Audit 387433

Audit Finding 2024-005 – Lack of Required Time and Effort Documentation Identification of the Federal Programs: Title I, Part A; Assistance Listing Number 84.010; Year 2024 Education Stabilization Funds; Assistance Listing Number 84.425D, 84.425U, 84.425W; Year 2024 Criteria: Under 2 CFR 200.430(i), charges to federal awards for salaries and wages must be based on records that accurately reflect the work performed. These records must: • Be supported by a system of internal controls; • Be incorporated into the official records of the non‑Federal entity; • Reasonably reflect total activity for which the employee is compensated; • Support distribution among specific activities or cost objectives. Commonly accepted forms of support include Personal Activity Reports (PARs), timesheets, or an equivalent system documenting actual time worked. Condition: During our testing of payroll charges for employees whose salaries were allocated to the programs, we noted that the entity did not maintain Personal Activity Reports or other acceptable time‑and‑effort documentation supporting the distribution of time to the federal program. Context: Documentation was not maintained for support of all employees' salaries and wages tested. Cause: The District has had vacancies in certain positions that are key parts of the District's control processes which led to the District not maintaining proper documentation. Effect or Potential Effect: Without adequate time and effort documentation, there is an increased risk that payroll costs charged to the federal award are inaccurate or unallowable. The lack of supporting records may result in questioned costs related to unsupported salary expenditures. Questioned Costs: None Recommendation: We recommend that the entity: • Implement and enforce policies requiring Personal Activity Reports or an equivalent method that meets 2 CFR 200.430. • Train employees and supervisors responsible for documenting and approving time charged to federal programs. • Maintain documentation that accurately reflects actual time worked on federal awards.

Audit Finding 2024-006 – Noncompliance with Prevailing Wage Requirements Identification of the Federal Program: Education Stabilization Funds; Assistance Listing Number 84.425; Year 2024 Criteria: Under prevailing wage requirements applicable to this program (e.g., Davis Bacon Act, 40 U.S.C. 3141–3148, and 2 CFR 200.327 for procurement), contractors and subcontractors performing construction work must: • Pay laborers and mechanics no less than the locally prevailing wage rates as determined by the U.S. Department of Labor (Wage Determinations). • Submit certified payrolls weekly, signed by an authorized representative, in compliance with 29 CFR 5.5(a)(3). • Maintain adequate documentation supporting labor classifications, wage rates, and hours worked. Condition: During our testing of prevailing wage compliance for the outside class structure project, we identified prevailing wage rate clauses were not included in the contract and we could not verify that certified payrolls for compliance with the applicable wage determination were submitted. Context: Documentation was not maintained for prevailing wage support of projects tested. Cause: The District has had vacancies in certain positions that are key parts of the District's control processes which led to the District not maintaining proper documentation. Effect or Potential Effect: Failure to comply with required prevailing wage laws may result in: • Workers being underpaid; • The federal awarding agency requiring back‑wage restitution; • The entity being subject to enforcement actions or questioned costs. Questioned Costs: None Recommendation: We recommend that the entity: • Strengthen internal controls to ensure all contractors adhere to applicable wage determinations. • Require consistent and documented review of weekly certified payrolls. • Obtain restitution for identified underpayments, if applicable. • Provide training to staff overseeing construction and contractor compliance.