Finding Text
Finding Number: 2023-001
Repeat Finding: Yes, 2022-001
Program Names/Assistance Listing Titles: Assistance Listing Numbers: Federal Award Numbers: Questioned Costs:
Education Stabilization Fund 84.425 S425D210038, S425U210038 N/A
Impact Aid 84.041 N/A N/A
Federal Agency(ies): U.S Department of Education
Pass-Through Agency(ies): Arizona Department of Education
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirements: Special Tests and Provisions – Wage Rate
Criteria
According to Federal guidelines, §7007 construction funds, as well as any §7002 or §7003(b) funds expended for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b).
Condition
Wage rate certificates were not turned in weekly. Additionally, one procurement did not include the appropriate wage rate compliance disclosure.
Cause
Effective internal controls were not implemented that would adequately prevent or detect a deficiency. There were delays on the side of the contractors regarding submission and an issue with the District’s internet connection that may have also affected email since April/May of 2023.
Effect
The District did not comply with the special tests and provisions requirements of the grants.
Context
The District failed to monitor the contract weekly to ensure compliance with the wage rate requirements. Additionally, the District could not provide support that the contract/subcontract or procurement included the appropriate wage rate clauses. The sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should monitor and ensure Davis-Bacon Act prevailing wage requirements are properly disclosed to all vendors and that wage rate certificates are turned in weekly.
Views of Responsible Officials
See Corrective Action Plan.