FA 2024-001 Internal Controls over Wage Rate Requirements
Compliance Requirement: Special Tests and Provisions
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Education
Pass-Through Entity: Georgia Department ...
FA 2024-001 Internal Controls over Wage Rate Requirements
Compliance Requirement: Special Tests and Provisions
Internal Control Impact: Significant Deficiency
Compliance Impact: Nonmaterial Noncompliance
Federal Awarding Agency: U.S. Department of Education
Pass-Through Entity: Georgia Department of Education
Assistance Listing Number and Title: COVID-19 - 84.425U - American Rescue Plan Elementary
and Secondary School Emergency Relief Fund
Federal Award Number: S425U210012 (Year: 2022)
Questioned Costs: None identified
Description: A review of construction-related expenditures charged to
the Elementary and Secondary School Emergency Relief
Fund program revealed that the School District's internal
control procedures were not operating to ensure that
Wage Rate Requirements were followed appropriately.
Corrective Action Plans: The Meriwether County School District is committed to maintaining
full compliance with the Davis-Bacon Act and related Federal
wage requirements for all construction projects funded with
Federal dollars. To ensure compliance, we are implementing
clear, documented procedures to verify that all construction-
related contracts include the appropriate wage provisions and
that certified payroll records are submitted weekly and in a
timely manner by all contractors and subcontractors. The
following steps outline how the district will develop, implement,
and monitor these procedures: Development and Implementation
Procedures:
1. Contract Template Updates-All standard construction contract
templates will be updated to include Davis-Bacon prevailing
wage rate requirements, certified payroll provisions, and
enforcement language.
2. Inclusion in Bid Documents and RFP's-All bid solicitations
and RFPs for federally funded construction projects will
explicitly reference the applicable Federal wage determinations
and required payroll documentation.
3. Pre-Award Contractor Communication-Contractors will be
notified in writing of their obligations under the Davis-Bacon
Act during the bid process and again at contract award.
4. Pre-Construction Orientation-Pre-construction meetings
will be held with contractors and subcontractors to review
Davis-Bacon requirements, wage determinations, and payroll
submission expectations.
1. Certified Payroll Collection-Contractors will be required to
submit certified payrolls weekly for each week of work
performed. A checklist and calendar will be maintained by the
project manager to track submissions.
2. Payroll Verification Process-Submitted certified payrolls will be
reviewed for completeness, accuracy, and compliance with wage
rates. Spot checks (e.g., worker interviews or site visits) will be
conducted periodically.
3. Centralized Document Storage-All certified payrolls and
compliance records will be stored in a centralized, secure digital
file system accessible by authorized district staff and available
for audit and federal review.
4. Compliance Reporting and Follow-up-Any instances of
non-compliance will be documented and addressed promptly.
Corrective actions may include warnings, payment withholdings
or notification to oversight agencies.
5. Internal Audits and Staff Training-The district's Federal
Programs Director will conduct internal quarterly audits as
necessary when Federal funds are being used to verify proper
procedures are being followed, and ongoing training will be
provided to staff involved in procurement, contracting, and
facilities management.
By implementing these procedures, the district will ensure
that all federally funded construction contracts fully comply
with applicable wage law and that payroll records are collected,
reviewed, and maintained in a timely and transparent manner.
Regular monitoring and staff accountability will help ensure
continued legal compliance and project integrity.
Estimated Completion Date: June 30, 2025
Contact Person: Carrie Chambers, Federal Programs Director
Telephone: 706-441-0601
Email: carrie.chambers@mcssga.org