Finding 1224881 (2025-001)

Material Weakness Repeat Finding
Requirement
N
Questioned Costs
-
Year
2025
Accepted
2026-07-29

AI Summary

  • Core Issue: Construction contracts lacked required language on wage rates, risking compliance with federal funding rules.
  • Impacted Requirements: Contractors must pay prevailing wages for projects over $2,000, as mandated by the Department of Labor.
  • Recommended Follow-Up: Ensure all contracts include wage rate clauses and that certified payrolls are submitted and reviewed promptly.

Finding Text

Finding Number: 2025-001 Federal Agency: U.S. Department of Education Cluster/Program(s): Elementary and Secondary School Emergency Relief Assistance Listing Number(s): 84.425D, 84.425U Compliance Requirement: Special Tests and Provisions Type of Finding: Significant Deficiency – Internal Control over Compliance Statement of Condition: Language regarding wage rate requirements was not included in construction contracts. Criteria: 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. Management needs to ensure that all contractors and subcontractors are submitting weekly certified payrolls and verify that they are being paid at least the prevailing wage rates. Cause: Contract documents could not be located and therefore, we were unable to verify the necessary language regarding wage rate requirements was included. Effect: Employees could potentially not be paid prevailing wage rates which could jeopardize grant funding. Recommendation: Management needs to ensure that all construction contracts with contractors in excess of $2,000 have a prevailing wage rate clause and that certified payrolls are received and reviewed in a timely manner. Documentation should be maintained according to all laws, regulations, and policies to demonstrate compliance with established requirements. Questioned Costs: None – certified payroll forms were completed for the project even though the contract language did not specifically require it.

Corrective Action Plan

Management’s Response/Corrective Action Plan: MSAD 15 will update its federal procurement checklist to ensure that all future federally funded construction, alteration, or repair contracts in excess of $2,000 explicitly incorporate Davis-Bacon Act wage rate requirement clauses.

Categories

Special Tests & Provisions Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1224879 2025-001
    Material Weakness Repeat
  • 1224880 2025-001
    Material Weakness Repeat

Programs in Audit

ALN Program Name Expenditures
84.027 Local Entitlement $538,194
84.010 Title 1A Disadvantaged $412,070
10.555 National School Lunch Program $249,414
84.425 COVID-19 - Elementary and Secondary School Emergency Relief III $217,000
84.425 COVID-19 - Summer Learning Enrichment $114,702
10.553 School Breakfast Program $113,222
84.367 Title IIA - Supporting Effective Instruction $96,136
10.555 National School Lunch Program - Donated Commodities $95,756
84.002 Adult Education - Basic Grants to States $58,085
84.358 Title V - Rural and Low Income Schools $18,388
84.173 Preschool Grants $8,812
84.424 Title IV - Student Support and Academic Achievements $7,625
84.425 COVID-19 - Literacy Grant $188