Finding Text
2023-001 - Special Tests and Provisions - Wage Rate Requirements
Federal Program Information:
Department of Housing and Urban Development:
ALN - 14.867 - Indian Housing Block Grant
Criteria: The following CFR(s) apply to this finding: 2 CFR 200.327 and 29 CFR 5.5.
Condition: During audit procedures, it was identified that the Housing Authority’s contracts
with vendors for services related to development of Tribal Housing did not include Davis-
Bacon wage requirements. It was also identified that they did not obtain copies of the
required certified payrolls and the accompanying Statement of Compliance.
Cause: The Housing Authority does not have the necessary internal controls over
compliance.
Effect: The Housing Authority’s construction projects are not in compliance with Davis-
Bacon wage requirements.
Identification of Questioned Costs: Payments for the identified clean-up project totalled
$24,185.78, all of which were performed without contracts containing the required
clauses. Related certified payrolls and accompanying Statement of Compliance were not
obtained for any of the payments sampled.
Context: There was a repair project identified by auditors in the samples of expenses
reviewed for the grant, of which had contracts with the required clauses. There were
$24,185.78 payments made for this construction project, none of which had related
certified payrolls and accompanying Statement of Compliance. Auditors established the
potential population of two transactions. This was not a statistically valid sample.
Repeat Finding: This is a repeat finding.
Recommendation: It is recommended that the Housing Authority familiarize themselves
with federal Wage Rate Requirements and implement internal control processes and
procedures to ensure that they are following the criteria above.
Views of Responsible Officials and Corrective Action Plan: Please see the Corrective
Action Plan issued by the Pleasant Point Housing Authority.