Finding Text
Identification of the federal program: AL 84.424, Elementary and Secondary School Emergency Relief Fund (ESSER), US Department of Education, Award Year: July 1, 2022 – June 30, 2023, Compliance Requirement: N – Special Tests and Provisions (Construction of Assets); Type of Finding: Significant Deficiency in Internal Control over Compliance.
Criteria: Management is responsible for the design, implementation, and maintenance of internal control relevant compliance with federal programs.
Condition: The District did not implement an effective internal control over compliance sufficient to ensure compliance with the requirement to obtain certified payroll reports for work performed using ESSER program funding.
Context: While certified payroll reports were not obtained, the District did comply with related provisions, including the inclusion of the contract provision to pay prevailing wage rates contained in the contract with the contractor.
Cause: We are unsure of the cause, but it appears the District was unaware of the requirement to obtain certified payroll reports and thus did not implement an internal control to ensure compliance.
Effect: The District did not confirm that the contractor who performed the work paid its workers the prevailing wage as required.
Recommendation: We recommend the District implement policy for any upcoming real property construction to be funded using federal programs to ensure that prevailing wage requirements are monitored by use of obtaining certified payroll reports.
Views of Responsible Officials: The District agrees with this finding and will adopt policies relating to construction projects with federal funds.