Finding Text
2024-004 Education Stabilization Fund – COVID 19 – Assistance Listing No. 84.425
Compliance Requirement: Special Tests & Provisions – Davis-Bacon Act
Type of Finding: Significant Deficiency in Internal Control Over Compliance
Fiscal Year Finding Initially Occurred 2024
Criteria: For construction contracts financed in whole or in part with federal funds exceeding
$2,000, the Davis-Bacon Act requires the grantee to: (1) Obtain weekly certified
payrolls from each contractor and subcontractor. (2) Review those payrolls to verify
that employees are paid at least the prevailing wage and fringe benefits for the
corresponding labor classifications.
Condition: During our testing, it was determined that the payrolls were not monitored timely to
ensure that employees were paid the prevailing wage rate.
Cause: The School Board’s grant administration team lacks formally documented procedures
and training related to Davis-Bacon compliance.
Effect: Lack of timely monitoring of the payrolls could result in underpayment of wages due
during the contract period to the contractor and not qualifying for reimbursement
from the grantor.
Recommendation: The School Board should take the necessary steps to ensure that staff are
appropriately trained and contractor payrolls are monitored timely.
Views of Responsible Officials: The School System’s grant administration team will complete the
necessary training related to Davis-Bacon to ensure that contractors are in
compliance with the Davis Bacon Act.