Finding 1160606 (2024-009)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-10-16

AI Summary

  • Core Issue: The College failed to obtain and review required weekly certified payrolls from contractors and subcontractors as mandated by the Davis-Bacon Act.
  • Impacted Requirements: This oversight violates 29 CFR section 5.5 and 2 CFR 200.303, which require compliance with wage rate laws and internal controls for federal awards.
  • Recommended Follow-Up: Strengthen processes to ensure timely receipt, review, and documentation of certified payrolls to achieve compliance.

Finding Text

Criteria or specific requirement: In accordance with 29 CFR section 5.5, Davis-Bacon Act (currently known as Wage Rate Requirements) requires that all contractors and subcontractors performing on federal contracts (and contractors or subcontractors performing on federally assisted contracts under the related Acts) in excess of $2,000 pay their laborers and mechanics not less than the prevailing wage rates and fringe benefits listed in the contract’s Davis-Bacon wage determination for corresponding classes of laborers and mechanics employed on similar projects in the area. Each covered contractor and subcontractor must, on a weekly basis, provide the entity with a copy of all payrolls providing the information listed under 29 CFR 5.5(a)(3)(ii)(B) for the preceding weekly payroll period. The contractor, subcontractor or authorized officer or employee of the contractor or subcontractor who supervises the payment of wages must sign the weekly payroll and certification statement. Further Uniform Guidance 2 CFR 200.303, non-federal entities receiving federal awards are required to establish and maintain internal controls designed to reasonably ensure compliance with federal laws, regulations, and program compliance requirements. Condition: The College did not receive or review the required weekly certified payrolls from subcontractors and contractors. Questioned Costs: None. Context: During our testing of two contracts with contractors/subcontractors that were subject to the Davis-Bacon wage rate requirements the College did not obtain the certified payrolls from the contactors/subcontractors and document their review and approval of them. Cause: The College was not aware of the requirement to obtain and review weekly certified payrolls prior to processing the vendor payment. Effect: The College was not in compliance with the Department of Commerce’s wage rate requirements under special tests and provisions. Repeat Finding: No. Recommendation: We recommend the College strengthen its process for obtaining certified payrolls and implement procedures to ensure timely receipt, review, and documentation of these reports. Views of responsible officials: There is no disagreement with the finding.

Corrective Action Plan

Economic Development Cluster – Assistance Listing No. 11.307 Recommendation: We recommend the College strengthen its process for obtaining certified payrolls and implement procedures to ensure timely receipt, review, and documentation of these reports. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: A process workflow has been developed to ensure that the certified payroll reports are requested and reviewed monthly prior to paying the monthly invoices or pay applications to the contractor. Name(s) of the contact person(s) responsible for corrective action: Saundra Buchanan and Sam Draper Planned completion date for corrective action plan: 7/28/2025

Categories

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

Other Findings in this Audit

  • 1160585 2024-002
    Material Weakness Repeat
  • 1160586 2024-002
    Material Weakness Repeat
  • 1160587 2024-002
    Material Weakness Repeat
  • 1160588 2024-002
    Material Weakness Repeat
  • 1160589 2024-003
    Material Weakness Repeat
  • 1160590 2024-003
    Material Weakness Repeat
  • 1160591 2024-003
    Material Weakness Repeat
  • 1160592 2024-004
    Material Weakness Repeat
  • 1160593 2024-004
    Material Weakness Repeat
  • 1160594 2024-004
    Material Weakness Repeat
  • 1160595 2024-004
    Material Weakness Repeat
  • 1160596 2024-005
    Material Weakness Repeat
  • 1160597 2024-005
    Material Weakness Repeat
  • 1160598 2024-005
    Material Weakness Repeat
  • 1160599 2024-005
    Material Weakness Repeat
  • 1160600 2024-006
    Material Weakness Repeat
  • 1160601 2024-006
    Material Weakness Repeat
  • 1160602 2024-006
    Material Weakness Repeat
  • 1160603 2024-006
    Material Weakness Repeat
  • 1160604 2024-007
    Material Weakness Repeat
  • 1160605 2024-008
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 Federal Pell Grant Program $1.07M
84.268 Federal Direct Student Loans $694,147
93.575 Child Care and Development Block Grant $655,375
11.307 Covid-19 Workforce Expansion $493,391
11.617 National Institute of Standards and Technology Congressionally Identified Projects Program (cipp) $428,668
84.031 Building Equitable Access and Success Project (ease) $379,133
84.425 Covid-19: Higher Education Emergency Relief Funds, Student Aid - Arp-Esser $216,080
17.259 Youth Formula $196,816
17.258 Adult Formula $182,368
84.002 Adult Education - Basic Grants to States $158,002
15.228 Blm Fuels Management and Community Fire Assistance Program Activities $149,505
47.076 Education and Human Resources $130,679
17.278 Dislocated Worker Formula $116,071
59.037 Small Business Development Center $104,789
21.027 Covid-19-Esol Fiscal Recovery Funds $89,517
21.027 Covid-19 Prosperity 10k Fiscal Recovery Funds $81,066
17.258 Adult - Manufacturing Trades $59,994
45.310 Library Services and Technology Act $43,562
84.007 Federal Supplemental Educational Opportunity Grants $42,950
84.048 Nontraditional Perkins - Career and Technical Education $19,400
21.027 Covid-19 State and Local Fiscal Recovery Funds $8,530
84.033 Federal Work-Study Program $5,751
45.129 Mini Grant for Rural Libraries $2,234