Finding 513063 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2024-12-05
Audit: 330975
Organization: Tahquamenon Area Schools (MI)
Auditor: Hungerford

AI Summary

  • Core Issue: There is a significant deficiency in internal controls over the Education Stabilization Fund, leading to noncompliance with wage reporting requirements.
  • Impacted Requirements: Contractors must submit certified payrolls to ensure laborers are paid prevailing wages as mandated by federal law.
  • Recommended Follow-Up: The District should establish effective internal controls to review certified payrolls for all federally funded construction projects.

Finding Text

Finding Type: Significant deficiency in internal controls over major programs and noncompliance with laws and regulations. Program Impacted: Education Stabilization Fund; ARP ESSER III (84.425U) Condition: All required payrolls were not submitted by contractors or subcontractors for work performed by laborers on projects funded, in part, by the Education Stabilization Fund grant. Criteria: All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000, financed by federal assistance funds, must be paid wages no less than those established for the locality of the project (prevailing wage rates) by the Department of Labor (40 USC 3141-3144, 3146, and 3147). The reporting for this includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which work is performed, a copy of the payroll and statement of compliance (certified payrolls) (2 CFR Part 176, Subpart C; and 2 CFR section 200.326). Cause: The District did not maintain effective internal controls over the review of certified payrolls to ensure that prevailing wages were paid to mechanics and other laborers working on the contract. Effect: The District is unable to verify compliance with prevailing wage rate requirements for projects funded under the grant. Context: We evaluated 3 vendors as part of our review of wage rate requirements and noted the following: *For 1 of the 3 vendors reviewed, certified payrolls were not submitted to the District. Questioned Costs: $0, program funding associated with construction was used for supplies and materials only. Such costs were budgeted for, and approved by, the grantor agency. Recommendation: The District should implement internal controls that include review of certified payrolls for all construction projects funded by federal grant dollars. District’s Response: The District agrees with the finding and will develop internal control procedures necessary to correct the condition.

Corrective Action Plan

Corrective Action: The District will be proactive with adherence to all federal requirements, including, but not limited to prevailing wage rate provisions with any contracts moving forward. Additionally, the district will be aware of the need to adhere to these federal requirements when funding streams are blended. The district has already started communication to relay that federal prevailing wage rates should have been utilized. Responsible Person: Nicole Eilola, Shared Services Business Manager & Stacy Price, Superintendent. Anticipated Completion Date: Immediate

Categories

Reporting Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 1089505 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $225,453
10.553 School Breakfast Program $60,551
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $58,900
84.027 Special Education Grants to States $31,134
84.010 Title I Grants to Local Educational Agencies $25,260
84.424 Student Support and Academic Enrichment Program $12,821
84.425 Education Stabilization Fund $8,808
93.778 Medical Assistance Program $3,618
84.358 Rural Education $2,030