2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.313(c) through (d) which require that:
(c) Equipment must be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the Federal award or, when appropriate, under other Federal awards; however, the non-Federal entity must not encumber the equipment without prior approval of the Federal awarding agency.
(d) Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements:
1. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
2. A physical inventory of the property must be taken and the results reconciled with the property records at least once every 2 years.
3. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated.
4. Adequate maintenance procedures must be developed to keep the property in good condition.
5. If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return.
The School District failed to properly track assets purchased or improvements completed with ESF (specifically Elementary and Secondary School Emergency Relief (ESSER)) funds in their Equipment Inventory System. In addition, support was not provided that the required physical inventory of equipment was being performed.
The School District Treasurer should review the Equipment Inventory System and adjust it to include all assets purchased with ESSER Funds. The School District should establish procedures to ensure the required physical inventories are being performed and reconciled with the Equipment Inventory System at least every two years.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section. 2 CFR part 200, Appendix II(D), states that all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following. The “Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144 and 3146-3148) as supplemented by Department of Labor regulations (29 CFR § 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency.”
29 CFR § 5.5(A)(3)(ii) requires the contractor to submit weekly payroll reports certifying, among other requirements, “that each laborer or mechanic employed on the contract has been paid the full weekly wages earned.”
During fiscal year 2022, the School District incurred expenses with contractors for work done which was paid out of the Elementary and Secondary School Emergency Relief Fund as follows:
• Dixon Electrical for the high school baseball / softball fields lighting project in the amount of $331,293
• Tierney for the Interactive Smart Panel Project in the amount of $418,066
• Tribute Contracting and Consultants, LLC for Construction of Outdoor Classrooms in the amount of $116,325
• GLS Electric Inc for electrical work for smartboard installation in the amount of $43,800
Although the required clauses concerning prevailing wages were included in the contracts for these services, as a result of a lack of proper internal controls, certified payrolls were not provided by the School District to support that for each week in which work was performed under the contract or subcontract, the contractor or subcontractor was submitting the required certified payrolls.
Failure to have effective controls in place over wage-rate requirements may result in the School District and its contractors or subcontractors failing to pay prevailing wages when required by Federal law and could result in reduction of future Federal funding or other sanctions imposed by Federal grantors.
When required by Federal grant legislation, the School District should ensure prime construction contracts in excess of $2,000 paid with Federal grant monies contain provisions that require the contractor to comply with wage rate requirements. Further, the School District should ensure certified payroll reports are provided weekly by the contractor.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.328 which provides the Federal awarding agency must solicit only the standard, OMB-approved governmentwide data elements for collection of financial information. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting.
The Ohio Department of Education Grants Manual requires, at the end of the grant period, that entities submit a final expenditure report (FER). A FER must be submitted to show how grant funds were expended during the grant period.
The amounts submitted by the School District in the Final Expenditure Report for the Education Stabilization Fund Elementary and Secondary School Emergency Relief Grant (ESSER II) (grant year 2022) understated when compared to the underlying system data. This was due to the Treasurer not including expenditures in the amount of $260,404 which were expended during Fiscal Year 2021.
In addition, the amounts by object code submitted by the School District in the Final Expenditure Report for the Education Stabilization Fund American Rescue Plan Elementary and Secondary School Emergency Relief Grant (grant year 2022) varied from the underlying system data due to the Treasurer incorrectly posting Purchased Services of $11,733 as Supplies and not including Capital Outlay expenditures in the amount of $158,486. Total expenditures on the Final Expenditure Report were understated by $158,486 when compared to the underlying School District records.
These error postings were the result of a lack of proper internal controls and due care when preparing the reports. The Treasurer should properly compile and review the annual Final Expenditure Reports, verifying the correct information is provided to the grantor.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.313(c) through (d) which require that:
(c) Equipment must be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the Federal award or, when appropriate, under other Federal awards; however, the non-Federal entity must not encumber the equipment without prior approval of the Federal awarding agency.
(d) Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements:
1. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
2. A physical inventory of the property must be taken and the results reconciled with the property records at least once every 2 years.
3. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated.
4. Adequate maintenance procedures must be developed to keep the property in good condition.
5. If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return.
The School District failed to properly track assets purchased or improvements completed with ESF (specifically Elementary and Secondary School Emergency Relief (ESSER)) funds in their Equipment Inventory System. In addition, support was not provided that the required physical inventory of equipment was being performed.
The School District Treasurer should review the Equipment Inventory System and adjust it to include all assets purchased with ESSER Funds. The School District should establish procedures to ensure the required physical inventories are being performed and reconciled with the Equipment Inventory System at least every two years.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section. 2 CFR part 200, Appendix II(D), states that all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following. The “Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144 and 3146-3148) as supplemented by Department of Labor regulations (29 CFR § 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency.”
29 CFR § 5.5(A)(3)(ii) requires the contractor to submit weekly payroll reports certifying, among other requirements, “that each laborer or mechanic employed on the contract has been paid the full weekly wages earned.”
During fiscal year 2022, the School District incurred expenses with contractors for work done which was paid out of the Elementary and Secondary School Emergency Relief Fund as follows:
• Dixon Electrical for the high school baseball / softball fields lighting project in the amount of $331,293
• Tierney for the Interactive Smart Panel Project in the amount of $418,066
• Tribute Contracting and Consultants, LLC for Construction of Outdoor Classrooms in the amount of $116,325
• GLS Electric Inc for electrical work for smartboard installation in the amount of $43,800
Although the required clauses concerning prevailing wages were included in the contracts for these services, as a result of a lack of proper internal controls, certified payrolls were not provided by the School District to support that for each week in which work was performed under the contract or subcontract, the contractor or subcontractor was submitting the required certified payrolls.
Failure to have effective controls in place over wage-rate requirements may result in the School District and its contractors or subcontractors failing to pay prevailing wages when required by Federal law and could result in reduction of future Federal funding or other sanctions imposed by Federal grantors.
When required by Federal grant legislation, the School District should ensure prime construction contracts in excess of $2,000 paid with Federal grant monies contain provisions that require the contractor to comply with wage rate requirements. Further, the School District should ensure certified payroll reports are provided weekly by the contractor.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.328 which provides the Federal awarding agency must solicit only the standard, OMB-approved governmentwide data elements for collection of financial information. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting.
The Ohio Department of Education Grants Manual requires, at the end of the grant period, that entities submit a final expenditure report (FER). A FER must be submitted to show how grant funds were expended during the grant period.
The amounts submitted by the School District in the Final Expenditure Report for the Education Stabilization Fund Elementary and Secondary School Emergency Relief Grant (ESSER II) (grant year 2022) understated when compared to the underlying system data. This was due to the Treasurer not including expenditures in the amount of $260,404 which were expended during Fiscal Year 2021.
In addition, the amounts by object code submitted by the School District in the Final Expenditure Report for the Education Stabilization Fund American Rescue Plan Elementary and Secondary School Emergency Relief Grant (grant year 2022) varied from the underlying system data due to the Treasurer incorrectly posting Purchased Services of $11,733 as Supplies and not including Capital Outlay expenditures in the amount of $158,486. Total expenditures on the Final Expenditure Report were understated by $158,486 when compared to the underlying School District records.
These error postings were the result of a lack of proper internal controls and due care when preparing the reports. The Treasurer should properly compile and review the annual Final Expenditure Reports, verifying the correct information is provided to the grantor.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.313(c) through (d) which require that:
(c) Equipment must be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the Federal award or, when appropriate, under other Federal awards; however, the non-Federal entity must not encumber the equipment without prior approval of the Federal awarding agency.
(d) Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements:
1. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
2. A physical inventory of the property must be taken and the results reconciled with the property records at least once every 2 years.
3. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated.
4. Adequate maintenance procedures must be developed to keep the property in good condition.
5. If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return.
The School District failed to properly track assets purchased or improvements completed with ESF (specifically Elementary and Secondary School Emergency Relief (ESSER)) funds in their Equipment Inventory System. In addition, support was not provided that the required physical inventory of equipment was being performed.
The School District Treasurer should review the Equipment Inventory System and adjust it to include all assets purchased with ESSER Funds. The School District should establish procedures to ensure the required physical inventories are being performed and reconciled with the Equipment Inventory System at least every two years.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section. 2 CFR part 200, Appendix II(D), states that all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following. The “Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144 and 3146-3148) as supplemented by Department of Labor regulations (29 CFR § 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency.”
29 CFR § 5.5(A)(3)(ii) requires the contractor to submit weekly payroll reports certifying, among other requirements, “that each laborer or mechanic employed on the contract has been paid the full weekly wages earned.”
During fiscal year 2022, the School District incurred expenses with contractors for work done which was paid out of the Elementary and Secondary School Emergency Relief Fund as follows:
• Dixon Electrical for the high school baseball / softball fields lighting project in the amount of $331,293
• Tierney for the Interactive Smart Panel Project in the amount of $418,066
• Tribute Contracting and Consultants, LLC for Construction of Outdoor Classrooms in the amount of $116,325
• GLS Electric Inc for electrical work for smartboard installation in the amount of $43,800
Although the required clauses concerning prevailing wages were included in the contracts for these services, as a result of a lack of proper internal controls, certified payrolls were not provided by the School District to support that for each week in which work was performed under the contract or subcontract, the contractor or subcontractor was submitting the required certified payrolls.
Failure to have effective controls in place over wage-rate requirements may result in the School District and its contractors or subcontractors failing to pay prevailing wages when required by Federal law and could result in reduction of future Federal funding or other sanctions imposed by Federal grantors.
When required by Federal grant legislation, the School District should ensure prime construction contracts in excess of $2,000 paid with Federal grant monies contain provisions that require the contractor to comply with wage rate requirements. Further, the School District should ensure certified payroll reports are provided weekly by the contractor.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.328 which provides the Federal awarding agency must solicit only the standard, OMB-approved governmentwide data elements for collection of financial information. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting.
The Ohio Department of Education Grants Manual requires, at the end of the grant period, that entities submit a final expenditure report (FER). A FER must be submitted to show how grant funds were expended during the grant period.
The amounts submitted by the School District in the Final Expenditure Report for the Education Stabilization Fund Elementary and Secondary School Emergency Relief Grant (ESSER II) (grant year 2022) understated when compared to the underlying system data. This was due to the Treasurer not including expenditures in the amount of $260,404 which were expended during Fiscal Year 2021.
In addition, the amounts by object code submitted by the School District in the Final Expenditure Report for the Education Stabilization Fund American Rescue Plan Elementary and Secondary School Emergency Relief Grant (grant year 2022) varied from the underlying system data due to the Treasurer incorrectly posting Purchased Services of $11,733 as Supplies and not including Capital Outlay expenditures in the amount of $158,486. Total expenditures on the Final Expenditure Report were understated by $158,486 when compared to the underlying School District records.
These error postings were the result of a lack of proper internal controls and due care when preparing the reports. The Treasurer should properly compile and review the annual Final Expenditure Reports, verifying the correct information is provided to the grantor.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.313(c) through (d) which require that:
(c) Equipment must be used in the program or project for which it was acquired as long as needed, whether or not the project or program continues to be supported by the Federal award or, when appropriate, under other Federal awards; however, the non-Federal entity must not encumber the equipment without prior approval of the Federal awarding agency.
(d) Procedures for managing equipment (including replacement equipment), whether acquired in whole or in part under a Federal award, until disposition takes place will, as a minimum, meet the following requirements:
1. Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property (including the Federal award identification number), who holds title, the acquisition date, cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property.
2. A physical inventory of the property must be taken and the results reconciled with the property records at least once every 2 years.
3. A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated.
4. Adequate maintenance procedures must be developed to keep the property in good condition.
5. If the non-Federal entity is authorized or required to sell the property, proper sales procedures must be established to ensure the highest possible return.
The School District failed to properly track assets purchased or improvements completed with ESF (specifically Elementary and Secondary School Emergency Relief (ESSER)) funds in their Equipment Inventory System. In addition, support was not provided that the required physical inventory of equipment was being performed.
The School District Treasurer should review the Equipment Inventory System and adjust it to include all assets purchased with ESSER Funds. The School District should establish procedures to ensure the required physical inventories are being performed and reconciled with the Equipment Inventory System at least every two years.
2 CFR § 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR part 200. Thus, this section gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE, except as otherwise noted in that section. 2 CFR part 200, Appendix II(D), states that all contracts made by the non-Federal entity under the Federal award must contain provisions covering the following. The “Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144 and 3146-3148) as supplemented by Department of Labor regulations (29 CFR § 5, “Labor Standards Provisions Applicable to Contracts Covering Federally Financed and Assisted Construction”). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency.”
29 CFR § 5.5(A)(3)(ii) requires the contractor to submit weekly payroll reports certifying, among other requirements, “that each laborer or mechanic employed on the contract has been paid the full weekly wages earned.”
During fiscal year 2022, the School District incurred expenses with contractors for work done which was paid out of the Elementary and Secondary School Emergency Relief Fund as follows:
• Dixon Electrical for the high school baseball / softball fields lighting project in the amount of $331,293
• Tierney for the Interactive Smart Panel Project in the amount of $418,066
• Tribute Contracting and Consultants, LLC for Construction of Outdoor Classrooms in the amount of $116,325
• GLS Electric Inc for electrical work for smartboard installation in the amount of $43,800
Although the required clauses concerning prevailing wages were included in the contracts for these services, as a result of a lack of proper internal controls, certified payrolls were not provided by the School District to support that for each week in which work was performed under the contract or subcontract, the contractor or subcontractor was submitting the required certified payrolls.
Failure to have effective controls in place over wage-rate requirements may result in the School District and its contractors or subcontractors failing to pay prevailing wages when required by Federal law and could result in reduction of future Federal funding or other sanctions imposed by Federal grantors.
When required by Federal grant legislation, the School District should ensure prime construction contracts in excess of $2,000 paid with Federal grant monies contain provisions that require the contractor to comply with wage rate requirements. Further, the School District should ensure certified payroll reports are provided weekly by the contractor.
2 CFR § 3474.1 gives regulatory effect to the Department of Education for 2 CFR § 200.328 which provides the Federal awarding agency must solicit only the standard, OMB-approved governmentwide data elements for collection of financial information. This information must be collected with the frequency required by the terms and conditions of the Federal award, but no less frequently than annually nor more frequently than quarterly except in unusual circumstances, for example where more frequent reporting is necessary for the effective monitoring of the Federal award or could significantly affect program outcomes, and preferably in coordination with performance reporting.
The Ohio Department of Education Grants Manual requires, at the end of the grant period, that entities submit a final expenditure report (FER). A FER must be submitted to show how grant funds were expended during the grant period.
The amounts submitted by the School District in the Final Expenditure Report for the Education Stabilization Fund Elementary and Secondary School Emergency Relief Grant (ESSER II) (grant year 2022) understated when compared to the underlying system data. This was due to the Treasurer not including expenditures in the amount of $260,404 which were expended during Fiscal Year 2021.
In addition, the amounts by object code submitted by the School District in the Final Expenditure Report for the Education Stabilization Fund American Rescue Plan Elementary and Secondary School Emergency Relief Grant (grant year 2022) varied from the underlying system data due to the Treasurer incorrectly posting Purchased Services of $11,733 as Supplies and not including Capital Outlay expenditures in the amount of $158,486. Total expenditures on the Final Expenditure Report were understated by $158,486 when compared to the underlying School District records.
These error postings were the result of a lack of proper internal controls and due care when preparing the reports. The Treasurer should properly compile and review the annual Final Expenditure Reports, verifying the correct information is provided to the grantor.