Finding Text
2024-006 Wage Rate Compliance
CFDA Title: Education Stabilization Fund
CFDA Number: 84.425
Federal Award Number: 2024
Federal Agency: U.S. Department of Education
Pass-through Entity: Montana Office of Public Instructions
Condition:
The District did not comply with the wage rate compliance related to the energy efficiency projects for expenditures paid from the Federal Education Stabilization Fund (ESSER)
grant monies.
Criteria:
Section 7007 construction funds, as well as any Section 7002 or 7003(b) funds spent for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Context:
During the testing of significant claims for the ESSER major program related to construction, we noted claims in which there should be contracts and that the prevailing wage rate requirements would apply.
Effect:
Noncompliance with the Wage Rate Requirement for the energy efficiency projects as the contract did not contain the prevailing wage rate requirement and the District did not require weekly certified payrolls for each work in which contract work is performed.
Cause:
The District was not aware of the requirement.
Recommendation:
The District should implement internal controls to determine the federal compliance requirements of all federal funds received. In addition, procedures should be implemented
to ensure any federal funds received in which the Wage Rate Requirement is required the following are implemented:
1. any construction vendor is by contract, and that contract includes the Prevailing
Wage clauses for the contractors and subcontractors
2. the weekly certified payrolls are submitted to the District by the contractor/subcontractor.