Item 2024‐001 – Special Tests and Provisions – Wage Rate Requirements (Repeat)
Recommendation: 2 CFR 200.303 requires the non-Federal entity to “(a) establish and maintain
effective internal controls over the Federal award that provides reasonable assurance that the non-
Federal entity is managing the Federal statutes, regulations, and the terms and conditions of the
Federal award.” 2 CFR 200.326 and 29 CFR Part 5, Labor Standards Provisions Applicable to
Contracts Governing Federally Financed and Assisted Construction (DOL Regulations) require the
contractor or subcontractor to submit to the nonfederal entity weekly, for each week in which any
contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls).
We recommend the strengthening of controls to ensure the prevailing wage rate clauses are
included in the contracts and that certified payrolls are received for each week in which
construction work is performed. The Chief School Financial Officer, Linda Harper, should review
documentation for inclusion of the prevailing wage rate clauses in construction contracts as part of
the bid process prior to expenditures being made. She should also review all invoices received from
contractors and subcontractors to ensure that the certified payroll information is received for all
weeks for which construction work is performed.
Action Taken: Management has reviewed the requirements of 2 CFR Section 200.303 and 2 CFR
200.326 relating to wage rate requirements and agrees with the recommendation. Management
has already communicated with all current contractors and subcontractors regarding the wage rate
requirements for contracts in progress and has implemented additional procedures for future
projects effective October 1, 2024. These additional procedures include the Chief School Financial
Officer (CSFO), Linda Harper, reviewing all proposed construction contracts for inclusion of the
prevailing wage rate clause as part of the bid process prior to expenditures being made. The CSFO
will also review all invoices received from contractors and subcontractors to ensure that the
certified payroll information is received for all weeks for which construction work is performed.