Finding Text
Criteria or Specific Requirement Per 2 CFR Part 200 and the ESSER Grant Award Terms & Conditions, the District must comply with the Davis-Bacon Act for construction-related activity. Contractors must submit weekly certified payrolls (29 CFR 5.5(a)(3)(ii)) to demonstrate payment of prevailing wages, and the District must review these payrolls timely prior to approving invoices. Condition During testing the Special Tests and Provisions requirement for the ESSER program, we noted that certified payroll reports were not completed and/or submitted on a timely basis for contractors paid with ESSER funds. The District is required to obtain weekly certified payrolls from contractors and subcontractors performing construction activities to ensure prevailing wage compliance. For the items tested, 11 out of 13 certified payrolls were received between 2–32 weeks late, and in some instances were missing required certifications at the time of payment. Cause The District did not have a formalized process to collect, track, and review certified payrolls weekly. Communication between the contractor and District staff regarding required documentation was inconsistent, and no monitoring log was maintained. Effect or Potential Effect Without timely submission and review of certified payrolls, the District cannot ensure contractors were paid the required prevailing wage rates, increasing the risk of noncompliance with federal requirements. This could result in questioned costs or corrective action required by the State or federal agency. Questioned Costs None Context The District did not obtain timely weekly certified payrolls from contractor. Identification of a Repeat Finding This is a new finding for the fiscal year ended June 30, 2025. Recommendation We recommend the District establish a formal monitoring process for certified payrolls. Views of Responsible Officials For future projects of this nature that are funded with federal dollars the District will implement a written procedure to ensure weekly certified payrolls are obtained, reviewed, and documented prior to payment approval. The District will communicate these requirements to contractors and maintain a monitoring log going forward. See Corrective Action Plan