Finding 504039 (2024-003)

-
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-10-29

AI Summary

  • Core Issue: The District failed to consistently review certified payrolls, leading to non-compliance with Davis-Bacon prevailing wage requirements for contractors.
  • Impacted Requirements: Compliance with federal regulations for projects over $2,000 using ESF funds, specifically ensuring proper wages for laborers and mechanics.
  • Recommended Follow-Up: The Construction Manager should implement a weekly review of certified payrolls for all ongoing projects funded by ESF to prevent future compliance issues.

Finding Text

EFS Section 1 - Elementary and Secondary Education - Davis-Bacon Prevailing Wage Requirements ALN 84.425U - ESSER III - Grant # 213713 2122 - Grant Ending September 30, 2024 Condition and Criteria: The Federal Compliance Supplement requires that recipients and subrecipients that use ESF funds for minor remodeling, renovation or construction contracts, that are over $2,000, and use laborers and mechanics, must meet Davis-Bacon prevailing wage requirements. To ensure this, the District is required to review the weekly certified payrolls, ensuring that the proper prevailing wages were paid. During the audit, it was noted that certified payrolls were not consistently being reviewed, which allowed for one contractor to not pay the correct rate to their employees. We would like to note that once this situation was uncovered, the contractor did in fact correct the prior pays so that all employees were paid the appropriate prevailing wages. Effect: The District was out of compliance in regards to the Davis-Bacon rules until the wages were subsequently corrected by the contractor.Cause: The Construction Manager was not consistently reviewing weekly certified payrolls, as required, throughout the course of the construction to ensure that proper prevailing wages were consistently paid. Context: While the District was out of compliance initially for not ensuring that the correct prevailing wages were paid, this situation was fully corrected prior to the audit by the contractor. Questioned Costs: $0. While the District was out of compliance initially for not ensuring that the correct prevailing wages were paid, this situation was fully corrected prior to the audit by the contractor. Auditors' Recommendation: We recommend the Contract Manager begin reviewing certified payrolls weekly for all on-going projects for which ESF funds are being utilized. Views of Responsible Officials and Planned Corrective Actions: The District understands the issue and will work with their Construction Manager to ensure that certified payrolls are reviewed weekly moving forward. Please see the attached Corrective Action Plan prepared by the District.

Corrective Action Plan

ESF Section 1 – Elementary and Secondary Education – Davis Bacon Prevailing Wage Requirements Condition: The Federal Compliance Supplement requires that recipients and subrecipients that use ESF funds for minor remodeling, renovation or construction contracts that are over $2,000 and use laborers and mechanics must meet Davis-Bacon prevailing wage requirements. To ensure this, the District is required to review the weekly certified payrolls, ensuring that the proper prevailing wages were paid. During the audit, it was noted that certified payrolls were not consistently being reviewed, which allowed for one contractor to not pay the correct rate to their employees. We would like to note that once this situation was uncovered, the contractor did in fact correct the prior pays so that all employees were paid the appropriate prevailing wages. Corrective Action: The District understands the issue and will work with their Construction Manager to ensure that certified payrolls are reviewed weekly moving forward. Please see the attached Corrective Action Plan prepared by the District. Contact Person Responsible for Corrective Action: Chanda Cleaves, Finance Director for Shared Business Services and Teresa Graham, Assistant Finance Director for Shared Business Services Completion Date: This issue will be corrected moving forward.

Categories

Subrecipient Monitoring

Other Findings in this Audit

Programs in Audit

ALN Program Name Expenditures
84.010 Title I Grants to Local Educational Agencies $11.36M
10.555 National School Lunch Program $1.69M
84.424 Student Support and Academic Enrichment Program $1.40M
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $1.15M
84.027 Special Education Grants to States $1.14M
10.553 School Breakfast Program $708,012
84.371 Comprehensive Literacy Development $433,744
10.558 Child and Adult Care Food Program $293,054
84.173 Special Education Preschool Grants $210,486
10.582 Fresh Fruit and Vegetable Program $116,691
84.425 Education Stabilization Fund $97,254
93.778 Medical Assistance Program $26,516
10.559 Summer Food Service Program for Children $22,733
10.185 Local Food for Schools Cooperative Agreement Program $22,082
10.574 Team Nutrition Grants $9,447
84.365 English Language Acquisition State Grants $9,322