Wage rate requirements for contracts using 84.425 Education Stabilization Funds
a. Type of deficiency: Material Weakness
i. Condition: The District did not obtain copies of certified payroll and statements of compliance from contractors that worked on construction contracts in excess of $2,000 financed by federal assistance funds. A material weakness in controls over compliance with wage rate requirements was identified.
ii. Cause: As the District does not typically fund construction projects with federal funds, the District’s staff were unaware of the requirement to obtain copies of certified payroll and statements of compliance from contractors that worked on construction contracts in excess of $2,000 financed by federal assistance funds.
iii. Effect or potential effect : Without adequate internal controls over wage rate requirements and including the required provisions in construction contracts in excess of $2,000 financed by ESF funds, the District cannot demonstrate compliance with the wage rate requirements of the Davis-Bacon Act requirements
iv. Questioned costs: Questioned costs, if any, are indeterminable.
v. Context: Out of a population of 11 contracts, 4 contracts were selected to test wage rate requirements. The District did not obtain copies of certified payroll and statements of compliance for the 4 contracts selected.
vi. Recommendation: The District should obtain an understanding of all compliance requirements and implement controls to ensure compliance with federal wage rate requirements.
b. District staff representatives from Facilities, Business Services, and Grant Accounting will participate in at least one Oregon Bureau of Labor and Industry (BOLI) seminar titled Prevailing Wage Rate Laws for Public Agencies in Spring 2025. The Grant Manager will be directed to provide prevailing wage training specific for federal grants to Facilities and Grant Accounting staff .
c. Date of scheduled BOLI seminars: February 6, 2025, March 19, 2025, and April 29, 2025. Additional training to be done by June 30, 2025.