Finding Text
Assistance Listing Number, Federal Agency, and Program Name - 84.425D, U.S. Department of Education, COVID 19 ESSER Formula Fund II Federal Award Identification Number and Year - 213712 Pass through Entity - Michigan Department of Education Finding Type - Material weakness Repeat Finding - No Criteria - Approved construction projects must comply with applicable Uniform Guidance requirements, as well as the department?s regulations regarding construction at 34 CFR ? 76.600. As is the case with all remodeling or construction contracts using laborers and mechanics financed by federal education funds, an LEA that uses ESSER or GEER funds for minor remodeling, renovation, repair, or construction contracts over $2,000 must meet all Davis Bacon prevailing wage requirements and include language in the contracts that all contractors or subcontractors must pay wages that are no less than those established for the locality of the project (prevailing wage rates). (See 20 U.S.C. 1232b Labor Standards.) (See also FAQ B 6.) Condition - During testing of the grant, we noted that the School District utilized funds from the Education Stabilization Funds (ESF) for minor remodeling and renovations of the school buildings. Per the 2022 Compliance Supplement, recipients and subrecipients that use ESF for minor remodeling, renovation, or construction contracts that are over $2,000 and use laborers and mechanics must meet Davis Bacon prevailing wage requirements. The School District expended approximately $360,000 in ESSER funds that related to repairs and renovations for an indoor air purification system; however, the School District failed to request or receive the certified payroll reports from the contractor until it was identified by the auditor. Once identified, the School District requested and received the certified payroll reports. Questioned Costs - None Identification of How Questioned Costs Were Computed - N/A - No questioned costs Context - We noted $360,000 of repairs and renovations that was charged to the ESSER II grant, which had a total of approximately $1.5 million in expenditures. While the School District met the requirement of having the prevailing wage language included in the contract with the contractor, the School District failed to request and review the certified payroll reports from the contractor until it was identified by the auditor that this had not yet occurred. Cause and Effect - The School District did not have a control in place to identify that they were required to request the certified payroll reports from the contractor. As a result, the review of the payroll reports in order to ensure that prevailing wages were paid to employees of the contractor did not occur until it was identified by the auditor that this review had not yet been completed. Recommendation - We recommend the School District have a process and control in place to ensure that certified payroll reports from the contractors are being received and reviewed by the School District on a timely basis. Views of Responsible Officials and Planned Corrective Actions - The School District will implement procedures to complete a review of contracts to make sure they include the Davis Bacon prevailing wage rate and review certified payroll reports from the contractors.