Finding 1191785 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-03-30

AI Summary

  • Core Issue: Construction projects funded by federal money did not comply with the Davis-Bacon Act requirements.
  • Impacted Requirements: Contractors must pay prevailing wages, submit weekly certified payrolls, and post wage determinations at job sites.
  • Recommended Follow-Up: Develop internal controls to ensure compliance with the Davis-Bacon Act for future federal construction projects, including monitoring payroll reports and posting requirements.

Finding Text

Material Weakness: 2025-001 Federal Agency: U.S. Department of Justice Program: COPS School Violence Program Assistance Listing: 16.710 Grant Period: Year Ending June 30, 2025 Condition: Construction projects paid with federal monies did not meet the compliance requirements of the Davis-Bacon Act. Criteria: The Davis-Bacon Act requires that nonfederal entities shall meet certain requirements for the construction, alteration or repair of public buildings or public works in excess of $2,000.00. Any contract entered into must include the locally prevailing wage to be paid to workers including fringe benefits. The contractor is obliged to pay at least the prevailing wage listed in the contract. Contractors are required to pay covered workers weekly and submit weekly certified payrolls to the contracting entity. They are also required to post the applicable Davis-Bacon wage determination along with the Davis-Bacon poster at the job site. Cause: The District did not follow the requirements of the Davis-Bacon Act when expending federal monies on projects. Effect: The District could be liable for paying any additional wages if the contractor did not pay prevailing wage rates to laborers working on the project, or the expenditures could be disallowed for the expenditures that were subject to the Davis-Bacon Act. Recommendation: We recommend the District develop internal controls to meet the requirements of the Davis-Bacon Act that ensure any time federal awards are used on construction that compliance with contracts, including inserting the prevailing wage clauses and ensuring that federal wage rates and fringes are met by an effective monitoring process which includes collecting and reviewing weekly certified payroll reports from the contractor or subcontractor. Also, ensuring that all items are posted at the work site to ensure compliance. District’s Response: The District will develop internal controls to ensure that in the future if federal awards are expended on construction, including projects with labor or installation, that all requirements of the Davis-Bacon Act will be met. Questioned Costs: $ 0

Corrective Action Plan

Elk City Public Schools will ensure that on all future construction contracts that deal with federal awards, requirements of the Davis-Bacon Act will be included. Prevailing wages will be inserted into the language of the contract and shall be signed by contractors and subcontractors. All contracts will also spell out weekly reporting requirements of certified wages paid by contractors and subcontrators. In addition, ECPS will ensure that Davis-Bacon information is posted at all job sites. These policy changes will be implemented immediately and be in place as of October 9, 2025.

Categories

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Programs in Audit

ALN Program Name Expenditures
84.010 TITLE I GRANTS TO LOCAL EDUCATIONAL AGENCIES $651,588
84.027 SPECIAL EDUCATION GRANTS TO STATES $458,613
10.553 SCHOOL BREAKFAST PROGRAM $199,361
84.424 STUDENT SUPPORT AND ACADEMIC ENRICHMENT PROGRAM $192,019
16.710 PUBLIC SAFETY PARTNERSHIP AND COMMUNITY POLICING GRANTS $184,710
84.358 RURAL EDUCATION $100,220
10.555 NATIONAL SCHOOL LUNCH PROGRAM $75,326
84.367 SUPPORTING EFFECTIVE INSTRUCTION STATE GRANTS (FORMERLY IMPROVING TEACHER QUALITY STATE GRANTS) $70,376
97.137 STATE AND LOCAL CYBERSECURITY GRANT PROGRAM TRIBAL CYBERSECURITY GRANT PROGRAM $69,550
84.365 ENGLISH LANGUAGE ACQUISITION STATE GRANTS $64,667
84.173 SPECIAL EDUCATION PRESCHOOL GRANTS $10,012
93.575 CHILD CARE AND DEVELOPMENT BLOCK GRANT $5,921
84.425 EDUCATION STABILIZATION FUND $1,292