Finding 1218928 (2025-003)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-06-25
Audit: 404978
Organization: University of Guam (GU)

AI Summary

  • Core Issue: The University failed to receive certified payrolls on time from contractors for 3 out of 8 samples tested.
  • Impacted Requirements: This violates 29 CFR 5.5(a)(3), which mandates weekly certified payroll submissions for Davis-Bacon Act work.
  • Recommended Follow-Up: The University should create and enforce internal controls to ensure timely receipt of certified payrolls moving forward.

Finding Text

Finding No.: 2025-003 Federal Agency: U.S. Department of Commerce AL Program: 11.307 Economic Adjustment Assistance Federal Award No.: 07 79 07557 Area: Special Tests and Provisions – Wage Rate Requirements Criteria: 29 CFR 5.5(a)(3) requires weekly submission by contractor or subcontractor of certified payrolls for each week in which any Davis-Bacon Act- or Related Acts-covered work is performed, to the applicant, sponsor, owner, or other entity, as the case may be, that maintains such records, for transmission to the federal agency. Condition: For 3 out of 8 samples tested, the University lacked procedures and controls over timely receipt of certified payroll submissions from the prime contractor and subcontractors. Cause: During the first half of fiscal year 2025, the University did not implement formal procedures to require timely submission of certified payroll from contractors and subcontractors. Effect or potential effect: The University was unable to demonstrate receipt of certified payroll during fiscal year 2025. Questioned costs: $0 Context: For three invoices, which contained 12 certified payroll weeks, we were unable to verify that certified payrolls were received timely by the University. Identification as a repeat finding: Finding No. 2024-004 Recommendation: The University should establish and implement effective internal control to comply with the requirements of 29 CFR.5.5. Views of responsible officials: The University agrees with the finding. See Corrective Action Plan. Conclusion: The views of responsible officials do not indicate disagreement with our finding.

Corrective Action Plan

Finding NO. 2025-003 Wage Rate Requirements View of the University of Guam and Corrective Action Plan: During the first half of fiscal year 2025, the University was in the process of implementing corrective actions related to the prior-year finding. While procedures were in place to address the requirements, improvements to the retention of certified payroll documentation and related compliance support were still being implemented during the period under review. The University's Capital Projects team continues to monitor certified payroll submissions from the Contractor and applicable Subcontractors. Through ongoing coordination with the Contractor, the University has strengthened its oversight procedures to help ensure certified payroll documentation is obtained, reviewed, and retained in accordance with applicable requirements. The University will continue to enhance its monitoring and documentation practices as part of its ongoing corrective action efforts. Name of Contact Person: Zenon Belanger, Interim Director, Facilities Management and Services Proposed Completion date: Ongoing

Categories

Special Tests & Provisions Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1218927 2025-002
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.063 FEDERAL PELL GRANT PROGRAM $9.99M
10.766 COMMUNITY FACILITIES LOANS AND GRANTS $8.90M
11.307 ECONOMIC ADJUSTMENT ASSISTANCE $7.87M
12.300 BASIC AND APPLIED SCIENTIFIC RESEARCH $3.94M
47.083 INTEGRATIVE ACTIVITIES $3.23M
10.203 PAYMENTS TO AGRICULTURAL EXPERIMENT STATIONS UNDER THE HATCH ACT $2.38M
84.268 FEDERAL DIRECT STUDENT LOANS $2.26M
10.511 SMITH-LEVER EXTENSION FUNDING $1.98M
21.029 CORONAVIRUS CAPITAL PROJECTS FUND $1.76M
11.417 SEA GRANT SUPPORT $1.74M
59.037 SMALL BUSINESS DEVELOPMENT CENTERS $1.27M
93.307 MINORITY HEALTH AND HEALTH DISPARITIES RESEARCH $733,299
10.025 ANIMAL DISEASE AND ANIMAL CARE $657,598
93.632 UNIVERSITY CENTERS FOR EXCELLENCE IN DEVELOPMENTAL DISABILITIES EDUCATION, RESEARCH, AND SERVICE $621,964
84.047 TRIO UPWARD BOUND $502,379
93.310 TRANS-NIH RESEARCH SUPPORT $480,970
84.031 HIGHER EDUCATION INSTITUTIONAL AID $471,303
10.308 RESIDENT INSTRUCTION, AGRICULTURE, AND FOOD SCIENCE FACILITIES AND EQUIPMENT GRANTS $465,976
84.033 FEDERAL WORK-STUDY PROGRAM $424,234
84.044 TRIO TALENT SEARCH $419,284
15.805 ASSISTANCE TO STATE WATER RESOURCES RESEARCH INSTITUTES $391,161
15.820 NATIONAL AND REGIONAL CLIMATE ADAPTATION SCIENCE CENTERS $384,982
84.042 TRIO STUDENT SUPPORT SERVICES $374,969
94.006 AMERICORPS STATE AND NATIONAL 94.006 $374,414
93.391 ACTIVITIES TO SUPPORT STATE, TRIBAL, LOCAL AND TERRITORIAL (STLT) HEALTH DEPARTMENT RESPONSE TO PUBLIC HEALTH OR HEALTHCARE CRISES $366,766
81.049 OFFICE OF SCIENCE FINANCIAL ASSISTANCE PROGRAM $363,376
15.808 U.S. GEOLOGICAL SURVEY RESEARCH AND DATA COLLECTION $356,643
12.002 PROCUREMENT TECHNICAL ASSISTANCE FOR BUSINESS FIRMS $351,345
47.050 GEOSCIENCES $345,591
10.028 WILDLIFE SERVICES $344,808
93.251 EARLY HEARING DETECTION AND INTERVENTION $324,679
10.561 STATE ADMINISTRATIVE MATCHING GRANTS FOR THE SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM $286,476
10.237 FROM LEARNING TO LEADING: CULTIVATING THE NEXT GENERATION OF DIVERSE FOOD AND AGRICULTURE PROFESSIONALS $282,415
10.937 PARTNERSHIPS FOR CLIMATE-SMART COMMODITIES $274,972
93.434 EVERY STUDENT SUCCEEDS ACT/PRESCHOOL DEVELOPMENT GRANTS $264,289
21.027 CORONAVIRUS STATE AND LOCAL FISCAL RECOVERY FUNDS $259,728
11.463 HABITAT CONSERVATION $223,610
93.612 NATIVE AMERICAN PROGRAMS $214,535
10.215 SUSTAINABLE AGRICULTURE RESEARCH AND EDUCATION $210,864
93.787 TITLE V SEXUAL RISK AVOIDANCE EDUCATION PROGRAM (DISCRETIONARY GRANTS) $205,826
43.008 OFFICE OF STEM ENGAGEMENT (OSTEM) $199,656
84.425 EDUCATION STABILIZATION FUND $186,470
15.615 COOPERATIVE ENDANGERED SPECIES CONSERVATION FUND $183,592
12.632 DEPARTMENT OF WAR ENERGY, INSTALLATIONS, AND ENVIRONMENT INNOVATION PROGRAMS $170,677
93.464 ACL ASSISTIVE TECHNOLOGY $155,737
84.032 FEDERAL FAMILY EDUCATION LOANS $146,421
11.431 CLIMATE AND ATMOSPHERIC RESEARCH $141,998
84.325 SPECIAL EDUCATION - PERSONNEL DEVELOPMENT TO IMPROVE SERVICES AND RESULTS FOR CHILDREN WITH DISABILITIES $136,758
84.007 FEDERAL SUPPLEMENTAL EDUCATIONAL OPPORTUNITY GRANTS $131,800
93.314 EARLY HEARING DETECTION AND INTERVENTION INFORMATION SYSTEM (EHDI-IS) SURVEILLANCE PROGRAM $130,988
93.243 SUBSTANCE ABUSE AND MENTAL HEALTH SERVICES PROJECTS OF REGIONAL AND NATIONAL SIGNIFICANCE $113,997
10.514 EXPANDED FOOD AND NUTRITION EDUCATION PROGRAM $109,757
10.170 SPECIALTY CROP BLOCK GRANT PROGRAM - FARM BILL $104,732
15.605 SPORT FISH RESTORATION $96,992
93.433 ACL NATIONAL INSTITUTE ON DISABILITY, INDEPENDENT LIVING, AND REHABILITATION RESEARCH $95,782
12.017 READINESS AND ENVIRONMENTAL PROTECTION INTEGRATION (REPI) PROGRAM $94,905
93.898 CANCER PREVENTION AND CONTROL PROGRAMS FOR STATE, TERRITORIAL AND TRIBAL ORGANIZATIONS $92,402
10.727 INFLATION REDUCTION ACT URBAN & COMMUNITY FORESTRY PROGRAM $86,802
10.331 GUS SCHUMACHER NUTRITION INCENTIVE PROGRAM $86,526
93.945 ASSISTANCE PROGRAMS FOR CHRONIC DISEASE PREVENTION AND CONTROL $74,432
15.875 ECONOMIC, SOCIAL, AND POLITICAL DEVELOPMENT OF THE TERRITORIES $73,582
10.680 FOREST HEALTH PROTECTION $72,244
66.046 CLIMATE POLLUTION REDUCTION GRANTS $70,379
10.310 AGRICULTURE AND FOOD RESEARCH INITIATIVE (AFRI) $70,051
11.012 INTEGRATED OCEAN OBSERVING SYSTEM (IOOS) $68,590
15.926 AMERICAN BATTLEFIELD PROTECTION $64,301
10.327 COMMON BEAN PRODUCTIVITY RESEARCH FOR GLOBAL FOOD SECURITY COMPETITIVE PROGRAM $62,400
15.945 COOPERATIVE RESEARCH AND TRAINING PROGRAMS €“ RESOURCES OF THE NATIONAL PARK SYSTEM $48,398
93.870 MATERNAL, INFANT AND EARLY CHILDHOOD HOME VISITING GRANT $47,528
47.049 MATHEMATICAL AND PHYSICAL SCIENCES $46,336
10.683 NATIONAL FISH AND WILDLIFE FOUNDATION $46,101
10.500 COOPERATIVE EXTENSION SERVICE $41,432
93.297 TEENAGE PREGNANCY PREVENTION PROGRAM $40,998
66.309 SURVEYS, STUDIES, INVESTIGATIONS, TRAINING AND SPECIAL PURPOSE ACTIVITIES RELATING TO ENVIRONMENTAL JUSTICE $40,977
10.202 COOPERATIVE FORESTRY RESEARCH $39,137
47.075 SOCIAL, BEHAVIORAL, AND ECONOMIC SCIENCES $38,424
12.901 MATHEMATICAL SCIENCES GRANTS $34,654
10.707 RESEARCH JOINT VENTURE AGREEMENT $34,578
84.379 TEACHER EDUCATION ASSISTANCE FOR COLLEGE AND HIGHER EDUCATION GRANTS (TEACH GRANTS) $33,477
10.322 DISTANCE EDUCATION GRANTS FOR INSTITUTIONS OF HIGHER EDUCATION IN INSULAR AREAS $25,065
10.652 FORESTRY RESEARCH $24,238
66.716 RESEARCH, DEVELOPMENT, MONITORING, PUBLIC EDUCATION, OUTREACH, TRAINING, DEMONSTRATIONS, AND STUDIES $23,764
10.515 RENEWABLE RESOURCES EXTENSION ACT $22,340
10.950 AGRICULTURAL STATISTICS REPORTS $21,692
11.482 CORAL REEF CONSERVATION PROGRAM $21,226
45.149 PROMOTION OF THE HUMANITIES DIVISION OF PRESERVATION AND ACCESS $16,951
10.328 FOOD SAFETY OUTREACH PROGRAM $14,426
10.304 FOOD AND AGRICULTURE DEFENSE INITIATIVE (FADI) $12,982
47.070 COMPUTER AND INFORMATION SCIENCE AND ENGINEERING $12,882
11.473 OFFICE FOR COASTAL MANAGEMENT $11,360
15.657 ENDANGERED SPECIES RECOVERY IMPLEMENTATION $10,555
47.076 STEM EDUCATION (FORMERLY EDUCATION AND HUMAN RESOURCES) $10,356
93.397 CANCER CENTERS SUPPORT GRANTS $5,168
10.311 BEGINNING FARMER AND RANCHER DEVELOPMENT PROGRAM $4,698
10.684 INTERNATIONAL FORESTRY PROGRAMS $4,651
45.129 PROMOTION OF THE HUMANITIES FEDERAL/STATE PARTNERSHIP $3,550
10.678 FOREST STEWARDSHIP PROGRAM $2,871
10.664 COOPERATIVE FORESTRY ASSISTANCE $2,502
10.329 CROP PROTECTION AND PEST MANAGEMENT COMPETITIVE GRANTS PROGRAM $1,850
10.924 CONSERVATION STEWARDSHIP PROGRAM $1,459
10.912 ENVIRONMENTAL QUALITY INCENTIVES PROGRAM $331
15.631 PARTNERS FOR FISH AND WILDLIFE $67
10.525 FARM AND RANCH STRESS ASSISTANCE NETWORK COMPETITIVE GRANTS PROGRAM $-1,497