Finding 31350 (2022-001)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-04-25

AI Summary

  • Core Issue: Contractors and subcontractors were not properly notified about the requirement to pay prevailing wage rates and submit certified payrolls for federally funded construction projects.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and Labor Standards Provisions was lacking, risking disallowed costs due to missing documentation.
  • Recommended Follow-Up: Strengthen controls to ensure prevailing wage rate clauses are included in contracts and that certified payrolls are collected weekly.

Finding Text

Item 2022-001 Special Tests and Provisions ? Wage Rate Requirements Education Stabilization Fund (ESF) ALN# 84.425 U.S. Department of Education Passed through the State Department of Education Grant period ? Years ended September 30, 2021 (84.425U) (84.425C) and September 30, 2020 (84.425D) Criteria ? Grantees should have controls in place to ensure that contractors and subcontractors are notified of the requirement to pay prevailing wage rates to all laborers and mechanics employed on construction contracts in excess of $2,000 financed by federal assistance funds and to submit weekly certified payrolls for each week in which contract work is performed. 2 CFR 200.303 requires the non-Federal entity to ?(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award.? 2 CFR 200.326 and 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction (DOL Regulations) require the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Condition ? Adequate controls were not in place to ensure that contractors and subcontractors were notified of the requirements to comply with the wage rate requirements and provided timely certified payrolls throughout the construction projects. Cause ? A clause describing the Wage Rate Requirements was not added to the construction contracts. There was a lack of sufficient controls over the communication of this requirement to ensure that accurate and complete certified payrolls were provided to the Board. Effect ? Lack of notification of the wage rate requirements to the contractors and subcontractors could lead to disallowed costs. We noted that payments to contractors did not have supporting documentation of certified payrolls. However, our audit disclosed no instances of unallowable costs. Questioned Costs ? Not determinable. Recommendation ? We recommend the strengthening of controls to ensure the prevailing wage rate clauses are included in the contracts and that certified payrolls are received for each week in which construction work is performed. Management?s Response ? The Board will strengthen the controls in place to provide assurance that proper prevailing wage rate clauses are added to construction contracts and certified payrolls are received from each week in which construction work is performed.

Corrective Action Plan

Corrective Action Plan The Enterprise City Board of Education (the Board) respectfully submits the following corrective action plan for the year ended September 30, 2022. Carr, Riggs & Ingram, LLC 1117 Boll Weevil Circle Enterprise, AL 36330 The finding from the September 30, 2022 schedule of findings and questioned costs is discussed below. The finding is numbered consistent with the number assigned in the schedule. FINDINGS- FINANCIAL STATEMENT AUDIT No such findings in the current year. FINDINGS - FEDERAL AWARDS PROGRAM AUDITS Item 2022-001 - Special Tests and Provisions - Wage Rate Requirements Recommendation: 2 CFR 200.303 requires the non-Federal entity to "(a) establish and maintain effective internal controls over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the Federal award." 2 CFR 200.326 and 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction (DOL Regulations) require the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). We recommend the strengthening of controls to ensure the prevailing wage rate clauses are included in the contracts and that certified payrolls are received for each week in which construction work is performed. The Chief School Financial Officer, Pam Christian, should review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She should also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed. Action Taken: Management has reviewed the requirements of 2 CFR Section 200.303 and 2 CFR 200.326 relating to wage rate requirements and agrees with the recommendation. Management will communicate with all contractors and subcontractors regarding the wage rate requirements and will implement additional procedures, effective May 1, 2023, stating that the Chief School Financial Officer, Pam Christian, will review documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of the bid process prior to expenditures being made. She will also review all invoices received from contractors and subcontractors to ensure that the certified payroll information is received for all weeks for which construction work is performed.

Categories

Allowable Costs / Cost Principles Matching / Level of Effort / Earmarking Special Tests & Provisions

Other Findings in this Audit

  • 31351 2022-001
    Material Weakness
  • 31352 2022-001
    Material Weakness
  • 607792 2022-001
    Material Weakness
  • 607793 2022-001
    Material Weakness
  • 607794 2022-001
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $3.12M
84.027 Special Education_grants to States $1.42M
84.010 Title I Grants to Local Educational Agencies $1.20M
84.041 Impact Aid $1.04M
10.553 School Breakfast Program $632,305
12.556 Competitive Grants: Promoting K-12 Student Achievement at Military-Connected Schools $423,889
10.558 Child and Adult Care Food Program $238,760
10.582 Fresh Fruit and Vegetable Program $205,838
84.367 Improving Teacher Quality State Grants $193,476
10.559 Summer Food Service Program for Children $150,471
10.555 Covid - 19 - National School Lunch Program $138,410
12.357 Rotc Language and Culture Training Grants $110,201
84.365 English Language Acquisition State Grants $99,607
84.027 Covid 19 - Special Education_grants to States $95,802
84.048 Career and Technical Education -- Basic Grants to States $76,559
84.323 Special Education - State Personnel Development $75,100
84.424 Student Support and Academic Enrichment Program $72,009
84.358 Rural Education $53,896
84.173 Special Education_preschool Grants $19,062
10.560 State Administrative Expenses for Child Nutrition $18,765
84.173 Covid - 19 - Special Education_preschool Grants $10,015
10.649 Pandemic Ebt Administrative Costs $4,470
96.001 Social Security_disability Insurance $500
84.425 Covid-19 - Education Stabilization Fund $321