Audit 298279

Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed practices and procedures regarding federal funds and Davis-Bacon Act compliance. These changes did not take effect in time to avoid the Impact Aid expenses. Procurement guidelines for construction projects funded by federal awards have been updated to include the appropriate clauses to comply with federal procurement guidelines. This expenditure occurred in FY23 but prior to the FY22 Audit completion.

Condition: Child counts entered on the Impact Aid application did not have proper supporting documentation for amounts. Criteria: Amounts entered on the application should be properly supported by survey data. Cause: Due to changes in categories of the child count on the application, the categories used in the surveys--did not match up exactly to application and therefore, child counts were underreported. Effect: Noncompliance with guidance Context: Application did not agree to child count on supporting data. Repeat Finding from Prior Year: No Recommendation We recommend child counts included on Impact Aid application agree to supporting documentation. We also recommend that child counts used on the application be reconciled and reviewed. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools selected to use its’ January 2020 application (FY21) for FY22 and FY23 as allowed by guidance. During the review of the survey data collected and the original application, it was discovered that the district under-reported numbers due to errors in the transcription of data. None of the employees responsible for the FY21 Impact Aid application are still with Lawton Public Schools. Lawton Public Schools has reviewed policies and procedures to ensure data is collected and reported accurately in its’ Impact Aid applications. Summary data, as well as survey data, are reviewed and verified by multiple staff members.

Condition: Devices/Services acquired with federal funds were not assigned to appropriate population of unmet needs. Criteria: FCC-ECF Program is to fund devices and services must be used primarily for off-campus educational purposes and by students, school staff with otherwise unmet needs; Who would otherwise lack access to connected device and/or broadband connectivity sufficient to engage in remote learning. Cause: The District did not assign devices/services to the correct population based on application. Effect: Noncompliance with guidance Context: 63 of the 800 devices were not issued to the proper population. Repeat Finding from Prior Year: 2022-010 Recommendation We recommend devices/services be assigned to the population approved in the federal funds application. We also recommend that District implement procedures to ensure distribution of services reconciles to the application. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools procedures require tracking of items with an acquisition cost of $5,000 or higher. These one-time FCC-ECF funds included specific criteria requiring specific tracking of all purchases including hotspots. These criteria were not identified until after the FY22 Audit was completed in March of 2023. The district updated procedures in April of 2023 to include the tracking of all items purchased with federal funds according to federal guidance. The implementation of these procedures occurred late if FY23 causing the finding to be repeated. Lawton Public Schools’ inventory practices have been evaluated. Inventory items being distributed or checked out are now entered into Incident IQ. The district has updated its’ in-processing of assets, additional staff have been put in place and trained to ensure items are distributed and tracked as required by federal award guidelines. In addition, these practices ensure distribution to only eligible students/staff.

Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed practices and procedures regarding federal funds and Davis-Bacon Act compliance. These changes did not take effect in time to avoid the Impact Aid expenses. Procurement guidelines for construction projects funded by federal awards have been updated to include the appropriate clauses to comply with federal procurement guidelines. This expenditure occurred in FY23 but prior to the FY22 Audit completion.

Condition: Child counts entered on the Impact Aid application did not have proper supporting documentation for amounts. Criteria: Amounts entered on the application should be properly supported by survey data. Cause: Due to changes in categories of the child count on the application, the categories used in the surveys--did not match up exactly to application and therefore, child counts were underreported. Effect: Noncompliance with guidance Context: Application did not agree to child count on supporting data. Repeat Finding from Prior Year: No Recommendation We recommend child counts included on Impact Aid application agree to supporting documentation. We also recommend that child counts used on the application be reconciled and reviewed. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools selected to use its’ January 2020 application (FY21) for FY22 and FY23 as allowed by guidance. During the review of the survey data collected and the original application, it was discovered that the district under-reported numbers due to errors in the transcription of data. None of the employees responsible for the FY21 Impact Aid application are still with Lawton Public Schools. Lawton Public Schools has reviewed policies and procedures to ensure data is collected and reported accurately in its’ Impact Aid applications. Summary data, as well as survey data, are reviewed and verified by multiple staff members.

Condition: Devices/Services acquired with federal funds were not assigned to appropriate population of unmet needs. Criteria: FCC-ECF Program is to fund devices and services must be used primarily for off-campus educational purposes and by students, school staff with otherwise unmet needs; Who would otherwise lack access to connected device and/or broadband connectivity sufficient to engage in remote learning. Cause: The District did not assign devices/services to the correct population based on application. Effect: Noncompliance with guidance Context: 63 of the 800 devices were not issued to the proper population. Repeat Finding from Prior Year: 2022-010 Recommendation We recommend devices/services be assigned to the population approved in the federal funds application. We also recommend that District implement procedures to ensure distribution of services reconciles to the application. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools procedures require tracking of items with an acquisition cost of $5,000 or higher. These one-time FCC-ECF funds included specific criteria requiring specific tracking of all purchases including hotspots. These criteria were not identified until after the FY22 Audit was completed in March of 2023. The district updated procedures in April of 2023 to include the tracking of all items purchased with federal funds according to federal guidance. The implementation of these procedures occurred late if FY23 causing the finding to be repeated. Lawton Public Schools’ inventory practices have been evaluated. Inventory items being distributed or checked out are now entered into Incident IQ. The district has updated its’ in-processing of assets, additional staff have been put in place and trained to ensure items are distributed and tracked as required by federal award guidelines. In addition, these practices ensure distribution to only eligible students/staff.