Finding 397034 (2023-007)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2023
Accepted
2024-05-16
Audit: 306409
Auditor: Croskey Lanni PC

AI Summary

  • Core Issue: The Academy failed to include necessary compliance provisions in construction contracts over $2,000, violating federal wage rate requirements.
  • Impacted Requirements: Non-compliance with the Davis-Bacon Act and 2 CFR Part 176 Subpart C, affecting federal funding eligibility.
  • Recommended Follow-Up: Establish internal controls to ensure all future contracts meet federal compliance standards, and maintain proper documentation to verify adherence.

Finding Text

Finding Type – Material noncompliance and material weakness in internal control over compliance. Repeat Finding – No. Federal Program(s) – U.S. Department of Education: ESSER III Formula – American Rescue Plan (ARP‐ESSER) ALN 84.425U; Passed through MDE; Project number 213713. Compliance Requirement – Special Tests and Provisions – Wage Rate Requirements. Criteria – All construction contracts in excess of $2,000 awarded by non‐Federal entities must include a provision for compliance with the Davis‐Bacon Act as supplemented by Department of Labor regulations. Condition – The Academy did not have controls in place to ensure construction contracts in excess of $2,000 included provisions for compliance with the Davis‐Bacon Act. Cause / Effect – The Academy entered into a contract with a construction manager for a project funded by federal funds. The original contract and bid alternate did not include a provision for compliance with the Davis‐Bacon Act. As a result, the Academy entered into a construction contract that was not in compliance with 2 CFR Part 176 Subpart C. Questioned Costs – Unknown. The Academy believes prevailing wages were paid; however, the Academy did not have controls in place to retain adequate documentation to determine that the compliance requirement was met. Recommendation – The Academy should implement internal controls and procedures to ensure construction contracts entered into that utilize federal funding are reviewed for compliance with federal requirements. Auditee Response – The Academy along with its new management company are reviewing, revising, and developing internal controls as necessary in order to comply with compliance requirements relevant to federal programs.

Corrective Action Plan

Corrective Action Plan: The Academy along with its new management company are reviewing, revising, and developing internal controls as necessary in order to comply with compliance requirements relevant to federal programs. Responsible Department: School Leadership and Board and Financial Service Provider together with which includes the bookkeeping, payroll, grants management, and purchasing functions. Responsible Person: Laura Carpenter, Comptroller, CS Partners Planned Completion Date: Immediate

Categories

Special Tests & Provisions Procurement, Suspension & Debarment Material Weakness Internal Control / Segregation of Duties

Other Findings in this Audit

  • 397026 2023-005
    Material Weakness
  • 397027 2023-006
    Material Weakness
  • 397028 2023-005
    Material Weakness
  • 397029 2023-006
    Material Weakness
  • 397030 2023-005
    Material Weakness
  • 397031 2023-006
    Material Weakness
  • 397032 2023-005
    Material Weakness
  • 397033 2023-006
    Material Weakness
  • 397035 2023-005
    Material Weakness
  • 397036 2023-006
    Material Weakness
  • 397037 2023-005
    Material Weakness
  • 397038 2023-006
    Material Weakness
  • 973468 2023-005
    Material Weakness
  • 973469 2023-006
    Material Weakness
  • 973470 2023-005
    Material Weakness
  • 973471 2023-006
    Material Weakness
  • 973472 2023-005
    Material Weakness
  • 973473 2023-006
    Material Weakness
  • 973474 2023-005
    Material Weakness
  • 973475 2023-006
    Material Weakness
  • 973476 2023-007
    Material Weakness
  • 973477 2023-005
    Material Weakness
  • 973478 2023-006
    Material Weakness
  • 973479 2023-005
    Material Weakness
  • 973480 2023-006
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.010 Title I Grants to Local Educational Agencies $451,999
10.555 National School Lunch Program $188,541
10.553 School Breakfast Program $74,541
84.027 Special Education_grants to States $47,324
84.424 Student Support and Academic Enrichment Program $7,062
84.367 Improving Teacher Quality State Grants $6,000
84.425 Education Stabilization Fund $4,963
10.559 Summer Food Service Program for Children $3,290
10.582 Fresh Fruit and Vegetable Program $828
10.649 Pandemic Ebt Administrative Costs $628