Audit 400870

2024-004: Highway Planning and Construction – ALN # 20.205, COVID-19 Coronavirus State and Local Fiscal Recovery Funds – ALN # 21.027, COVID-19 Elementary and Secondary School Emergency Relief (ESSER) Fund – ALN # 84.425D, and COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – ALN # 84.425U, Late Filling of Data Collection Form Condition The City did not submit the data collection form for the year ended June 30, 2024 timely. For June 30, 2024 year-end audits, under the requirements in the Uniform Guidance and the Office of Management and Budget (OMB), all entities are required to submit the annual data collection form with the Federal Audit Clearinghouse the earlier of either 30 days after the issuance of the entity’s annual audit or nine months after the entity’s fiscal year-end. Criteria The City is required to submit the annual data collection form with the Federal Audit Clearinghouse the earlier of either 30 days after the issuance of the City’s annual audit or nine months after the City’s fiscal year-end. Cause The data collection form was not filed timely due to the timing of the issuance of the City’s ACFR. Effect The City's form was submitted to the Federal Audit Clearinghouse late, delaying completion of all annual audit requirements for the City. Recommendation Management should take steps to ensure that the form is filed in a timely manner. Repeat Finding Similar condition present in the prior year. See finding 2023-004 in Summary Schedule of Prior Year Audit Findings. View of Responsible Officials and Planned Corrective Action Colonial Heights Public Schools will work with the City to ensure that the annual data collection form was filed on behalf of the school district. City management concurs with this recommendation.

2024-003: COVID-19 Elementary and Secondary School Emergency Relief (ESSER) Fund – ALN #84.425D and COVID-19 American Rescue Plan Elementary and Secondary School Emergency Relief Fund (ARP ESSER) – ALN #84.425U, Special Tests and Provisions – Wage Rate (Material Noncompliance) Condition During our review of one applicable contract for a federally funded project, we noted that the contract did not include the required Wage Rate (Davis Bacon Act) and DOL regulations. Criteria Under the ESSER grant guidelines, nonfederal entities must include in their construction contracts subject to the Davis-Bacon Act a provision that the contractor or subcontractor comply with the Davis-Bacon Act and the DOL regulations. The entities must establish internal controls to ensure that contracts related to federally funded projects are reviewed and contain the required language. Cause The omission of this clause was due to oversight and a lack of controls in place to ensure that the required language was included.Effect The written contract was not in compliance with required disclosures related to the Davis Bacon Act. Recommendation We recommend that a process be put in place that ensures that all contracts related to federally funded projects include necessary DOL regulations. Repeat Finding Similar condition present in the prior year. See finding 2023-003 in Summary Schedule of Prior Year Audit Findings. View of Responsible Officials and Planned Corrective Action The School Board agrees that the Davis Bacon Act was not included in the contract language. However, Colonial Heights Public Schools did not request any reimbursements for wages from the federal funding sources, only materials and supplies. Procedures were put in place, and where the Davis-Bacon Act applied, the contract language was added.