Finding 22642 (2022-006)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-11-27

AI Summary

  • Core Issue: The District failed to include required wage rate provisions in all tested construction contracts.
  • Impacted Requirements: Noncompliance with 2 CFR Part 176 and 200.326, which mandate certified payroll submissions from contractors.
  • Recommended Follow-Up: Ensure future contracts include necessary wage provisions and require certified payroll submissions to comply with the Davis Bacon Act.

Finding Text

2022-006 Special Provisions ? Wage Rate Requirements Federal agency: U.S. Department of Education Federal program name: Education Stabilization Fund Assistance Listing Number: 84.425D and 84.425U Pass-Through Agency: Minnesota Department of Education Pass-Through Number(s): S425C220015, S425D220045, and S425C220045 Award Period: July 1, 2021 - June 30, 2022 Type of Finding: ? Material Weakness in Internal Control over Compliance and Material Noncompliance Criteria or Specific Requirement: Per 2 CFR Part 176, Subpart C and 2 CFR section 200.326, the District shall include in their construction contracts subject to the wage requirements a special provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payments). Condition: During special provisions testing, it was noted that for 3 of 3 contractors tested that the required wage rate requirements were not included and the District did not require the contractors to submit certified payments. Questioned Costs: Not determinable. Context: 3 of 3 contracts tested did not follow proper wage requirements. Cause: Oversight. Effect: Lack of proper controls and noncompliance with wage rate requirements could result in the District doing business with contractors that are not paying laborer or mechanics prevailing wage rates. Repeat Finding: No. Recommendation: We recommend that the District consider any contracts for capital expenditures for applicability of Davis Bacon Act wage rate requirements prior to awarding the project and entering into the contract. If it is determined that wage rate requirements apply, the District should ensure the required provision is included in the applicable contracts and then the District also needs to require the applicable contractors to submit certified payrolls during the time of the projects. Views of Responsible Official: There is no disagreement with the finding.

Categories

Internal Control / Segregation of Duties Material Weakness Special Tests & Provisions

Other Findings in this Audit

  • 22631 2022-004
    Material Weakness
  • 22632 2022-005
    Significant Deficiency
  • 22633 2022-004
    Material Weakness
  • 22634 2022-005
    Significant Deficiency
  • 22635 2022-004
    Material Weakness
  • 22636 2022-005
    Significant Deficiency
  • 22637 2022-004
    Material Weakness
  • 22638 2022-005
    Significant Deficiency
  • 22639 2022-004
    Material Weakness
  • 22640 2022-005
    Significant Deficiency
  • 22641 2022-006
    Material Weakness
  • 22643 2022-006
    Material Weakness
  • 599073 2022-004
    Material Weakness
  • 599074 2022-005
    Significant Deficiency
  • 599075 2022-004
    Material Weakness
  • 599076 2022-005
    Significant Deficiency
  • 599077 2022-004
    Material Weakness
  • 599078 2022-005
    Significant Deficiency
  • 599079 2022-004
    Material Weakness
  • 599080 2022-005
    Significant Deficiency
  • 599081 2022-004
    Material Weakness
  • 599082 2022-005
    Significant Deficiency
  • 599083 2022-006
    Material Weakness
  • 599084 2022-006
    Material Weakness
  • 599085 2022-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
32.009 Emergency Connectivity Fund Program $106,687
84.027 Special Education_grants to States $99,286
84.010 Title I Grants to Local Educational Agencies $87,117
84.358 Rural Education $50,783
10.553 School Breakfast Program $45,485
93.323 Epidemiology and Laboratory Capacity for Infectious Diseases (elc) $34,566
21.027 Coronavirus State and Local Fiscal Recovery Funds $26,348
10.555 National School Lunch Program $13,551
84.367 Improving Teacher Quality State Grants $13,377
84.181 Special Education-Grants for Infants and Families $9,000
84.425 Education Stabilization Fund $3,846
84.048 Career and Technical Education -- Basic Grants to States $2,603