Finding Text
Elementary and Secondary School Emergency Relief Fund Wage Rate Requirements Federal Agency: U.S. Department of Education Federal Program Name: Elementary and Secondary School Relief Fund Assistance Listing Number: 84.425D, 84.425U Federal Award Identification Number and Year: S425D210044 Federal Award Date 1/6/2021 and S425U210044 Federal Award Date 12/6/2021 Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Numbers: 2022-714508-DPI-ESSERFII-163, 2022-714508-DPI-ESSERFIII-165 Award Period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria or specific requirement: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement. Condition: The District is responsible for ensuring the contractor provides the appropriate certified payrolls and reviewing them to ensure the prevailing wage rates are being met or exceeded. The District contracted with a third party to provide construction management including reviewing for Davis Bacon compliance; however, the District did not implement controls to monitor the construction management company to ensure this compliance requirement was met. Questioned costs: None. Context: While performing audit procedures, it was noted that the District's construction manager did obtain and review the appropriate certified payrolls; however, the District did not implement controls to monitor the construction manager to ensure this compliance requirement was met. Cause: The District was aware of the Davis Bacon Act and the compliance requirements surrounding it; however, the District was not aware they needed to document controls ensuring this was completed Effect: The District could pay vendors that are not in compliance with the Davis Bacon requirements. Repeat Finding: No. Recommendation: We recommended the District implement controls for monitoring third party contractors when the contractors are responsible for compliance requirements. Views of responsible officials: There is no disagreement with the audit finding.