Finding Text
2023-001: Written Internal Controls in regard to Compliance Federal Wage Rate Requirements / Davis Bacon and Suspended, Written or Debarment
Criteria: Recipients and subrecipients that use ESF funds for minor remodeling, renovation or construction contract over $2,000 and use laborers and emchanics must meet Davis-Bacon prevailing wage requirements. Uniform Guidance policies require under 2 CFR Part 180 which states that written policies and procedures related to internal controls be written regarding SAMS.gov contractor verification of debarment and suspension.
Condition and Context: During our detail expenditure testing we found invoices that Platte County School District #1, renovated the Wheatland HS Auditorium and West Elementary School Kitchen. These projects did not provide certified wage rate documentation as required. Furthermore, the District did not verify if the vendors/contractors working on these projects were suspended or debarred prior to making payment.
Cause: Platte County School District #1 was unaware of the Federal requirements. The Grant Award was not explicit in this requirement.
Effect or Potential Effect: Wage rate requirements may not be verified and vendors could be debarred or suspended.
Recommendation: The School District must provide written procedures that related directly to Federal expenditure requirements, incorporating the Davis Bacon Wage Requirements and suspension/debarment verification.