Finding Text
2024-001 – Special Tests and Provisions – Wage Rate Requirements
Criteria: Certified payroll records should be submitted by the contractor each week as required
by the Wage Rate Requirements.
Conditions: The District contracted with a consulting engineering firm to oversee the
contractor’s work, including compliance with Federal requirements. Neither the Consultant, nor
the District requested certified payroll records from the Contractor as work progressed, and the
Contractor did not prepare those certified payroll reports, as required by the Wage Rate
Requirements.
Cause: This appears to be caused by vague language in the agreements with both project
management engineering firm, and the Contractor regarding the federal requirements needed to
be followed. Additionally, the District did not explicitly include the Wage Rate Requirements as
part of their oversight of the Contractor’s compliance with federal requirements.
Effect: As a result, we were unable to test whether the District complied with the Wage Rate
Requirements.
Context: As indicated previously, this appears to be an isolated instance regarding this contract,
as other federal award programs tested in the current and previous years have included the proper
language in the contracts, and evidence observed indicates that the Wage Rate Requirements
were followed in those other instances. Once notified of the lack of oversight, the District worked
to include amendments to its agreements, and make assignments to ensure Wage Rate
Requirement are followed on any current and future contracts. There was no similar finding in
prior years or in other federal programs tested.
Recommendation: We recommended the District ensure agreements with contractors and
agreements with oversight engineering firms include explicit language regarding Wage Rate
Requirements, and assign individuals with responsibility for ensuring such oversight activities
take place.
Corrective action plan – The District’s response to the finding is included in the corrective action
plan, which can be found on the following page.