Finding 48600 (2022-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-05

AI Summary

  • Core Issue: The District did not comply with federal wage rate requirements for construction projects.
  • Impacted Requirements: Failure to submit weekly wage certificates and disclose wage rate compliance in procurement documents.
  • Recommended Follow-Up: Implement monitoring to ensure compliance with Davis-Bacon Act requirements and timely submission of wage rate certificates.

Finding Text

FINDINGS AND QUESTIONED COSTS RELATED TO FEDERAL AWARDS Finding Number: 2022-001 Repeat Finding: No Program Name/Assistance Listing Title: Impact Aid Assistance Listing Number: 84.041 Federal Agency: U.S Department of Education Federal Award Number: N/A Pass-Through Agency: N/A Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions CRITERIA According to Federal guidelines, ?7007 construction funds, as well as any ?7002 or ?7003(b) funds expended for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). CONDITION Wage certificates were not turned in weekly for one construction project. Additionally, one procurement did not contain the required wage rate compliance disclosure. CAUSE Effective internal controls were not implemented that would adequately prevent or detect a deficiency. EFFECT The District did not comply with the special tests and provisions requirements of the grant. CONTEXT The District failed to monitor the contractor weekly to ensure compliance with wage rate requirements. Additionally, the District failed to disclose the wage rate requirement in one request for bids issued for construction services. The sample was not intended to be, and was not, a statistically valid sample. RECOMMENDATION The District should monitor and ensure Davis-Bacon Act prevailing wage requirements are properly disclosed to all vendors and that wage rate certificates are turned in weekly. VIEWS OF RESPONSIBLE OFFICIALS See Corrective Action Plan.

Corrective Action Plan

Findings and Questioned Costs Related to Federal Awards Finding Number: 2022-001 Program Name/Assistance Listing Title: Impact Aid Assistance Listing Number: 84.041 Contact Person: Priscine Jones, Business Manager Anticipated Completion Date: October 27, 2022 Planned Corrective Action: The Business Manager corrected the information on the scope of work and asked the vendor to submit payroll certifications on October 27, 2022 before the vendor was paid the full amount. In addition, the Business Office revised their Business Operations Policies and Procedures Manual to include in the scope of work for any current and future projects that payroll certification be turned into the Business Office. Our current vendor was notified and we develop a process where time certification will be emailed in a link weekly to the Administrative Assistant and reviewed by the Business Manager weekly. Chinle Unified School District issued a PO in the amount of $30,000 for demolition of old federal building. The PO was issued on September 17, 2021 and paid in full on November 4, 2021. The District did not pay until the payroll certifications were turned into the Business Office which was on October 27, 2022. The original specifications did not mention following the Davis-Bacon Prevailing Wages which was an oversight on the District. In addition to the Davis Bacon requirements, the Business Manager did not know that 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR part 215, Appendix A, Contract Provisions); 2 CFR part 176, subpart C; and 2 CFR section 200.326 asked for weekly payroll certification on any construction projects funded through federal funding.

Categories

Procurement, Suspension & Debarment Special Tests & Provisions Significant Deficiency

Other Findings in this Audit

  • 625042 2022-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.041 Impact Aid $25.53M
84.010 Title I Grants to Local Educational Agencies $5.16M
10.559 Summer Food Service Program for Children $2.52M
84.425 Covid-19 Education Stabilization Fund $831,939
84.060 Indian Education_grants to Local Educational Agencies $714,057
84.027 Special Education_grants to States $708,950
15.130 Indian Education_assistance to Schools $476,815
21.027 Covid-19 Coronavirus State and Local Fiscal Recovery Funds $430,661
84.367 Supporting Effective Instruction State Grants $376,624
84.377 School Improvement Grants $276,736
84.048 Career and Technical Education -- Basic Grants to States $169,944
84.424 Student Support and Academic Enrichment Program $148,310
10.582 Fresh Fruit and Vegetable Program $133,153
84.027 Covid-19 Special Education_grants to States $96,928
10.555 Covid-19 National School Lunch Program $89,045
84.358 Rural Education $85,851
12.U01 Rotc $40,388
84.365 English Language Acquisition State Grants $28,021
84.173 Special Education_preschool Grants $6,150
10.555 National School Lunch Program $4,739
10.649 Covid-19 Pandemic Ebt Administrative Costs $2,964
84.334 Gaining Early Awareness and Readiness for Undergraduate Programs $1,946