruction Addendum to Bulletin 048-17, establishes requirements for documenting time and effort. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
The District?s internal controls were inadequate for ensuring compliance with federal Title I eligibility requirements. Assistance Listing Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 0204000, 0270309, 0270595 Known Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During fiscal year 2022, the District spent $890,158 in Title I federal funding. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Title I requires participating districts to allocate more funds to schools with higher poverty percentages. Districts must rank schools from highest to lowest poverty concentrations based on the total number of students from low-income families attending the school or residing in the area. For districts with community eligibility provision (CEP) schools, which are those that can serve free and reduced-price lunch to all students without collecting applications because of the high concentration of students from low-income families, the districts must use the CEP school direct certification low-income count when ranking schools. The rankings are included in the Title I application, and districts must maintain documentation supporting their rankings. Description of Condition Our audit found the District?s internal controls were inadequate for ensuring compliance with Title I eligibility requirements. Specifically, the District used the building enrollment count instead of the CEP school direct certification low-income count when ranking its school buildings. It also did not properly rank three out of six school buildings. In addition, the District did not retain support for the National School Lunch Program student count used to allocate funding to its buildings. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District had turnover in its management positions. The Business Manager who prepared the Title I application no longer works with the District, and the Program Director was new at the time of submitting the application. Current staff also could not locate the supporting documentation for the counts used in the application. Effect of Condition The District cannot demonstrate that it complied with program requirements and allocated funding from the highest-to-lowest-poverty school buildings, as federal regulations require. Further, this may have limited the type and nature of services provided to schools with higher percentages of poverty. Recommendation We recommend the District establish and follow internal controls to ensure it uses correct income data for determining Title I building rankings and funding allocations, and retains documentation supporting counts used in the application. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Title I Program Director will work closely with the Grants Manager and Director of Finance to ensure that the annual application is completed correctly, including the allocations to school buildings. ? An action plan was submitted to OSPI which includes initial planning with the District Office team prior to the beginning of the school year, as well as monthly meetings with the Title I Program Director to ensure ranking and allocations are maintained. ? The district now has a Grants Manager that is working closely with the Title I Program Director to ensure that the buildings are within ranking order. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 34 U.S. Code of Federal Regulations (CFR), Part 200, Title 1 ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by the Local Educational Agencies, Section 78 ? Allocation of funds to school attendance areas and schools. Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
The District?s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 0204000, 0270309, 0270595 Known Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During fiscal year 2022, the District spent $890,158 in Title I federal funding. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as federal regulations and the awarding agency require. Depending on the number and type of activities an employee performs, documentation can be a semiannual certification or a monthly personnel activity report, such as a timesheet. The Office of Superintendent of Public Instruction (OSPI) approved a plan for the District to complete and certify quarterly time-and-effort documentation based on employees? predetermined schedules. Description of Condition The District?s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the program with appropriate time-and-effort documentation. The District could not provide quarterly time-and-effort documentation for six employees. We consider this deficiency in internal controls to be material weakness, which led to a material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District had turnover among key staff responsible for recordkeeping and preparing time-and-effort documentation. As a result, current District staff were unable to locate the documents for the six employees. Effect of Condition Using a nonstatistical sample, we found six of 19 employees (36 percent) whose payroll costs totaling $95,142 did not have time-and-effort documentation to support the hours worked on the program. Without adequate time-and-effort documentation, the District cannot assure the federal grantor that payroll costs charged to the program were accurate and valid. During the audit, the District provided alternative documentation to show the employees worked in the program and the costs charged to it were for allowable activities. Therefore, we are not questioning these costs. Recommendation We recommend the District establish effective internal controls to ensure all payroll costs charged to applicable federal programs comply with federal and OSPI requirements for time-and-effort documentation. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: The Director of Finance will revise the time and effort procedure to include a verification process to ensure that all federally funded staff complete and submit time and effort forms. The Director of Finance will meet with the Grants Manager on a quarterly basis to review the staffing schedules and payroll coding to ensure that all federally funded staff are included in the Time and Effort tracking spreadsheet. We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Office of Superintendent of Public Instruction Addendum to Bulletin 048-17, establishes requirements for documenting time and effort. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
The District?s internal controls were inadequate for ensuring compliance with federal Title I eligibility requirements. Assistance Listing Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 0204000, 0270309, 0270595 Known Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During fiscal year 2022, the District spent $890,158 in Title I federal funding. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Title I requires participating districts to allocate more funds to schools with higher poverty percentages. Districts must rank schools from highest to lowest poverty concentrations based on the total number of students from low-income families attending the school or residing in the area. For districts with community eligibility provision (CEP) schools, which are those that can serve free and reduced-price lunch to all students without collecting applications because of the high concentration of students from low-income families, the districts must use the CEP school direct certification low-income count when ranking schools. The rankings are included in the Title I application, and districts must maintain documentation supporting their rankings. Description of Condition Our audit found the District?s internal controls were inadequate for ensuring compliance with Title I eligibility requirements. Specifically, the District used the building enrollment count instead of the CEP school direct certification low-income count when ranking its school buildings. It also did not properly rank three out of six school buildings. In addition, the District did not retain support for the National School Lunch Program student count used to allocate funding to its buildings. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District had turnover in its management positions. The Business Manager who prepared the Title I application no longer works with the District, and the Program Director was new at the time of submitting the application. Current staff also could not locate the supporting documentation for the counts used in the application. Effect of Condition The District cannot demonstrate that it complied with program requirements and allocated funding from the highest-to-lowest-poverty school buildings, as federal regulations require. Further, this may have limited the type and nature of services provided to schools with higher percentages of poverty. Recommendation We recommend the District establish and follow internal controls to ensure it uses correct income data for determining Title I building rankings and funding allocations, and retains documentation supporting counts used in the application. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Title I Program Director will work closely with the Grants Manager and Director of Finance to ensure that the annual application is completed correctly, including the allocations to school buildings. ? An action plan was submitted to OSPI which includes initial planning with the District Office team prior to the beginning of the school year, as well as monthly meetings with the Title I Program Director to ensure ranking and allocations are maintained. ? The district now has a Grants Manager that is working closely with the Title I Program Director to ensure that the buildings are within ranking order. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 34 U.S. Code of Federal Regulations (CFR), Part 200, Title 1 ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by the Local Educational Agencies, Section 78 ? Allocation of funds to school attendance areas and schools. Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
The District?s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 0204000, 0270309, 0270595 Known Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During fiscal year 2022, the District spent $890,158 in Title I federal funding. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as federal regulations and the awarding agency require. Depending on the number and type of activities an employee performs, documentation can be a semiannual certification or a monthly personnel activity report, such as a timesheet. The Office of Superintendent of Public Instruction (OSPI) approved a plan for the District to complete and certify quarterly time-and-effort documentation based on employees? predetermined schedules. Description of Condition The District?s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the program with appropriate time-and-effort documentation. The District could not provide quarterly time-and-effort documentation for six employees. We consider this deficiency in internal controls to be material weakness, which led to a material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District had turnover among key staff responsible for recordkeeping and preparing time-and-effort documentation. As a result, current District staff were unable to locate the documents for the six employees. Effect of Condition Using a nonstatistical sample, we found six of 19 employees (36 percent) whose payroll costs totaling $95,142 did not have time-and-effort documentation to support the hours worked on the program. Without adequate time-and-effort documentation, the District cannot assure the federal grantor that payroll costs charged to the program were accurate and valid. During the audit, the District provided alternative documentation to show the employees worked in the program and the costs charged to it were for allowable activities. Therefore, we are not questioning these costs. Recommendation We recommend the District establish effective internal controls to ensure all payroll costs charged to applicable federal programs comply with federal and OSPI requirements for time-and-effort documentation. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: The Director of Finance will revise the time and effort procedure to include a verification process to ensure that all federally funded staff complete and submit time and effort forms. The Director of Finance will meet with the Grants Manager on a quarterly basis to review the staffing schedules and payroll coding to ensure that all federally funded staff are included in the Time and Effort tracking spreadsheet. We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Office of Superintendent of Public Instruction Addendum to Bulletin 048-17, establishes requirements for documenting time and effort. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
The District?s internal controls were inadequate for ensuring compliance with federal Title I eligibility requirements. Assistance Listing Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 0204000, 0270309, 0270595 Known Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During fiscal year 2022, the District spent $890,158 in Title I federal funding. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Title I requires participating districts to allocate more funds to schools with higher poverty percentages. Districts must rank schools from highest to lowest poverty concentrations based on the total number of students from low-income families attending the school or residing in the area. For districts with community eligibility provision (CEP) schools, which are those that can serve free and reduced-price lunch to all students without collecting applications because of the high concentration of students from low-income families, the districts must use the CEP school direct certification low-income count when ranking schools. The rankings are included in the Title I application, and districts must maintain documentation supporting their rankings. Description of Condition Our audit found the District?s internal controls were inadequate for ensuring compliance with Title I eligibility requirements. Specifically, the District used the building enrollment count instead of the CEP school direct certification low-income count when ranking its school buildings. It also did not properly rank three out of six school buildings. In addition, the District did not retain support for the National School Lunch Program student count used to allocate funding to its buildings. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District had turnover in its management positions. The Business Manager who prepared the Title I application no longer works with the District, and the Program Director was new at the time of submitting the application. Current staff also could not locate the supporting documentation for the counts used in the application. Effect of Condition The District cannot demonstrate that it complied with program requirements and allocated funding from the highest-to-lowest-poverty school buildings, as federal regulations require. Further, this may have limited the type and nature of services provided to schools with higher percentages of poverty. Recommendation We recommend the District establish and follow internal controls to ensure it uses correct income data for determining Title I building rankings and funding allocations, and retains documentation supporting counts used in the application. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Title I Program Director will work closely with the Grants Manager and Director of Finance to ensure that the annual application is completed correctly, including the allocations to school buildings. ? An action plan was submitted to OSPI which includes initial planning with the District Office team prior to the beginning of the school year, as well as monthly meetings with the Title I Program Director to ensure ranking and allocations are maintained. ? The district now has a Grants Manager that is working closely with the Title I Program Director to ensure that the buildings are within ranking order. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 34 U.S. Code of Federal Regulations (CFR), Part 200, Title 1 ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by the Local Educational Agencies, Section 78 ? Allocation of funds to school attendance areas and schools. Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District?s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 0204000, 0270309, 0270595 Known Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During fiscal year 2022, the District spent $890,158 in Title I federal funding. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as federal regulations and the awarding agency require. Depending on the number and type of activities an employee performs, documentation can be a semiannual certification or a monthly personnel activity report, such as a timesheet. The Office of Superintendent of Public Instruction (OSPI) approved a plan for the District to complete and certify quarterly time-and-effort documentation based on employees? predetermined schedules. Description of Condition The District?s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the program with appropriate time-and-effort documentation. The District could not provide quarterly time-and-effort documentation for six employees. We consider this deficiency in internal controls to be material weakness, which led to a material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District had turnover among key staff responsible for recordkeeping and preparing time-and-effort documentation. As a result, current District staff were unable to locate the documents for the six employees. Effect of Condition Using a nonstatistical sample, we found six of 19 employees (36 percent) whose payroll costs totaling $95,142 did not have time-and-effort documentation to support the hours worked on the program. Without adequate time-and-effort documentation, the District cannot assure the federal grantor that payroll costs charged to the program were accurate and valid. During the audit, the District provided alternative documentation to show the employees worked in the program and the costs charged to it were for allowable activities. Therefore, we are not questioning these costs. Recommendation We recommend the District establish effective internal controls to ensure all payroll costs charged to applicable federal programs comply with federal and OSPI requirements for time-and-effort documentation. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: The Director of Finance will revise the time and effort procedure to include a verification process to ensure that all federally funded staff complete and submit time and effort forms. The Director of Finance will meet with the Grants Manager on a quarterly basis to review the staffing schedules and payroll coding to ensure that all federally funded staff are included in the Time and Effort tracking spreadsheet. We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Office of Superintendent of Public Instruction Addendum to Bulletin 048-17, establishes requirements for documenting time and effort. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
The District?s internal controls were inadequate for ensuring compliance with federal Title I eligibility requirements. Assistance Listing Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 0204000, 0270309, 0270595 Known Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During fiscal year 2022, the District spent $890,158 in Title I federal funding. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Title I requires participating districts to allocate more funds to schools with higher poverty percentages. Districts must rank schools from highest to lowest poverty concentrations based on the total number of students from low-income families attending the school or residing in the area. For districts with community eligibility provision (CEP) schools, which are those that can serve free and reduced-price lunch to all students without collecting applications because of the high concentration of students from low-income families, the districts must use the CEP school direct certification low-income count when ranking schools. The rankings are included in the Title I application, and districts must maintain documentation supporting their rankings. Description of Condition Our audit found the District?s internal controls were inadequate for ensuring compliance with Title I eligibility requirements. Specifically, the District used the building enrollment count instead of the CEP school direct certification low-income count when ranking its school buildings. It also did not properly rank three out of six school buildings. In addition, the District did not retain support for the National School Lunch Program student count used to allocate funding to its buildings. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District had turnover in its management positions. The Business Manager who prepared the Title I application no longer works with the District, and the Program Director was new at the time of submitting the application. Current staff also could not locate the supporting documentation for the counts used in the application. Effect of Condition The District cannot demonstrate that it complied with program requirements and allocated funding from the highest-to-lowest-poverty school buildings, as federal regulations require. Further, this may have limited the type and nature of services provided to schools with higher percentages of poverty. Recommendation We recommend the District establish and follow internal controls to ensure it uses correct income data for determining Title I building rankings and funding allocations, and retains documentation supporting counts used in the application. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Title I Program Director will work closely with the Grants Manager and Director of Finance to ensure that the annual application is completed correctly, including the allocations to school buildings. ? An action plan was submitted to OSPI which includes initial planning with the District Office team prior to the beginning of the school year, as well as monthly meetings with the Title I Program Director to ensure ranking and allocations are maintained. ? The district now has a Grants Manager that is working closely with the Title I Program Director to ensure that the buildings are within ranking order. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 34 U.S. Code of Federal Regulations (CFR), Part 200, Title 1 ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by the Local Educational Agencies, Section 78 ? Allocation of funds to school attendance areas and schools. Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
The District?s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 0204000, 0270309, 0270595 Known Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During fiscal year 2022, the District spent $890,158 in Title I federal funding. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as federal regulations and the awarding agency require. Depending on the number and type of activities an employee performs, documentation can be a semiannual certification or a monthly personnel activity report, such as a timesheet. The Office of Superintendent of Public Instruction (OSPI) approved a plan for the District to complete and certify quarterly time-and-effort documentation based on employees? predetermined schedules. Description of Condition The District?s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the program with appropriate time-and-effort documentation. The District could not provide quarterly time-and-effort documentation for six employees. We consider this deficiency in internal controls to be material weakness, which led to a material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District had turnover among key staff responsible for recordkeeping and preparing time-and-effort documentation. As a result, current District staff were unable to locate the documents for the six employees. Effect of Condition Using a nonstatistical sample, we found six of 19 employees (36 percent) whose payroll costs totaling $95,142 did not have time-and-effort documentation to support the hours worked on the program. Without adequate time-and-effort documentation, the District cannot assure the federal grantor that payroll costs charged to the program were accurate and valid. During the audit, the District provided alternative documentation to show the employees worked in the program and the costs charged to it were for allowable activities. Therefore, we are not questioning these costs. Recommendation We recommend the District establish effective internal controls to ensure all payroll costs charged to applicable federal programs comply with federal and OSPI requirements for time-and-effort documentation. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: The Director of Finance will revise the time and effort procedure to include a verification process to ensure that all federally funded staff complete and submit time and effort forms. The Director of Finance will meet with the Grants Manager on a quarterly basis to review the staffing schedules and payroll coding to ensure that all federally funded staff are included in the Time and Effort tracking spreadsheet. We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Office of Superintendent of Public Instruction Addendum to Bulletin 048-17, establishes requirements for documenting time and effort. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
The District?s internal controls were inadequate for ensuring compliance with federal Title I eligibility requirements. Assistance Listing Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 0204000, 0270309, 0270595 Known Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During fiscal year 2022, the District spent $890,158 in Title I federal funding. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Title I requires participating districts to allocate more funds to schools with higher poverty percentages. Districts must rank schools from highest to lowest poverty concentrations based on the total number of students from low-income families attending the school or residing in the area. For districts with community eligibility provision (CEP) schools, which are those that can serve free and reduced-price lunch to all students without collecting applications because of the high concentration of students from low-income families, the districts must use the CEP school direct certification low-income count when ranking schools. The rankings are included in the Title I application, and districts must maintain documentation supporting their rankings. Description of Condition Our audit found the District?s internal controls were inadequate for ensuring compliance with Title I eligibility requirements. Specifically, the District used the building enrollment count instead of the CEP school direct certification low-income count when ranking its school buildings. It also did not properly rank three out of six school buildings. In addition, the District did not retain support for the National School Lunch Program student count used to allocate funding to its buildings. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District had turnover in its management positions. The Business Manager who prepared the Title I application no longer works with the District, and the Program Director was new at the time of submitting the application. Current staff also could not locate the supporting documentation for the counts used in the application. Effect of Condition The District cannot demonstrate that it complied with program requirements and allocated funding from the highest-to-lowest-poverty school buildings, as federal regulations require. Further, this may have limited the type and nature of services provided to schools with higher percentages of poverty. Recommendation We recommend the District establish and follow internal controls to ensure it uses correct income data for determining Title I building rankings and funding allocations, and retains documentation supporting counts used in the application. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Title I Program Director will work closely with the Grants Manager and Director of Finance to ensure that the annual application is completed correctly, including the allocations to school buildings. ? An action plan was submitted to OSPI which includes initial planning with the District Office team prior to the beginning of the school year, as well as monthly meetings with the Title I Program Director to ensure ranking and allocations are maintained. ? The district now has a Grants Manager that is working closely with the Title I Program Director to ensure that the buildings are within ranking order. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 34 U.S. Code of Federal Regulations (CFR), Part 200, Title 1 ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by the Local Educational Agencies, Section 78 ? Allocation of funds to school attendance areas and schools. Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
The District?s internal controls were inadequate for ensuring compliance with requirements for time-and-effort documentation. Assistance Listing Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 0204000, 0270309, 0270595 Known Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During fiscal year 2022, the District spent $890,158 in Title I federal funding. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding program requirements and monitoring the effectiveness of established controls. The District is responsible for ensuring it supports all payroll costs charged to the program with adequate time-and-effort documentation, as federal regulations and the awarding agency require. Depending on the number and type of activities an employee performs, documentation can be a semiannual certification or a monthly personnel activity report, such as a timesheet. The Office of Superintendent of Public Instruction (OSPI) approved a plan for the District to complete and certify quarterly time-and-effort documentation based on employees? predetermined schedules. Description of Condition The District?s internal controls were ineffective for ensuring it supported all salaries and benefits charged to the program with appropriate time-and-effort documentation. The District could not provide quarterly time-and-effort documentation for six employees. We consider this deficiency in internal controls to be material weakness, which led to a material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District had turnover among key staff responsible for recordkeeping and preparing time-and-effort documentation. As a result, current District staff were unable to locate the documents for the six employees. Effect of Condition Using a nonstatistical sample, we found six of 19 employees (36 percent) whose payroll costs totaling $95,142 did not have time-and-effort documentation to support the hours worked on the program. Without adequate time-and-effort documentation, the District cannot assure the federal grantor that payroll costs charged to the program were accurate and valid. During the audit, the District provided alternative documentation to show the employees worked in the program and the costs charged to it were for allowable activities. Therefore, we are not questioning these costs. Recommendation We recommend the District establish effective internal controls to ensure all payroll costs charged to applicable federal programs comply with federal and OSPI requirements for time-and-effort documentation. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: The Director of Finance will revise the time and effort procedure to include a verification process to ensure that all federally funded staff complete and submit time and effort forms. The Director of Finance will meet with the Grants Manager on a quarterly basis to review the staffing schedules and payroll coding to ensure that all federally funded staff are included in the Time and Effort tracking spreadsheet. We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Office of Superintendent of Public Instruction Addendum to Bulletin 048-17, establishes requirements for documenting time and effort. Title 2 CFR Part 200, Uniform Guidance, Subpart E, Cost Principles, establishes requirements for determining allowable costs and supporting costs allocated to federal programs. Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
The District?s internal controls were inadequate for ensuring compliance with federal Title I eligibility requirements. Assistance Listing Number and Title: 84.010 ? Title I Grants to Local Educational Agencies Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: 0204000, 0270309, 0270595 Known Questioned Cost Amount: $0 Background The objective of the Title I program is to improve the teaching and learning of children who are at risk of not meeting state academic standards and who reside in areas with high concentrations of children from low-income families. During fiscal year 2022, the District spent $890,158 in Title I federal funding. Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Title I requires participating districts to allocate more funds to schools with higher poverty percentages. Districts must rank schools from highest to lowest poverty concentrations based on the total number of students from low-income families attending the school or residing in the area. For districts with community eligibility provision (CEP) schools, which are those that can serve free and reduced-price lunch to all students without collecting applications because of the high concentration of students from low-income families, the districts must use the CEP school direct certification low-income count when ranking schools. The rankings are included in the Title I application, and districts must maintain documentation supporting their rankings. Description of Condition Our audit found the District?s internal controls were inadequate for ensuring compliance with Title I eligibility requirements. Specifically, the District used the building enrollment count instead of the CEP school direct certification low-income count when ranking its school buildings. It also did not properly rank three out of six school buildings. In addition, the District did not retain support for the National School Lunch Program student count used to allocate funding to its buildings. We consider this deficiency in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition The District had turnover in its management positions. The Business Manager who prepared the Title I application no longer works with the District, and the Program Director was new at the time of submitting the application. Current staff also could not locate the supporting documentation for the counts used in the application. Effect of Condition The District cannot demonstrate that it complied with program requirements and allocated funding from the highest-to-lowest-poverty school buildings, as federal regulations require. Further, this may have limited the type and nature of services provided to schools with higher percentages of poverty. Recommendation We recommend the District establish and follow internal controls to ensure it uses correct income data for determining Title I building rankings and funding allocations, and retains documentation supporting counts used in the application. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Title I Program Director will work closely with the Grants Manager and Director of Finance to ensure that the annual application is completed correctly, including the allocations to school buildings. ? An action plan was submitted to OSPI which includes initial planning with the District Office team prior to the beginning of the school year, as well as monthly meetings with the Title I Program Director to ensure ranking and allocations are maintained. ? The district now has a Grants Manager that is working closely with the Title I Program Director to ensure that the buildings are within ranking order. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 34 U.S. Code of Federal Regulations (CFR), Part 200, Title 1 ? Improving the Academic Achievement of the Disadvantaged, Subpart A ? Improving Basic Programs Operated by the Local Educational Agencies, Section 78 ? Allocation of funds to school attendance areas and schools. Title 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11.
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).
The District did not have adequate internal controls for ensuring compliance with wage rate requirements. Assistance Listing Number and Title: 84.425, COVID-19 Education Stabilization Fund Federal Grantor Name: U.S. Department of Education Federal Award/Contract Number: N/A Pass-through Entity Name: Office of Superintendent of Public Instruction Pass-through Award/Contract Number: COVID-19, 84.425U-0712258 COVID-19, 84.425D-0120321 COVID-19, 84.425D-0135565 COVID-19, 84.425U-0138191 COVID-19, 84.425D-0137210 COVID-19, 84.425D-0140518 Known Questioned Cost Amount: $0 Background The objectives of the Education Stabilization Fund (ESF) program are to prevent, prepare for and respond to the COVID-19 pandemic. In fiscal year 2022, the District spent a total of $2,912,879 of its ESF awards. This included $1,517,486 in the Elementary and Secondary School Emergency Relief Fund (ESSER II) subprogram (84.425D) and $1,395,392 in the American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER/ESSER III) subprogram (84.425U). Federal regulations require recipients to establish and maintain internal controls that ensure compliance with program requirements. These controls include understanding grant requirements and monitoring the effectiveness of established controls. Under federal wage rate requirements, also known as the Davis-Bacon Act, contractors and subcontractors that work on projects financed with more than $2,000 of federal money must pay laborers and mechanics wage rates that the U.S. Department of Labor considers being similar to what local workers have been paid for similar projects. For construction contracts subject to these wage rate requirements, the District must include a provision that the contractor and subcontractor comply with those requirements and the Department of Labor?s regulations. This includes a requirement for the contractor and its subcontractor to submit to the District weekly, for each week in which any contract work is performed, certified payroll reports. These reports must include a copy of the payroll and a signed statement of compliance. Description of Condition During the 2021?22 school year, the District spent $1,662,730 from its ESSER II and III awards to pay a contractor and its subcontractors for purchasing and installing four classroom portables. This project was part of the District?s school facility capital improvement efforts to prevent the spread of COVID-19. Our audit found the District did not have adequate internal controls for ensuring compliance with federal prevailing wage rate requirements. Specifically, the District did not: ? Include the required prevailing wage rate clause in the contract established with the contractor ? Collect weekly certified payroll reports from the contractor and its subcontractors to confirm they paid laborers proper prevailing wages We consider these deficiencies in internal controls to be a material weakness, which led to material noncompliance. The issue was not reported as a finding in the prior audit. Cause of Condition District management did not know about the federal requirements to include the prevailing wage rate clause clauses in the contracts and collect all certified payroll reports from the contractor and its subcontractors each week to confirm they paid laborers proper prevailing wages. Effect of Condition Without adequate internal controls that ensure it includes the prevailing wage rate clauses in its contracts and collects all weekly certified payroll reports, the District cannot demonstrate it complied with federal wage rate requirements. The District could also be liable for paying any additional wages if the contractors and subcontractors did not pay prevailing wage rates to laborers working on the contracts. Recommendation We recommend the District develop internal controls to ensure compliance with federal wage rate requirements. This should include inserting prevailing wage rate clauses into contracts, as well as implementing effective monitoring processes to collect and review all weekly certified payroll reports timely from contractors and subcontractors. District?s Response The Wahluke School District concurs with this finding. The following corrective actions will be taken: ? The Director of Finance will develop and implement a procedure that will ensure that all the wage requirements for public works are met. ? The procedure will identify a key person that will ensure that the district is receiving copies of the certified payroll reports on a weekly basis, from the start of the project to the completion of the project. Auditor?s Remarks We thank the District for its cooperation and assistance during the audit and acknowledge its commitment to improving the condition described. We will review the status of this issue during our next audit. Applicable Laws and Regulations Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), section 516, Audit findings, establishes reporting requirements for audit findings. Title 2 CFR Part 200, Uniform Guidance, section 303, Internal controls, describes the requirements for auditees to maintain internal controls over federal programs and comply with federal program requirements. The American Institute of Certified Public Accountants defines significant deficiencies and material weaknesses in its Codification of Statements on Auditing Standards, section 935, Compliance Audits, paragraph 11. Title 29 CFR, Section 3.3 ? Weekly statement with respect to payment of wages, and Section 3.4 ? Submission of weekly statements and the preservation and inspection of weekly payroll records, establishes requirements for contractor or subcontractor submission of weekly certified payroll reports. Title 29 CFR, Section 5.5 ? Contract provisions and related matters establishes the requirements for the contracting officer to insert in full any contract in excess of $2,000 which is entered into for the actual construction, alteration and/or repair, including painting and decorating, of a public building or public work, or building or work financed in whole or in part with federal funds the clauses listed, which includes but is not limited to the minimum wages to be paid and payrolls and basic records to be maintained (submission of weekly certified payrolls).