FA 2025-01 Internal Controls over Wage Rate Requirements Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Repeat of Prior Year Finding: Description: Special Tests and Provision...
FA 2025-01 Internal Controls over Wage Rate Requirements Compliance Requirement: Internal Control Impact: Compliance Impact: Federal Awarding Agency: Pass-Through Entity: Assistance Listing Number and Title: Federal Award Number: Repeat of Prior Year Finding: Description: Special Tests and Provisions Material Weakness Material Noncompliance U.S. Department of Education Georgia Department of Education COVID-19 - 84.425U - American Rescue Plan Elementary and Secondary School Emergency Relief Fund S425U210012 (Year: 2022) FA 2024-001 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 RFPs 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. Monitoring and Enforcement Procedures 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 or federal review. 4. Compliance Reporting and Follow-Up Any instances of non-compliance will be documented and addressed promptly. Corrective actions may include written 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 laws 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