Finding Text
Federal Agency: U.S. Department of Education Passthrough Entity: Missouri Department of Elementary and Secondary Education Assistance Listing Number and Federal Program: 84.425U American Rescue Plan-Elementary and Secondary School Emergency Relief Compliance Requirement: F. Equipment and Real Property Management Criteria: 2 CFR section 200.313(d) states ?(1) Property records must be maintained that include a description of the property, a serial number or other identification number, the source of funding for the property, who holds title, the acquisition date, and cost of the property, percentage of Federal participation in the project costs for the Federal award under which the property was acquired, the location, use and condition of the property, and any ultimate disposition data including the date of disposal and sales price of the property. (2) A physical inventory of the property must be taken and the results reconciled with the property records at least once every two years. (3) A control system must be developed to ensure adequate safeguards to prevent loss, damage, or theft of the property. Any loss, damage, or theft must be investigated. Additionally, the District did not comply with 29 CFR section 5.5 (Davis-Bacon Act) which states Federally funded construction projects exceeding $2,000 must include prevailing wage rate clauses and ensure that contractors and subcontractors pay workers the prevailing wage rates established by the Department of Labor. Statement of Condition: During our audit we found the District is not keeping records to specifically track property and equipment acquired with Federal awards, nor is an inventory performed as required. The District used Federal funds for minor remodeling projects and it was found that the District did not ensure the contractors were paying workers correct prevailing wage rates. Statement of Cause: The absence of internal controls over equipment and real property management led to the noncompliance with Federal regulations. Statement of Effect: Equipment purchases with Federal funds may be misallocated or disposed of improperly. A misunderstanding of Davis-Bacon Act requirements increases the risk that contractors and subcontractors paid with Federal funds will not pay the appropriate prevailing wage rates to workers. Questioned Costs: No questioned costs were identified. Perspective Information: This appears to be a systemic problem as it was found no inventory has ever been kept for equipment purchased with Federal funds and therefore no physical inventory has been performed. The issue related to the Davis-Bacon Act is an isolated instance. Identification of Repeat Findings: Not a repeat finding.Recommendation: We recommend the District create an inventory listing of all equipment purchased with Federal funds. The District should create policies and procedures and ensure internal controls are in place to update the listing accurately and timely. Additionally, internal controls should be developed to safeguard the equipment and perform a physical inventory at least once every two years. The District should become familiar with the Davis-Bacon Act requirements and ensure the prevailing wage rate requirements are being followed by its contractors and subcontractors. The District should create policies and procedures to implement a review of the prevailing wage rates paid to workers.