Finding 1215763 (2024-004)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2026-05-28
Audit: 402417
Organization: Ware County, Georgia (GA)

AI Summary

  • Core Issue: The construction contract lacked required clauses for prevailing wage rates, violating federal compliance standards.
  • Impacted Requirements: Non-compliance with 2 CFR 200.303(a) and 40 USC 3141-3147 regarding wage rate provisions for federally funded projects.
  • Recommended Follow-Up: Management plans to create and enforce policies ensuring all future contracts include prevailing wage rate clauses.

Finding Text

2024-004 Wage Rate Requirements - Contract Language ALN and Title: 20.106 - Airport Improvement Program Federal Agency: U.S. Department of Transportation Pass Through Entity: Georgia Department of Transportation Identifying Number: 313SBGP0582023 Award Year: 2023 Special Tests and Provisions-Wage Rate Requirements Criteria or Specific Requirement - 2 CFR 200.303(a) requires non-Federal entities expending Federal awards to establish and maintain effective internal controls over compliance with Federal statues, regulations, and the terms and conditions of Federal awards. All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141-3144, 3146, and 3147. Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR Part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). (29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); 0MB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Condition - Required prevailing wage rate clauses were not included in the contract or subcontract. Cause of Condition -The County was not aware the prevailing wage rate clauses were required to be include in the construction contract. Effect of Condition - The contract was not in compliance and did not contain the language that notified the contractor that prevailing wages were required under the contract. Questioned Costs - Undetermined Response of Management - Management concurs with this finding and will develop and implement policies to ensure that contracts and subcontracts with contractors or subcontractors working on projects financed by federal assistance funds contain prevailing wage rate clauses.

Corrective Action Plan

IC 2024-004 Wage Rate Requirements - Contract Language Required prevailing wage rate clauses were not included in the contract or subcontract. a) We concur with IC 2024-004 that the required language was not included in the contract or subcontract. b) Management concurs with this finding. We will work to develop policies and procedures for ensuring that contracts subject to the Wage Rate Requirements include in the contract language the required prevailing wage rate clauses in accordance with the Uniform Guidance. James Shubert, County Manager and Beverly York, Senior Accounting Supervisor, are responsible for the corrective action process and anticipate resolution by June 30, 2025 .

Categories

Matching / Level of Effort / Earmarking Special Tests & Provisions

Other Findings in this Audit

  • 1215764 2024-005
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
20.106 AIRPORT IMPROVEMENT PROGRAM, INFRASTRUCTURE INVESTMENT AND JOBS ACT PROGRAMS, AND COVID-19 AIRPORTS PROGRAMS $1.03M
21.032 COVID-19; LOCAL ASSISTANCE AND TRIBAL CONSISTENCY FUND $734,630
97.036 DISASTER GRANTS - PUBLIC ASSISTANCE (PRESIDENTIALLY DECLARED DISASTERS) $508,517
21.027 COVID-19; CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $442,132
93.045 SPECIAL PROGRAMS FOR THE AGING, TITLE III, PART C, NUTRITION SERVICES $79,319
16.922 EQUITABLE SHARING PROGRAM $74,909
16.575 CRIME VICTIM ASSISTANCE $71,467
14.228 COMMUNITY DEVELOPMENT BLOCK GRANTS/STATE'S PROGRAM AND NON-ENTITLEMENT GRANTS IN HAWAII $15,000
97.042 EMERGENCY MANAGEMENT PERFORMANCE GRANTS $2,108