Finding 1115828 (2024-005)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2024
Accepted
2025-03-28
Audit: 349937
Organization: City of Norfolk (VA)

AI Summary

  • Core Issue: Contracts and subcontracts lacked required prevailing wage rate provisions as mandated by 2 CFR section 200.326.
  • Impacted Requirements: Noncompliance with the Wage Rate Requirements may lead to vendors being unaware of essential program regulations.
  • Recommended Follow-Up: The City should enhance policies to ensure all contracts consistently include necessary wage rate provisions.

Finding Text

Criteria or specific requirement: Per 2 CFR section 200.326, nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. Condition: The contracts and subcontracts did not include the required prevailing wage rate provisions. Context: For all 11 contracts tested, prevailing wage rate clauses were missing in both the contracts or subcontracts. However, the City did obtain certified weekly payrolls from all contractors tested. Questioned costs: Undetermined. Cause: The City failed to adhere to established internal controls over wage rate requirements and related regulations. Effect: Excluding the required prevailing wage rate information in contracts and subcontracts may cause vendors to be uninformed about specific program regulations that apply to the funds they receive. Recommendation: The City should review and enhance its policies and procedures to ensure that all required wage rate provisions are consistently included in contracts and subcontracts. Views of responsible officials: The City agrees with this finding. See separate Corrective Action Plan related to this finding.

Categories

Questioned Costs Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 539385 2024-004
    Significant Deficiency
  • 539386 2024-005
    Significant Deficiency
  • 539387 2024-006
    Significant Deficiency
  • 539388 2024-006
    Significant Deficiency
  • 539389 2024-007
    Significant Deficiency
  • 1115827 2024-004
    Significant Deficiency
  • 1115829 2024-006
    Significant Deficiency
  • 1115830 2024-006
    Significant Deficiency
  • 1115831 2024-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $57.61M
84.010 Title I Grants to Local Educational Agencies $18.85M
84.027 Special Education Grants to States $8.13M
20.205 Highway Planning and Construction $6.40M
93.914 Hiv Emergency Relief Project Grants $5.58M
10.561 State Administrative Matching Grants for the Supplemental Nutrition Assistance Program $5.40M
66.458 Clean Water State Revolving Fund $4.71M
93.778 Medical Assistance Program $4.33M
84.041 Impact Aid $3.39M
93.659 Adoption Assistance $3.09M
93.558 Temporary Assistance for Needy Families $2.97M
14.251 Economic Development Initiative, Community Project Funding, and Miscellaneous Grants $2.90M
93.667 Social Services Block Grant $2.81M
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $2.57M
93.959 Block Grants for Prevention and Treatment of Substance Abuse $2.14M
93.658 Foster Care Title IV-E $1.93M
10.556 Special Milk Program for Children $1.22M
10.558 Child and Adult Care Food Program $994,249
84.287 Twenty-First Century Community Learning Centers $985,560
14.239 Home Investment Partnerships Program $893,069
20.933 National Infrastructure Investments $855,608
93.568 Low-Income Home Energy Assistance $748,634
14.218 Community Development Block Grants/entitlement Grants $726,745
84.424 Student Support and Academic Enrichment Program $722,159
93.596 Child Care Mandatory and Matching Funds of the Child Care and Development Fund $666,363
14.272 National Disaster Resilience Competition $628,813
84.048 Career and Technical Education -- Basic Grants to States $625,242
14.231 Emergency Solutions Grant Program $623,522
10.582 Fresh Fruit and Vegetable Program $622,202
14.238 Shelter Plus Care $598,357
11.307 Economic Adjustment Assistance $540,221
10.559 Summer Food Service Program for Children $521,426
16.575 Crime Victim Assistance $506,741
66.202 Congressionally Mandated Projects $432,642
84.181 Special Education-Grants for Infants and Families $385,261
97.056 Port Security Grant Program $377,447
97.067 Homeland Security Grant Program $366,807
84.173 Special Education Preschool Grants $354,496
93.788 Opioid Str $330,462
21.027 Coronavirus State and Local Fiscal Recovery Funds $319,352
84.013 Title I State Agency Program for Neglected and Delinquent Children and Youth $305,382
93.958 Block Grants for Community Mental Health Services $267,474
84.002 Adult Education - Basic Grants to States $234,712
16.593 Residential Substance Abuse Treatment for State Prisoners $146,989
93.556 Marylee Allen Promoting Safe and Stable Families Program $138,263
97.029 Flood Mitigation Assistance $136,872
93.150 Projects for Assistance in Transition From Homelessness (path) $135,596
16.590 Grants to Encourage Arrest Policies and Enforcement of Protection Orders Program $134,340
97.042 Emergency Management Performance Grants $106,886
16.710 Public Safety Partnership and Community Policing Grants $105,000
16.812 Second Chance Act Reentry Initiative $103,985
16.588 Violence Against Women Formula Grants $97,056
16.738 Edward Byrne Memorial Justice Assistance Grant Program $90,912
93.566 Refugee and Entrant Assistance State/replacement Designee Administered Programs $72,976
16.922 Equitable Sharing Program $57,702
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $56,962
93.472 Title IV-E Prevention Program $56,832
81.128 Energy Efficiency and Conservation Block Grant Program (eecbg) $54,210
93.767 Children's Health Insurance Program $53,078
10.555 National School Lunch Program $51,735
93.674 John H. Chafee Foster Care Program for Successful Transition to Adulthood $47,670
14.889 Choice Neighborhoods Implementation Grants $34,598
20.939 Safe Streets and Roads for All $30,457
84.365 English Language Acquisition State Grants $25,399
16.606 State Criminal Alien Assistance Program $24,160
93.090 Guardianship Assistance $20,978
45.024 Promotion of the Arts Grants to Organizations and Individuals $18,771
20.600 State and Community Highway Safety $16,368
66.466 Geographic Programs - Chesapeake Bay Program $12,580
10.553 School Breakfast Program $11,862
16.540 Juvenile Justice and Delinquency Prevention $9,957
15.904 Historic Preservation Fund Grants-in-Aid $8,680
20.607 Alcohol Open Container Requirements $7,622
93.599 Chafee Education and Training Vouchers Program (etv) $4,034
84.184 School Safely National Activities $4,000
93.645 Stephanie Tubbs Jones Child Welfare Services Program $2,581
15.663 Nfwf-Usfws Conservation Partnership $1,590
16.320 Services for Trafficking Victims $568