Finding 611581 (2022-001)

Material Weakness
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-30

AI Summary

  • Core Issue: Devils Lake Public School District failed to comply with wage rate requirements for ESSER funding and lacked effective internal controls for certified payrolls.
  • Impacted Requirements: Noncompliance with 40 USC wage rate laws and internal control standards as per Uniform Guidance and the Green Book.
  • Recommended Follow-Up: Implement procedures to ensure wage rate compliance and establish internal controls for federal awards as outlined in the recommendations.

Finding Text

2022-001 COVID 19 - EDUCATION STABILIZATION FUND ? INTERNAL CONTROLS AND WAGE RATE REQUIREMENTS ? ALN 84.425D ? MATERIAL WEAKNESS AND MATERIAL NONCOMPLIANCE FINDING TYPE: Material Weakness ? Material Noncompliance Finding 2022-001 Federal Program: COVID 19 - Education Stabilization Fund ALN: 84.425D Federal Award Number(s) and Year(s): S425U210007, 2022 Federal Agency: U.S. Department of Education Pass Through Agency: North Dakota Department of Public Instruction Questioned Cost: $0 Condition Devils Lake Public School District did not comply with the wage rate requirements applicable to the Elementary and Secondary School Emergency Relief Fund (ESSER) funding received for the renovation of a current building into a childcare and preschool center. Further, Devils Lake Public School District did not establish and maintain effective internal controls to ensure certified payrolls are received from the contractors. Context Devils Lake Public School District completed one construction project during fiscal year 2022 that was subject to the wage rate requirements. The approved project cost was $60,000. Where sampling was performed, the audit used a non-statistical sampling method. Effect Devils Lake Public School District was not in compliance with the wage rate requirements for the ESSER program. In addition, laborers may not have been paid the prevailing wage rates. Cause Devils Lake Public School District may not have been aware of the wage rate requirements applicable to construction contracts in excess of $2,000 financed by federal assistance funds. Devils Lake Public School District may not have been aware of the requirement to document and develop internal controls related to the federal programs. Criteria All laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages no less than those established for the locality of the project (prevailing wage rates) by the Department of Labor - 40 USC 3141-3144, 3146, and 3147. "Standards for Internal Control in the Federal Government" (Green Book) requires management to design, implement, and operate internal controls to achieve its objectives related to operations, reporting, and compliance. Management is to design appropriate types of control activities for the entity's internal control system. Control activities help management fulfill responsibilities and address identified risk responses in the internal control system. Uniform Guidance 2 CFR 200.303(a) states ?The non-Federal entity must establish and maintain effective internal control over the Federal award that provides reasonable assurance that the non-Federal entity is managing the Federal award in compliance with Federal statutes, regulations, and the terms and conditions of the Federal award. These internal controls should be in compliance with guidance in "Standards for Internal Control in the Federal Government" issued by the Comptroller General of the United States or the "Internal Control Integrated Framework", issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).? Questioned Costs None. Prior Recommendation No. Recommendation We recommend Devils Lake Public School District implement procedures to ensure compliance with the wage rate requirements of 40 USC 3141-3144, 3146, and 3147. We also recommend they establish and maintain internal controls over Federal awards in compliance with the Uniform Guidance 2 CFR 200.303(a) and the Green Book. Devils Lake Public School District No. 1?s Response See Corrective Action Plan

Categories

Material Weakness Reporting Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 35138 2022-002
    Material Weakness
  • 35139 2022-001
    Material Weakness
  • 611580 2022-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.010 Title I Grants to Local Educational Agencies $761,066
84.425 Covid 19 - Education Stabilization Fund $504,015
84.371 Striving Readers $330,653
84.287 Twenty-First Century Community Learning Centers $267,313
84.367 Improving Teacher Quality State Grants $252,725
10.553 School Breakfast Program $247,094
84.041 Impact Aid $154,945
84.060 Indian Education_grants to Local Educational Agencies $137,562
84.425 Covid-19 - Education Stabilization Fund $135,002
84.424 Student Support and Academic Enrichment Program $114,954
10.555 National School Lunch Program $97,473
84.048 Career and Technical Education -- Basic Grants to States $83,279
12.U01 Army Junior Reserve Officer Training Corps. (jrotc) $62,020
10.582 Fresh Fruit and Vegetable Program $57,017
10.560 State Administrative Expenses for Child Nutrition $9,934
10.579 Child Nutrition Discretionary Grants Limited Availability $8,713
10.559 Summer Food Service Program for Children $1,596
10.649 Pandemic Ebt Administrative Costs $614