Finding Text
Finding 2024-006: Special Tests-Wage Rate Requirements
Federal Agency Name: U.S. Department of Education
Program Name: Education Stabilization Fund ARP ESSER III
Assistance Listing Number: 84.425U
Federal Award Identification: S425D210021
Criteria: OMB 2 CFR Part 200, Appendix XI, Compliance Supplement for Federal Assistance for 84.425U states that ESF used for minor remodeling, renovation or construction contracts that are over $2,000 and use laborers and mechanics must meet Davis-Bacon prevailing wage requirements.
Condition: The District did not have controls in place to properly identify that certified payrolls were obtained for repair contract.
Cause: The District relied on guidance from the contractor that since the project was under $75,000 prevailing wage would not apply. The information was from the Missouri Department of Labor website. However, this does not follow the federal program guidelines when the project was paid for with federal funds.
Effect: The District did not have adequate control in place to ensure that Davis-Bacon prevailing wage requirements were meet.
Questioned costs: $39,970
Context: During testing it was noted that the District used a contractor that may not have paid prevailing wages. No reporting of certified payrolls for the project was obtained.
Recommendation: We recommend that the District review guidance provided by DESE related to each Federal Award.
Response: The administration is new as of July 1, 2024, after the contract was in place and executed. They will make sure additional internal controls are in place to properly and timely review wage rate requirements.