Finding 46893 (2022-005)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-02-04

AI Summary

  • Core Issue: The School Corporation lacked effective internal controls to ensure compliance with wage rate requirements for federally funded construction contracts.
  • Impacted Requirements: Compliance with the Department of Labor's prevailing wage rates and submission of weekly payrolls was not adequately monitored.
  • Recommended Follow-Up: Management should implement internal controls to ensure adherence to grant agreements and wage rate compliance moving forward.

Finding Text

FINDING 2022-005 Subject: COVID-19 - Education Stabilization Fund - Special Tests and Provisions - Wage Rate Requirements Federal Agency: Department of Education Federal Program: COVID-19 - Education Stabilization Fund Assistance Listings Number: 84.425 Federal Award Numbers or Years (or Other Identifying Numbers): S425D200013, S425D2100013, S425U210013 Pass-Through Entity: Indiana Department of Education Compliance Requirement: Special Tests and Provisions - Wage Rate Requirements Audit Finding: Material Weakness Condition and Context An effective internal control system was not designed or implemented at the School Corporation to ensure compliance with requirements related to the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Construction contracts in excess of $2,000 financed by federal assistance funds must pay wages not less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (DOL) to their laborers and mechanics. Nonfederal entities are to include in their construction contracts subject to the Wage Rate Requirements a provision that the contractor or subcontractor comply with these requirements and the DOL regulations. This would include a requirement to submit a copy of the payroll and statement of compliance to the entity for each week in which contract work was performed. The School Corporation had the required clause in the contract and received the payroll; however, the School Corporation did not have adequate policies or procedures to ensure that the required payrolls were submitted and reviewed for each week in which contract work was performed. The lack of internal controls was systemic throughout the audit period. Criteria 2 CFR 200.303 states in part: "The non-Federal entity must: (a) Establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in 'Standards for Internal Control in the Federal Government' issued by the Comptroller General of the United States or the 'Internal Control Integrated Framework', issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). . . ." Cause Management had not developed or implemented a system of internal control that would have ensured compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Effect The failure to establish an effective internal control system could have enabled material noncompliance to go undetected. Questioned Costs There were no questioned costs identified. Recommendation We recommended that the School Corporation's management establish internal controls to ensure compliance with the grant agreement and the Special Tests and Provisions - Wage Rate Requirements compliance requirement. Views of Responsible Officials For the views of responsible officials, refer to the Corrective Action Plan that is part of this report.

Corrective Action Plan

FINDING 2022-005 Contact Person Responsible for Corrective Action: Kyle Zahn Contact Phone Number: 765-883-5576 ext. 5112 Views of Responsible Official: We concur with the finding. Description of Corrective Action Plan: The school?s leadership team will review the Federal Wage Rate requirements during the next director?s meeting. All future projects being funded by federal funds will require weekly payroll submissions to be reviewed by the school employee who is overseeing the project. Anticipated Completion Date: February 2023?

Categories

Matching / Level of Effort / Earmarking Special Tests & Provisions Subrecipient Monitoring Material Weakness

Other Findings in this Audit

  • 46891 2022-003
    Material Weakness
  • 46892 2022-004
    Material Weakness
  • 46894 2022-003
    Material Weakness
  • 46895 2022-004
    Material Weakness
  • 46896 2022-005
    Material Weakness
  • 46897 2022-003
    Material Weakness
  • 46898 2022-005
    Material Weakness
  • 46899 2022-003
    Material Weakness
  • 46900 2022-005
    Material Weakness
  • 623333 2022-003
    Material Weakness
  • 623334 2022-004
    Material Weakness
  • 623335 2022-005
    Material Weakness
  • 623336 2022-003
    Material Weakness
  • 623337 2022-004
    Material Weakness
  • 623338 2022-005
    Material Weakness
  • 623339 2022-003
    Material Weakness
  • 623340 2022-005
    Material Weakness
  • 623341 2022-003
    Material Weakness
  • 623342 2022-005
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425U Education Stabilization Fund Fy22 $1.29M
10.555 National School Lunch Program Fy 22 $1.21M
84.425D Education Stabilization Fund Fy22 $659,327
84.027 Special Education_grants to States Fy21 $594,769
84.027 Special Education_grants to States Fy 22 $573,343
84.010 Title I Grants to Local Educational Agencies Fy22 $377,834
10.553 School Breakfast Program Fy22 $257,371
84.010 Title I Grants to Local Educational Agencies Fy21 $122,389
84.425D Education Stabilization Fund Fy21 $99,618
10.555 National School Lunch Program Fy21 $83,639
84.367 Improving Teacher Quality State Grants Fy22 $62,349
97.036 Disaster Grants - Public Assistance (presidentially Declared Disasters) Fy22 $34,271
84.173 Special Education_preschool Grants Fy21 $17,217
84.424 Student Support and Academic Enrichment Program Fy22 $15,810
84.424 Student Support and Academic Enrichment Program Fy21 $15,204
10.553 School Breakfast Program Fy21 $14,543
84.367 Improving Teacher Quality State Grants Fy21 $8,134
84.027 Special Education_grants to States Fy22 $7,321
84.173 Special Education_preschool Grants Fy22 $4,315
10.649 Pandemic Ebt Administrative Costs Fy22 $614