CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE
Clarkston School District No. J250-185
September 1, 2022 through August 31, 2023
This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Cod...
CORRECTIVE ACTION PLAN FOR FINDINGS REPORTED UNDER UNIFORM GUIDANCE
Clarkston School District No. J250-185
September 1, 2022 through August 31, 2023
This schedule presents the corrective action the District is planning to take for findings included in this report in accordance with Title 2 U.S. Code of Federal Regulations (CFR) Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance).
Finding ref number:
2023-001 Finding caption:
The District did not have adequate internal controls for ensuring compliance with federal wage rate requirements.Name, address, and telephone of District contact person:
Randy Lybyer, Director of Financial Services
1294 Chestnut St
Clarkston, WA 99403-0070
(509) 769-5538
Corrective action the auditee plans to take in response to the finding:
The Clarkston School District welcomes the State Auditor’s Office review of federal wage rate requirements in our use of federal funds for the Grantham Elementary HVAC construction project. We agree with the auditor’s findings that our internal control structure was inadequate to ensure compliance with wage rate requirements.
The following internal control processes have been implemented effective May 2023.
1. Identify public works projects and other contracts that require compliance with federal wage rate requirements through regular communication with District administrators and maintenance/operations management staff.
2. Complete and enhance the Districts contracts checklists for agreements entered into with contractors, agencies or purchasing cooperatives for the contraction of public works projects.
3. Consult with ESD, OSPI, and SAO to assure proper and complete terms are included in agreement documentation.
4. Collect and review weekly Certified Payroll Reports from contractors and subcontractors upon commencement of applicable projects until completion.
5. Confirmation of receipt and review of Certified Payroll Reports shall be verified prior to vendor payments.
A contributing factor to this internal control weakness was turnover in key compliance positions during the time the contracts were being processed and construction was commencing.
This finding effectively carried over from the prior audit period September 1, 2021 through August 31, 2022, to the current audit period September 1, 2022 through August 31, 2023. The final invoices for this project were received by the District in March 2023. The finding was originally identified after March 2023 and responded to in May 2023. The opportunity had passed for the District to include prevailing wage clauses in the contract and collect weekly certified payroll from the contractor. The internal control processes listed above were put into place after the project was completed.
Anticipated date to complete the corrective action: Immediately