Finding Text
Davis Bacon Act prevailing wage requirements were not included in the contract or
discussed with the contractor and Davis Bacon Act record retention requirements were not
followed during the duration of the construction project (significant deficiency and noncompliance) Condition:
Vision Preparatory Charter School, Inc. did not discuss the need to meet the Davis Bacon Act prevailing
wage requirements with the roof contractors before requesting bids or signing a contract. The School
also did not receive wage reports during the duration of the project and in turn, did not ensure that the
contractor was in compliance with the Davis Bacon Act for prevailing wage rates paid to employees that
worked on the roof replacement project prior to completion. The oversight was recognized prior to reimbursement and they took action to try to remedy the non compliance by requesting the missing
documentation after the fact.
Criteria:
Per the 2022 Compliance Supplement, recipients and subrecipients that use ESF funds for minor
remodeling, renovation or construction contracts that are over $2,000 and use laborers and mechanics
must meet Davis-Bacon prevailing wage requirements.
Cause:
The School had not implemented any controls or processes to ensure compliance with this requirement
prior to executing contracts.
Effect:
Non-compliance with the Uniform Guidance for the federal grant funding received. And this noncompliance
could have led to additional funds being needed to compensate for a lower than prevailing
wage rate paid to the Contractor's employees or it could have led to disallowed costs and a resulting
repayment of federal grant funds received.
Questioned Cost: Unknown
Recommendation:
We recommend the School make the Davis Bacon Act prevailing wage requirements known as a
requirement to contractors before accepting bids on projects in the future. We also recommend that the
School make sure the contract agreement for the project includes a requirement for the contractor to
comply with the Davis Bacon Act regarding prevailing wage rates. And we recommend the School
receive weekly wage reports for the duration of the project and compare the wages paid with the
prevailing wage rates to ensure compliance with the Davis Bacon Act.