Audit 298156

Required language was not included in the construction contracts using laborers and mechanics financed with ESSER funds. ESSER program required all construction contracts to include language in the contracts that all contractors or subcontractors must pay wages that are not less than those established for the locality of the project. Due to oversight of management and the outside accountant this requirement was not noted. Federal ESSER funds were spent on construction that did not include the required language in the contract. Management and the outside accountants should review the terms of the award to ensure all compliance requirements of the award are addressed appropriately. We acknowledge the audit finding regarding non-compliance with the management of our ESSER grant. We understand the importance of following the applicable rules and regulations for the use of federal funds. Current management will proceed with the following to prevent a similar oversight from reoccurring. 1 . Any Griffin Foundation staff who is responsible for the management of Federal funding will complete training focused on the requirements established by the Office of Budget Management (0MB). 2. Management will work with Grants Management staff to obtain training via their document library and/or annual conference. 3. Management will work with contracted accounting service to ensure similar training is received by their staff. 4. The Board of the Griffin Foundation will establish a policy that requires additional documentation and consideration before any future federal funds are used to fund a capital project.

Required language was not included in the construction contracts using laborers and mechanics financed with ESSER funds. ESSER program required all construction contracts to include language in the contracts that all contractors or subcontractors must pay wages that are not less than those established for the locality of the project. Due to oversight of management and the outside accountant this requirement was not noted. Federal ESSER funds were spent on construction that did not include the required language in the contract. Management and the outside accountants should review the terms of the award to ensure all compliance requirements of the award are addressed appropriately. We acknowledge the audit finding regarding non-compliance with the management of our ESSER grant. We understand the importance of following the applicable rules and regulations for the use of federal funds. Current management will proceed with the following to prevent a similar oversight from reoccurring. 1 . Any Griffin Foundation staff who is responsible for the management of Federal funding will complete training focused on the requirements established by the Office of Budget Management (0MB). 2. Management will work with Grants Management staff to obtain training via their document library and/or annual conference. 3. Management will work with contracted accounting service to ensure similar training is received by their staff. 4. The Board of the Griffin Foundation will establish a policy that requires additional documentation and consideration before any future federal funds are used to fund a capital project.

Required language was not included in the construction contracts using laborers and mechanics financed with ESSER funds. ESSER program required all construction contracts to include language in the contracts that all contractors or subcontractors must pay wages that are not less than those established for the locality of the project. Due to oversight of management and the outside accountant this requirement was not noted. Federal ESSER funds were spent on construction that did not include the required language in the contract. Management and the outside accountants should review the terms of the award to ensure all compliance requirements of the award are addressed appropriately. We acknowledge the audit finding regarding non-compliance with the management of our ESSER grant. We understand the importance of following the applicable rules and regulations for the use of federal funds. Current management will proceed with the following to prevent a similar oversight from reoccurring. 1 . Any Griffin Foundation staff who is responsible for the management of Federal funding will complete training focused on the requirements established by the Office of Budget Management (0MB). 2. Management will work with Grants Management staff to obtain training via their document library and/or annual conference. 3. Management will work with contracted accounting service to ensure similar training is received by their staff. 4. The Board of the Griffin Foundation will establish a policy that requires additional documentation and consideration before any future federal funds are used to fund a capital project.

Required language was not included in the construction contracts using laborers and mechanics financed with ESSER funds. ESSER program required all construction contracts to include language in the contracts that all contractors or subcontractors must pay wages that are not less than those established for the locality of the project. Due to oversight of management and the outside accountant this requirement was not noted. Federal ESSER funds were spent on construction that did not include the required language in the contract. Management and the outside accountants should review the terms of the award to ensure all compliance requirements of the award are addressed appropriately. We acknowledge the audit finding regarding non-compliance with the management of our ESSER grant. We understand the importance of following the applicable rules and regulations for the use of federal funds. Current management will proceed with the following to prevent a similar oversight from reoccurring. 1 . Any Griffin Foundation staff who is responsible for the management of Federal funding will complete training focused on the requirements established by the Office of Budget Management (0MB). 2. Management will work with Grants Management staff to obtain training via their document library and/or annual conference. 3. Management will work with contracted accounting service to ensure similar training is received by their staff. 4. The Board of the Griffin Foundation will establish a policy that requires additional documentation and consideration before any future federal funds are used to fund a capital project.