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2022-009 Federal Agency: U.S. Department of Education Pass Thru Entity: Oklahoma State Department of Education Program: COVID-19 Education Stabilization Fund Assistance Listing: COVID-19- 84.425D & 84.425U Grant Period: Year ending June 30, 2022 Condition: Construction projects did not obtain certified payrolls documenting compliance with wage rate requirements. Criteria: 29 CFR Part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted construction requires that nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (Which still may be referenced as Davis-Bacon Act). Which includes a requirement for the contractor or subcontractor to submit to the nonfederal entity weekly, for each which in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). Cause: The District had a letter from the contractor certifying compliance with Davis-Bacon Act but were unaware of need to obtain certified payrolls. Effect: The expenditures may be disallowed. Context: Unable to determine labor costs included in applications for payment from the contractor. Repeat Finding from Prior Year: No Recommendation Obtain certified payrolls for construction projects funded with federal awards. Determine that contracts for construction using federal funds include the appropriate clauses to be in compliance with federal procurement guidelines. Views of Responsible Officials And Planned Corrective Action: Lawton Public Schools obtained contractor certification of Davis-Bacon Act compliance, but did not obtain certified payrolls. The district identified this issue early in FY23 and immediately changed funding sources for the project. District construction bidding procedures for federally funded construction have been updated to include verbiage required by the Davis-Bacon Act.