Finding 518575 (2024-004)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-01-10

AI Summary

  • Core Issue: The School Board lacks adequate internal controls to ensure compliance with the Davis-Bacon Act wage requirements for federally funded contracts.
  • Impacted Requirements: Compliance with 29 CFR 5.5 and 2 CFR 200.303(a) is not being met, risking noncompliance with federal labor standards.
  • Recommended Follow-Up: Enhance policies to include regular wage verification, contractor payroll monitoring, and proper documentation of compliance efforts.

Finding Text

Federal Agency: U.S. Department of Education Federal Program Name: Education Stabilization Fund Assistance Listing Number: 84.425 Federal Award Identification Number and Year: S45U210005 Pass-Through Agency: Maryland State Department of Education Pass-Through Number: 211935 Award Period: 3/24/2021 - 9/30/2023 Type of Finding: Significant Deficiency in Internal Control over Compliance, Other Matters Criteria or Specific Requirement: Compliance: The Davis-Bacon Act requires that laborers and mechanics employed by contractors and subcontractors in the performance of federally funded or assisted contracts in excess of $2,000 for construction, alteration, or repair (including painting and decorating) of public buildings or public works must be paid wages not less than those established by the Secretary of Labor. Adequate monitoring of compliance with these wage requirements is required to ensure that workers are being paid correctly as per 29 CFR 5.5 compliance provisions. Control: Per 2 CFR section 200.303(a), a non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should comply with the guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control-Integrated Framework," issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO). Condition: During our testing, we noted the School Board did not have adequate internal controls designed to ensure vendors were in compliance with applicable Davis-Bacon Wage Rate requirements. Questioned Costs: There are no questioned costs related to this finding. Context: The School Board did not retain documentation supporting indication of their review of certified payroll records in accordance with monitoring compliance with the Davis-Bacon Act requirements for contracts funded by the Education Stabilization Fund. Additionally, for one out of twenty-two payroll periods tested, the School Board was not able to provide payroll documentation certified by the vendor. Cause: The Board’s procedures and internal controls over monitoring Davis-Bacon Act compliance were not sufficiently designed or implemented to ensure that wage determinations were verified and that contractors and subcontractors were monitored for compliance. Effect: Failure to monitor Davis-Bacon wage requirements may result in noncompliance with federal labor standards and could potentially lead to financial penalties, reputational damage, and a loss of future federal funding. Repeat Finding: No Recommendation: We recommend that the Board enhance its policies and procedures to ensure the effective monitoring of compliance with Davis-Bacon wage requirements. Procedures should include regular verification of wage determinations, monitoring of contractor and subcontractor payrolls, and documentation of compliance efforts. Views of responsible officials: Management acknowledges the finding and agrees with the recommendation and will implement corrective action.

Categories

Subrecipient Monitoring Significant Deficiency Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties Special Tests & Provisions

Other Findings in this Audit

  • 518539 2024-003
    Material Weakness Repeat
  • 518540 2024-003
    Material Weakness Repeat
  • 518541 2024-003
    Material Weakness Repeat
  • 518542 2024-003
    Material Weakness Repeat
  • 518543 2024-003
    Material Weakness Repeat
  • 518544 2024-003
    Material Weakness Repeat
  • 518545 2024-003
    Material Weakness Repeat
  • 518546 2024-003
    Material Weakness Repeat
  • 518547 2024-003
    Material Weakness Repeat
  • 518548 2024-003
    Material Weakness Repeat
  • 518549 2024-003
    Material Weakness Repeat
  • 518550 2024-003
    Material Weakness Repeat
  • 518551 2024-003
    Material Weakness Repeat
  • 518552 2024-003
    Material Weakness Repeat
  • 518553 2024-003
    Material Weakness Repeat
  • 518554 2024-003
    Material Weakness Repeat
  • 518555 2024-003
    Material Weakness Repeat
  • 518556 2024-003
    Material Weakness Repeat
  • 518557 2024-003
    Material Weakness Repeat
  • 518558 2024-003
    Material Weakness Repeat
  • 518559 2024-003
    Material Weakness Repeat
  • 518560 2024-003
    Material Weakness Repeat
  • 518561 2024-003
    Material Weakness Repeat
  • 518562 2024-003
    Material Weakness Repeat
  • 518563 2024-003
    Material Weakness Repeat
  • 518564 2024-003
    Material Weakness Repeat
  • 518565 2024-003
    Material Weakness Repeat
  • 518566 2024-003
    Material Weakness Repeat
  • 518567 2024-003
    Material Weakness Repeat
  • 518568 2024-003
    Material Weakness Repeat
  • 518569 2024-003
    Material Weakness Repeat
  • 518570 2024-004
    Significant Deficiency
  • 518571 2024-004
    Significant Deficiency
  • 518572 2024-004
    Significant Deficiency
  • 518573 2024-004
    Significant Deficiency
  • 518574 2024-004
    Significant Deficiency
  • 518576 2024-002
    Material Weakness
  • 518577 2024-002
    Material Weakness
  • 518578 2024-002
    Material Weakness
  • 518579 2024-002
    Material Weakness
  • 1094981 2024-003
    Material Weakness Repeat
  • 1094982 2024-003
    Material Weakness Repeat
  • 1094983 2024-003
    Material Weakness Repeat
  • 1094984 2024-003
    Material Weakness Repeat
  • 1094985 2024-003
    Material Weakness Repeat
  • 1094986 2024-003
    Material Weakness Repeat
  • 1094987 2024-003
    Material Weakness Repeat
  • 1094988 2024-003
    Material Weakness Repeat
  • 1094989 2024-003
    Material Weakness Repeat
  • 1094990 2024-003
    Material Weakness Repeat
  • 1094991 2024-003
    Material Weakness Repeat
  • 1094992 2024-003
    Material Weakness Repeat
  • 1094993 2024-003
    Material Weakness Repeat
  • 1094994 2024-003
    Material Weakness Repeat
  • 1094995 2024-003
    Material Weakness Repeat
  • 1094996 2024-003
    Material Weakness Repeat
  • 1094997 2024-003
    Material Weakness Repeat
  • 1094998 2024-003
    Material Weakness Repeat
  • 1094999 2024-003
    Material Weakness Repeat
  • 1095000 2024-003
    Material Weakness Repeat
  • 1095001 2024-003
    Material Weakness Repeat
  • 1095002 2024-003
    Material Weakness Repeat
  • 1095003 2024-003
    Material Weakness Repeat
  • 1095004 2024-003
    Material Weakness Repeat
  • 1095005 2024-003
    Material Weakness Repeat
  • 1095006 2024-003
    Material Weakness Repeat
  • 1095007 2024-003
    Material Weakness Repeat
  • 1095008 2024-003
    Material Weakness Repeat
  • 1095009 2024-003
    Material Weakness Repeat
  • 1095010 2024-003
    Material Weakness Repeat
  • 1095011 2024-003
    Material Weakness Repeat
  • 1095012 2024-004
    Significant Deficiency
  • 1095013 2024-004
    Significant Deficiency
  • 1095014 2024-004
    Significant Deficiency
  • 1095015 2024-004
    Significant Deficiency
  • 1095016 2024-004
    Significant Deficiency
  • 1095017 2024-004
    Significant Deficiency
  • 1095018 2024-002
    Material Weakness
  • 1095019 2024-002
    Material Weakness
  • 1095020 2024-002
    Material Weakness
  • 1095021 2024-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
10.555 National School Lunch Program $7.63M
21.027 Coronavirus State and Local Fiscal Recovery Funds $3.02M
32.009 Emergency Connectivity Fund Program $1.35M
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $867,369
84.424 Student Support and Academic Enrichment Program $733,114
10.558 Child and Adult Care Food Program $641,981
10.579 Child Nutrition Discretionary Grants Limited Availability $457,774
84.010 Title I Grants to Local Educational Agencies $221,275
10.582 Fresh Fruit and Vegetable Program $210,956
84.181 Special Education-Grants for Infants and Families $104,432
84.425 Education Stabilization Fund $46,803
84.048 Career and Technical Education -- Basic Grants to States $46,129
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $42,716
10.185 Local Food for Schools Cooperative Agreement Program $26,072
84.196 Education for Homeless Children and Youth $25,453
84.365 English Language Acquisition State Grants $13,849
93.434 Every Student Succeeds Act/preschool Development Grants $13,306
10.542 Pandemic Ebt Food Benefits $3,256
84.173 Special Education Preschool Grants $833
84.027 Special Education Grants to States $191