FAC Explorer

Audit 315033

FY End
2023-06-30
Total Expended
$3.40M
Findings
4
Programs
10
Organization: Brockton School District (MT)
Year: 2023 Accepted: 2024-07-12
Auditor: Denning Downey and Associates Cpa's

Organization Exclusion Status:

Findings

ID Ref Severity Repeat Requirement
478363 2023-009 Material Weakness Yes N
478364 2023-010 Material Weakness Yes L
1054805 2023-009 Material Weakness Yes N
1054806 2023-010 Material Weakness Yes L

Programs

ALN Program Spent Major Findings
84.041 Impact Aid $2.14M Yes 2
84.425 Education Stabilization Fund $193,801 - 0
10.553 School Breakfast Program $47,705 - 0
84.060 Indian Education_grants to Local Educational Agencies $36,645 - 0
84.010 Title I Grants to Local Educational Agencies $33,986 - 0
15.130 Indian Education_assistance to Schools $6,826 - 0
84.358 Rural Education $6,514 - 0
10.555 National School Lunch Program $5,683 - 0
10.582 Fresh Fruit and Vegetable Program $5,085 - 0
10.559 Summer Food Service Program for Children $4,059 - 0

Contacts

Name Title Type
QMADBDLNJGY6 Ron Shanks Auditee
4067863195 Robert Denning Auditor
No contacts on file

Notes to SEFA

Title: Value of Federal Awards Expended in the form of Noncash Assistance Accounting Policies: The accompanying Schedule of Expenditures of Federal Awards (SEFA) includes the federal grant activity of Brockton Public Schools, Roosevelt County, Montana. The information in this schedule is presented in accordance with the requirements Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards. Because the schedule presents only a selected portion of the operations of the Brockton Public Schools, it is not intended to and does not present the financial position, changes in net position, or cash flows of the Brockton Public Schools. Therefore, some amounts presented in this schedule may differ from amounts presented in, or used in preparation of the basic financial statements. Expenditures reported on the Schedule are reported on the accrual basis of accounting. Such expenditures are recognized following the cost principles contained in the Uniform GuiDance, wherein certain types of expenditures are not allowable or are limited as to reimbursement. De Minimis Rate Used: N Rate Explanation: The Brockton Public Schools has elected not to use the 10 percent e Minimis indirect cost rate as provided in Sec. 200.414 Indirect Costs under Uniform Guidance. Food Commodities value equals the fair value at the time of receipt, $5,683.

Finding Details

Finding 2023-009
2023-009 Wage Compliance (Repeat Finding 2021/2022-011) CFDA Title: Impact Aid CFDA Number: 84.041 Federal Award Number: 2023 Federal Agency: U.S. Department of Education Pass-through Entity: Direct Condition: The District did not comply with the wage rate compliance related to the teacher housing civil construction project or the locker room remodel for expenditures paid from Impact Aid monies. Criteria: Section 7007 construction funds, as well as any Section 7002 or 7003(b) funds spent for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Compliance Requirement - All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141-3144, 3146, and 3147). Non-federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR part 215, Appendix A, Contract Provisions); 2 CFR part 176, subpart C; and 2 CFR section 200.326). Context: During the testing of significant claims for the Impact Aid major program related to construction, we noted claims in which there should be contracts in place and that the wage rate requirements would apply. Effect: Noncompliance with the Wage Rate Requirement for the teacher housing civil construction project, and the locker room remodel project. Cause: The District was not aware of the requirement. Recommendation: The District should implement internal controls to determine the federal compliance requirements of all federal funds received. In addition, procedures should be implemented to ensure any federal funds received in which the Wage Rate Requirement is required the following are implemented: 1. any construction vendor is by contract, and that contract includes the Prevailing Wage clauses for the contractors and subcontractors 2. the weekly certified payrolls are submitted
Finding 2023-010
2023-010 Late Audit Submission CFDA Title: Impact Aid CFDA Number: 84.041 Federal Award Number: 2023 Federal Agency: U.S. Department of Education Pass-through Entity: Direct Condition: Montana local governments with a June 30th fiscal year end must submit their audit report to the MT Department of Administration and the Federal Clearing house by March 31st, following the fiscal year end. The District’s audit was not completed until May 2024. Criteria: The audit for the fiscal year ended June 30th, 2023, was due to the State and the Federal government by March 31, 2024 as required by MT Administrative Rules 2.4.411 and the Federal Uniform Guidance/A-133 rules. Context: Per review of the audit compliance requirements for both the State of Montana and the Federal government. Effect: The District is late in completing their fiscal year 2023 audit. Cause: The District was unable to provide needed documentation to complete both the financial statement portion of the audit and the federal compliance testing for the audit. Recommendation: We recommend the District complete their annual audits in compliance with MT Administrative Rules 2.4.411 and federal rules described in the Uniform Guidance/A- 133.
Finding 2023-009
2023-009 Wage Compliance (Repeat Finding 2021/2022-011) CFDA Title: Impact Aid CFDA Number: 84.041 Federal Award Number: 2023 Federal Agency: U.S. Department of Education Pass-through Entity: Direct Condition: The District did not comply with the wage rate compliance related to the teacher housing civil construction project or the locker room remodel for expenditures paid from Impact Aid monies. Criteria: Section 7007 construction funds, as well as any Section 7002 or 7003(b) funds spent for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Compliance Requirement - All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by Federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141-3144, 3146, and 3147). Non-federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR part 215, Appendix A, Contract Provisions); 2 CFR part 176, subpart C; and 2 CFR section 200.326). Context: During the testing of significant claims for the Impact Aid major program related to construction, we noted claims in which there should be contracts in place and that the wage rate requirements would apply. Effect: Noncompliance with the Wage Rate Requirement for the teacher housing civil construction project, and the locker room remodel project. Cause: The District was not aware of the requirement. Recommendation: The District should implement internal controls to determine the federal compliance requirements of all federal funds received. In addition, procedures should be implemented to ensure any federal funds received in which the Wage Rate Requirement is required the following are implemented: 1. any construction vendor is by contract, and that contract includes the Prevailing Wage clauses for the contractors and subcontractors 2. the weekly certified payrolls are submitted
Finding 2023-010
2023-010 Late Audit Submission CFDA Title: Impact Aid CFDA Number: 84.041 Federal Award Number: 2023 Federal Agency: U.S. Department of Education Pass-through Entity: Direct Condition: Montana local governments with a June 30th fiscal year end must submit their audit report to the MT Department of Administration and the Federal Clearing house by March 31st, following the fiscal year end. The District’s audit was not completed until May 2024. Criteria: The audit for the fiscal year ended June 30th, 2023, was due to the State and the Federal government by March 31, 2024 as required by MT Administrative Rules 2.4.411 and the Federal Uniform Guidance/A-133 rules. Context: Per review of the audit compliance requirements for both the State of Montana and the Federal government. Effect: The District is late in completing their fiscal year 2023 audit. Cause: The District was unable to provide needed documentation to complete both the financial statement portion of the audit and the federal compliance testing for the audit. Recommendation: We recommend the District complete their annual audits in compliance with MT Administrative Rules 2.4.411 and federal rules described in the Uniform Guidance/A- 133.