Finding Text
Environmental Protection Agency Direct Program: Congressionally Mandated Projects - 66.202 Award Year: 2023 Criteria or Specific Requirement - Davis-Bacon Act Per 2 CFR 200.303, the non-Federal entities receiving federal awards (i.e., auditee management) should establish and maintain internal control design to reasonably ensure compliance with Federal statutes, regulations, and the terms and conditions of the Federal Award. Per the Environmental Protection Agency Congressionally Mandated Project's Programmatic Conditions, non-Federal entities that receive the federal award are required to maintain adequate records to demonstrate compliance with compensation requirements. Condition: During our test work over the Congressionally Mandated Projects grant, we noted the Board of Public Utilities did not obtain Statements of Compliance/Certified Payrolls from the applicable vendors in timely manner. Cause: The Board of Public Utilities' controls to ensure that the Statements of Compliance/Certified Payrolls are submitted timely were not operating effectively. Effect or Potential Effect: The Board of Public Utilities was unable to demonstrate compliance with Davis-Bacon wage rate requirements. Questioned Costs - None noted. Context: For all weeks selected for testing, the subcontractor did not submit the required Statements of Compliance within a timely manner. The sample was not intended to be, and was not, a statistically valid sample. Identification of Prior Year Finding: N/A Recommendation: We recommend that the Board of Public Utilities implement a process that includes tracking the timely submission of Statements of Compliance and documenting review of the Statements once received. Views of Responsible Official and Planned Corrective Action: Management agrees with finding. See corrective action plan.