Finding 23283 (2022-008)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2023-04-13
Audit: 18647
Organization: Greenwood School District (WI)

AI Summary

  • Core Issue: The District failed to ensure compliance with the Davis-Bacon Act wage rate requirements for construction projects funded by ESSER.
  • Impacted Requirements: Lack of documented review of certified payrolls and absence of necessary contract provisions led to potential noncompliance.
  • Recommended Follow-Up: Implement controls to ensure contracts include required wage provisions and establish monitoring for third-party contractors to verify compliance.

Finding Text

Education Stabilization Fund Wage Rate Requirements Federal Agency: U.S. Department of Education Federal Program Title: Education Stabilization Fund - Elementary and Secondary School Emergency Relief Fund Assistance Listing Number: 84.425D Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2022-102394-DPI-ESSERFII-163 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter Criteria or Specific Requirement: 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. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement. Condition: The District had 2 construction projects funded by ESSER during 2021-22. The District is responsible for ensuring the contractor provides the appropriate certified payrolls and reviewing them to ensure the prevailing wage rates are being met or exceeded. The documented review of the certified payrolls did not occur. When the District had a construction manager for one of the projects, the District did not implement controls to monitor the construction management company to ensure this compliance requirement was met. Questioned Costs: $14,420. Context: For one of the projects, the District did not have a signed contract that included all required prevailing wage components. The District did not obtain the appropriate certified payrolls and did not document any review of the certified payrolls ensuring appropriate wage rates were being charged for the project. It was noted that the District's construction manager for the other project did obtain and review the appropriate certified payrolls; however, the District did not implement controls to monitor the construction manager to ensure this compliance requirement was met. Cause: The District was not aware of the Davis Bacon Act and the compliance requirements surrounding it. Effect: The District could pay vendors that are not in compliance with the wage rate requirements (Davis Bacon Act). Repeat Finding: No Recommendation: We recommended that the District implement controls to ensure construction contracts include the proper wording and implement controls to ensure certified payrolls are received and reviewed. We also recommend the district implement controls for monitoring third-party contractors when the contractors are responsible for compliance requirements. Views of Responsible Officials: There is no disagreement with the audit finding.

Corrective Action Plan

Elementary and Secondary School Emergency Relief Wage Rate Requirements Elementary and Secondary School Emergency Relief ? Assistance Listing No. 84.425D Recommendation: CLA recommends that the District implement controls to ensure construction contracts include the proper wording and implement controls to ensure certified payrolls are received and reviewed. We also recommend the district implement controls for monitoring third party contractors when the contractors are responsible for compliance requirements. Explanation of disagreement with audit finding: There is no disagreement with the audit finding. Action taken in response to finding: The district was contracting with CESA #10 facilities management to oversee the project. The prevailing wage requirement was designated in the bidding process and the district was assured that the prevailing wage rule would be met. Wage reports were requested and maintained by the CESA #10 office. From now on the district will be requesting that these documents be sent on to the district in a timely manner for review and take pictures of the postings at the job site. Name(s) of the contact person(s) responsible for corrective action: Joe Green Planned completion date for corrective action plan: Next capital project

Categories

Questioned Costs Subrecipient Monitoring Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Significant Deficiency

Other Findings in this Audit

  • 23270 2022-005
    Significant Deficiency
  • 23271 2022-006
    Significant Deficiency Repeat
  • 23272 2022-005
    Significant Deficiency
  • 23273 2022-006
    Significant Deficiency Repeat
  • 23274 2022-005
    Significant Deficiency
  • 23275 2022-006
    Significant Deficiency Repeat
  • 23276 2022-005
    Significant Deficiency
  • 23277 2022-006
    Significant Deficiency Repeat
  • 23278 2022-005
    Significant Deficiency
  • 23279 2022-006
    Significant Deficiency Repeat
  • 23280 2022-005
    Significant Deficiency
  • 23281 2022-006
    Significant Deficiency Repeat
  • 23282 2022-007
    Significant Deficiency
  • 23284 2022-007
    Significant Deficiency
  • 23285 2022-007
    Significant Deficiency
  • 599712 2022-005
    Significant Deficiency
  • 599713 2022-006
    Significant Deficiency Repeat
  • 599714 2022-005
    Significant Deficiency
  • 599715 2022-006
    Significant Deficiency Repeat
  • 599716 2022-005
    Significant Deficiency
  • 599717 2022-006
    Significant Deficiency Repeat
  • 599718 2022-005
    Significant Deficiency
  • 599719 2022-006
    Significant Deficiency Repeat
  • 599720 2022-005
    Significant Deficiency
  • 599721 2022-006
    Significant Deficiency Repeat
  • 599722 2022-005
    Significant Deficiency
  • 599723 2022-006
    Significant Deficiency Repeat
  • 599724 2022-007
    Significant Deficiency
  • 599725 2022-008
    Significant Deficiency
  • 599726 2022-007
    Significant Deficiency
  • 599727 2022-007
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
93.778 Medical Assistance Program $103,188
10.553 School Breakfast Program $56,123
84.367 Improving Teacher Quality State Grants $35,091
84.424 Student Support and Academic Enrichment Program $28,069
84.027 Special Education_grants to States $24,026
84.425 Education Stabilization Fund $22,535
10.555 National School Lunch Program $19,050
10.559 Summer Food Service Program for Children $11,478
84.048 Career and Technical Education -- Basic Grants to States $6,848
10.582 Fresh Fruit and Vegetable Program $5,488
84.173 Special Education_preschool Grants $2,751
84.358 Rural Education $1,766
84.010 Title I Grants to Local Educational Agencies $-2,308