Finding Text
US DEPARTMENT Of EDUCATIONUS DEPARTMENT Of EDUCATION Education Stabilization Fund (ESF) Elementary and Secondary School Emergency Relief (ESSER) Fund CFDA# 84.425D Significant Deficiency 2022-001 Condition and criteria: The District should have control processes in place to ensure that projects subject to prevailing wage requirements are performed under those requirements. There were two small projects that were subject to Federal prevailing wage requirements but did not get performed or documented for those requirements. Cause: The District?s controls are established to follow prevailing wage requirements for projects over $50,000, which is the State of Oregon requirement and was unaware that the Federal requirement was for projects over $2,000. Context and effect: The District has very few capital projects funded by grant dollars, but there were two HVAC projects for $48,966 and $38,840, which fell between the Federal and State guidelines. Materials were the main portion of the costs of the project and the difference between prevailing wage rates to actual rates are not expected to be material to IMESD or the program. Auditor?s recommendation: We recommend the District update their policies and procedures to identify Federal prevailing wage requirements at the lower threshold. Management response: Management agrees with the audit finding. Management has reviewed the federal compliance supplement for Assistance Listing 84.425 Education Stabilization Fund, in particular Section F Equipment/Real Property Management. Capital projects now go through a review process to ensure both state and federal procurement laws are followed. In addition, Management has updated procurement procedures to include review of compliance supplement for federal funded purchases.