Finding 374630 (2023-002)

Finding #2023-002: ESSER II #84.425D COVID-19 – Education Stabilization Fund and ESSER III #84.425U COVID-19 – Education Stabilization Fund Federal Grantor: U.S. Department of Education Pass-through Award Numbers: 2022-252646-DPI-ESSERFII-163 and 2022- 252646-DPI-ESSERFIII-165 Pass-through Entity: Wisconsin Department of Public Instruction Condition: There were five Education Stabilization Fund construction projects performed by contractors/subcontractors. None of the contracts included prevailing wage language clauses and certified payrolls were not obtained by the District during the fiscal year expended. Not all contractors/subcontractors were able to provide certified payrolls when requested as part of the compliance testing. Criteria: Wage rate requirements apply to the Education Stabilization Fund when laborers and mechanics employed by contractors or subcontractors work on construction contracts more than $2,000. Laborers must be paid wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL). Nonfederal entities shall include in their contracts subject to wage rate requirements a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. This includes a requirement for the contractor or subcontractor to submit to the District weekly payrolls and a statement of compliance (certified payrolls). Cause: There was turnover in the business office and the contracts were secured and approved prior to the current business manager. The District was not aware of the applicable requirements related to these projects. Effect: A reimbursement request was made for expenditures that did not comply with wage rate requirements. Questioned Costs: $78,300 Recommendation: Establish procedures and controls to comply with wage rate requirements related to the Education Stabilization Fund. Obtain verification from contractors that prevailing wage rates were paid on the projects submitted for costs reimbursed by the grant. Response: The District became aware of the prevailing wage rate requirements after finishing the projects. Before bidding future construction projects more than $2,000, that may be funded with federal grant dollars, the request for bid and contract will include a prevailing wage rate clause. Certified payrolls will be received from contractors or subcontractors.