Finding 50478 (2022-002)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2022-10-16
Audit: 51225
Auditor: Yeo & Yeo PC

AI Summary

  • Core Issue: The District lacks controls to ensure contractors comply with the Davis-Bacon Act for prevailing wage payments.
  • Impacted Requirements: Contractors must pay laborers according to the prevailing wage rates and provide weekly payroll records.
  • Recommended Follow-Up: Implement internal controls to monitor compliance with the Davis-Bacon Act.

Finding Text

Program Information: Education Stabilization Fund, U.S. Department of Education, passed through Michigan Department of Education, Assistance Listing #84.425. Pass-Through Grantor #213712 and 213713. Criteria: The Davis-Bacon Act (23 U.S.C. 113) requires contractors and subcontractors performing work on federal contracts in excess of $2,000 to pay their laborers and mechanics not less than the prevailing wage rates and fringe benefits listed in the contract?s wage determination class. Each covered contractor and subcontractor must, on a weekly basis, provide a copy of the payroll providing the information listed under recordkeeping for the preceding weekly payroll period. Condition: The District did not have controls in place to determine if contractors are complying with the Davis-Bacon Act regarding the payment of prevailing wage rates. Questioned Costs: None. Cause and Effect: The District was unaware that monitoring compliance with the Davis-Bacon Act regarding the payment of prevailing wage rates was a responsibility of the District. The District therefore had no assurance that the wages paid were in compliance with the Davis-Bacon Act. Recommendation: We recommend that the District implements internal controls to ensure compliance with the requirements over the Davis-Bacon Act. Views of Responsible Officials: Management agrees with the finding. Corrective Action Plan: See attached corrective action plan.

Corrective Action Plan

District response to Audit Finding 2022-001 ? Contact Person Responsible for Corrective Action ? Scott Brown and Jennifer Goodman Management agrees with this audit finding. The district received an unprecedented amount of federal funding in 2021-2022 to reimburse the district for Food Service meals for all students. As a result, the district's Food Service program completed the 2021-2022 fiscal year with an ending fund balance that exceeded the average three months of expenditures threshold by approximately $144,000. The corrective action planned is for management to meet and determine how to spend this $144,000 excess amount toward allowable Food Service program expenditures no later than June 30, 2023. The District must then report to the Michigan Department of Education (MOE) how it expects to spend this excess amount by January 2023. The district expects to meet the January 2023 deadline to submit a spending plan to MDE. The district also expects to spend down the excess $144,000 by June 30, 2023. District response to Audit Finding 2022-002 ? Contact Person Responsible for Corrective Action ? Scott Brown and Jennifer Goodman Management agrees with this audit finding. The district did not have controls in place to determine if contractors are complying with the Davis-Bacon Act regarding the payment of prevailing wage rates. District personnel were unaware that monitoring compliance with the Davis-Bacon Act regarding the payment of prevailing wage rates was a responsibility of the district. The corrective action plan to address this audit finding begins with education. Management now understands that compliance with the Davis-Bacon Act must be considered when working with contractors and subcontractors on federal contracts in excess of $2,000. The district has also updated the district's Business Office Operating Procedures Manual to include language that prevailing wage rates and review of contractor's employee timesheets must be complied. The district expects to be in compliance in regard to all Davis-Bacon Act regulations moving forward when contracting with contractors and subcontracted in excess of $2,000.00 when utilizing federal grant funding.

Categories

Subrecipient Monitoring Internal Control / Segregation of Duties

Other Findings in this Audit

  • 50479 2022-002
    Significant Deficiency
  • 626920 2022-002
    Significant Deficiency
  • 626921 2022-002
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $379,238
84.425U Education Stabilization Fund $232,092
84.425D Education Stabilization Fund $188,974
21.019 Coronavirus Relief Fund $66,935
84.010 Title I Grants to Local Educational Agencies $56,080
10.553 School Breakfast Program $20,321
84.367 Improving Teacher Quality State Grants $12,756
84.424 Student Support and Academic Enrichment Program $10,996
93.778 Medical Assistance Program $10,372