Finding 528719 (2024-001)

Significant Deficiency
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-18

AI Summary

  • Core Issue: The District failed to collect and review certified payroll for construction contracts over $2,000 funded by Impact Aid, violating federal wage rate requirements.
  • Impacted Requirements: Compliance with Wage Rate Requirements under federal guidelines, specifically for construction projects financed by federal assistance.
  • Recommended Follow-Up: The District should assess all federally-funded projects to identify those needing wage rate compliance and ensure certified payroll is obtained from contractors.

Finding Text

Finding Number: 2024‐001 Repeat Finding: No Program Name/Assistance Listing Title: Impact Aid Assistance Listing Number: 84.041 Federal Agency: Department of Education Federal Award Number: N/A Pass‐Through Agency: N/A Questioned Costs: N/A Type of Finding: Noncompliance, Significant Deficiency Compliance Requirement: Special Tests and Provisions Criteria According to Federal guidelines, §7007 construction funds, as well as any §7002 or §7003(b) funds expended for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b).  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 not  less  than  those  established  for  the  locality  of  the  project  (prevailing  wage  rates)  by  the  Department of Labor (DOL) (40 USC 3141–3144, 3146, and 3147). Condition Certified payroll from the contractor or subcontractor was not submitted or reviewed for contracts in excess of $2,000 financed by Impact Aid funds. Cause The  District  was  unaware  that  Impact  Aid  construction  expenditures  were  subject  to  wage  rate  requirements. Effect The District could not demonstrate that prevailing wage rates were paid on all applicable projects during the year. Context For four Impact Aid funded projects, the District did not obtain or review contractor or subcontractor certified payroll. The sample was not intended to be, and was not, a statistically valid sample. Recommendation The District should review all federally‐funded projects and determine which are subject to prevailing wage  rate  requirements.  When  applicable,  the  District  should  obtain  certified  payroll  from  contractors and subcontractors to determine that prevailing wage rate requirements are met. Views of Responsible Officials See Corrective Action Plan.

Corrective Action Plan

Finding Number: 2024‐001 Program Name/Assistance Listing Title: Impact Aid Assistance Listing Number: 84.041 Contact Person: Michelle Quiroz, Director of Finance Anticipated Completion Date: April 1, 2025 Planned Corrective Action: The District will provide training for all relevant personnel (procurement team members and project managers) on the need for certified payroll compliance and the consequences of non‐compliance; specifically emphasizing the requirements of the Davis‐Bacon Act and how to properly submit certified payroll documentation. The District will also implement a process to review contractors on federal projects, their compliance with certified payroll requirements, and their contracts to ensure the requirement for timely and accurate certified payroll submissions is included.

Categories

Special Tests & Provisions Significant Deficiency

Other Findings in this Audit

  • 1105161 2024-001
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.027 Special Education Grants to States $2.58M
84.041 Impact Aid $832,334
84.010 Title I Grants to Local Educational Agencies $606,226
10.555 National School Lunch Program $405,551
12.404 National Guard Challenge Program $392,850
84.367 Supporting Effective Instruction State Grants (formerly Improving Teacher Quality State Grants) $373,482
10.553 School Breakfast Program $353,477
84.048 Career and Technical Education -- Basic Grants to States $222,600
93.354 Public Health Emergency Response: Cooperative Agreement for Emergency Response: Public Health Crisis Response $99,746
84.027 Covid-19 Special Education Grants to States $76,027
84.424 Student Support and Academic Enrichment Program $61,214
84.173 Special Education Preschool Grants $44,536
93.778 Medical Assistance Program $42,437
84.365 English Language Acquisition State Grants $24,495
84.425 Covid-19 Education Stabilization Fund $22,235
93.243 Substance Abuse and Mental Health Services Projects of Regional and National Significance $12,524
84.196 Education for Homeless Children and Youth $11,439