Finding Text
U.S. Department of Education Finding 2022-001: Education Stabilization Funds Wage Rate Requirements Pass-through entity: Michigan Department of Education Assistance Listing Number(s): 84.425C, 84.425D and 84.425U Award Numbers: COVID-19 201200 20-21, COVID-19 211202 2122, COVID-19 213762 2122, COVID-19 213712 20-21, COVID-19 213722 2122, COVID-19 213742 2122 and COVID-19 213713 2122 Award Year End: September 30, 2023 Specific Requirement: Special Tests?Wage Rate Requirements Criteria: Section 20.001 and 200.311 of the Cost Principles of the Title 2 U.S. Code of Federal Regulations Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance) requires a School District to include prevailing rate clauses in construction contracts and receive certifications that prevailing wages in their location were paid during each week and have obtained board approval of the contracts. Questioned Costs: None. Condition: During our testing of the construction contract expenditures, we noted that the School District?s contract did not contain the required clause for prevailing wages to be paid during each week of construction. Context: The School District construction contract did not contain clauses requiring prevailing wages to be paid and the contractor to provide certifications that prevailing wages were paid for each week of the contract. The School District did obtain the proper Board approval of the contract in advance. Effect: The School District could be held responsible to ensure the construction contractor employees were paid prevailing wage rates for each week of the contract. Cause: The School District was unaware that this clause was required in relation to construction contracts funded with federal funds. Repeat Finding: This is not a repeat finding. Recommendation: The School District should review its construction contracts funded with federal funds to ensure that the contract requires prevailing wages to be paid and require proper certifications from the contractor that prevailing wages were paid for every week the work was performed. Views of Responsible Officials: The School District agrees with this finding and has received from the contractor the proper certifications that prevailing wages were paid to employees for each week of work performed.