Finding Text
AL 84.425 Elementary and Secondary School Emergency Relief Fund (ESSER), US Department of Education, Award ID: 64601, Award Year: July 1, 2022 ? June 30, 2022. Compliance requirement: Special Tests and Provisions. Criteria: Internal controls over compliance must be in place for every compliance requirement that the federal agency indicates is relevant to the program. Each federal program is generally limited to identifying no more than six of the 12 compliance requirements to be audited. For each of the six identified, however, the District is responsible for (1) determining if is relevant to their program and (2) if relevant, implementing control systems to ensure compliance. Condition and context: We were unable to find evidence that management knew of the Davis Bacon Act requirement or implemented internal controls over the compliance requirement. Cause: Based on responses to our inquiry, we believe the cause of a lack of knowledge and understanding of the program?s requirements. Effect: The District was unable to verify that the contractor paid their laborers prevailing wage rates as required. Recommendation: We recommend the District ensure that staff in charge of federal programs understand the program and obtain training prior to being given responsibility for federal programs. Each significant federal program should have its requirements documented and related compliance controls implemented and formally documented to ensure compliance with all relevant requirements. Views of responsible officials: District agrees with this recommendation. We will provide staff with additional training specific to Davis-Bacon wages and federal requirements.