Finding Text
2022-001 Wage Rate Requirements Federal Agency: U.S. Department of Education Assistance Listing Number: 84.425C, 84.425D, 84.425W Pass-Through Agency: Wisconsin Department of Public Instruction Pass-Through Entity Identifying Number: 2021-052289-DPI-ESSERF-160, 2022-052289-DPI-ESSERFII-163, 2021-052289-DPI-GEERF-162, 2022-052289-DPI-ARPHCYI-168 Award period: July 1, 2021 ? June 30, 2022 Type of Finding: Significant Deficiency in Internal Control Over Compliance and Other Matter Compliance Requirements: Special Tests and Provision. Criteria or Specific Requirement: Nonfederal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. Internal controls should be designed and implemented to prevent or detect noncompliance with this requirement. Condition: The District is responsible for ensuring the contractor provides the appropriate certified payrolls and reviewing them to ensure the prevailing wage rates are being met or exceeded. The District did not implement controls to ensure this compliance requirement was met until after the work was completed. Context: While performing audit procedures, it was noted that the District's construction reviewer did not obtain and review the appropriate certified payrolls for the two projects tested in our sample. Questioned Costs: 84.425C, 2021-052289-DPI-GEERF-162 - $60,062. Cause: The District was aware of the wage rate requirements (Davis Bacon Act) and the compliance requirements surrounding it; however, the District did not implement and document controls ensuring this was completed. Effect: The District could pay vendors that are not in compliance with the wage rate requirements (Davis Bacon Act). Repeat Finding: No Recommendation: We recommended the District implement controls to identify when the wage rate requirements are applicable and to ensure that the required documentation is obtained from the vendor on a timely basis and reviewed for completeness.