Finding Text
Required language was not included in the construction contracts using
laborers and mechanics financed with ESSER funds.
ESSER program required all construction contracts to include language in
the contracts that all contractors or subcontractors must pay wages that
are not less than those established for the locality of the project.
Due to oversight of management and the outside accountant this
requirement was not noted. Federal ESSER funds were spent on construction that did not include the required language in the contract. Management and the outside accountants should review the terms of the award to ensure all compliance requirements of the award are addressed appropriately. We acknowledge the audit finding regarding non-compliance with the management of our ESSER grant. We understand the importance of following the applicable rules and regulations for the use of federal funds. Current management will proceed with the following to prevent a similar oversight from reoccurring.
1 . Any Griffin Foundation staff who is responsible for the management of
Federal funding will complete training focused on the requirements
established by the Office of Budget Management (0MB).
2. Management will work with Grants Management staff to obtain
training via their document library and/or annual conference.
3. Management will work with contracted accounting service to ensure
similar training is received by their staff.
4. The Board of the Griffin Foundation will establish a policy that requires
additional documentation and consideration before any future
federal funds are used to fund a capital project.