Finding Text
2024-002 Finding in accordance with 2 CFR section 200.516(a)
Program Titles: COVID-19 Education Stabilization Fund
Assistance Listing Number: 84.425
Pass-through Entity: Virginia Department of Education
Compliance Requirement: Special Tests and Provisions
Finding Type: Noncompliance
Criteria: Construction contracts, in excess of $2,000 financed by federal assistance funds, shall include
a provision that the contractor or subcontractor pay prevailing wage rates established by the Department of Labor (DOL). In addition, the contractor or subcontractor must submit to the nonfederal entity a copy of the payroll and a statement of compliance weekly.
Condition: A Federally funded construction contract did not include the provision that the contractor or
subcontractor must pay prevailing wage rates established by the DOL nor did the School Board
receive certified payrolls from the contractor.
Questioned Costs: Unknown
Context: The contracts with this vendor in total were in the amount of $165,720 for renovations at
Blue Ridge Elementary. The School Board had program expenditures totaling $1,042,347 and
it appears there were only two vendors that were required to comply with these Special Tests
and Provisions. The other contractor complied with these requirements.
Effect: Unable to determine if prevailing wage rates were paid on the construction contract.
Cause: The federal program is fairly new and the compliance requirement was not known by School
Board personnel. In addition, guidance from the federal government was not provided by the
State Funding Agency.
Recommendation: Management should implement a process to review compliance requirements for all federal
assistance funds grants to ensure that all compliance requirements have been met.
Management's Response: Management will review its process for reviewing compliance requirements for all federal assistance funds.