Finding 943280 (2022-010)

Significant Deficiency
Requirement
N
Questioned Costs
$1
Year
2022
Accepted
2024-02-12

AI Summary

  • Core Issue: The School failed to include Davis Bacon Act prevailing wage requirements in contracts and did not discuss them with contractors.
  • Impacted Requirements: Non-compliance with federal grant funding criteria, specifically the need to meet prevailing wage standards for construction contracts over $2,000.
  • Recommended Follow-Up: Ensure future contracts explicitly state Davis Bacon Act compliance, require weekly wage reports during projects, and verify wages against prevailing rates.

Finding Text

Davis Bacon Act prevailing wage requirements were not included in the contract or discussed with the contractor and Davis Bacon Act record retention requirements were not followed during the duration of the construction project (significant deficiency and noncompliance) Condition: Vision Preparatory Charter School, Inc. did not discuss the need to meet the Davis Bacon Act prevailing wage requirements with the roof contractors before requesting bids or signing a contract. The School also did not receive wage reports during the duration of the project and in turn, did not ensure that the contractor was in compliance with the Davis Bacon Act for prevailing wage rates paid to employees that worked on the roof replacement project prior to completion. The oversight was recognized prior to reimbursement and they took action to try to remedy the non compliance by requesting the missing documentation after the fact. Criteria: Per the 2022 Compliance Supplement, recipients and subrecipients that use ESF funds for minor remodeling, renovation or construction contracts that are over $2,000 and use laborers and mechanics must meet Davis-Bacon prevailing wage requirements. Cause: The School had not implemented any controls or processes to ensure compliance with this requirement prior to executing contracts. Effect: Non-compliance with the Uniform Guidance for the federal grant funding received. And this noncompliance could have led to additional funds being needed to compensate for a lower than prevailing wage rate paid to the Contractor's employees or it could have led to disallowed costs and a resulting repayment of federal grant funds received. Questioned Cost: Unknown Recommendation: We recommend the School make the Davis Bacon Act prevailing wage requirements known as a requirement to contractors before accepting bids on projects in the future. We also recommend that the School make sure the contract agreement for the project includes a requirement for the contractor to comply with the Davis Bacon Act regarding prevailing wage rates. And we recommend the School receive weekly wage reports for the duration of the project and compare the wages paid with the prevailing wage rates to ensure compliance with the Davis Bacon Act.

Categories

Questioned Costs Procurement, Suspension & Debarment Subrecipient Monitoring Cash Management Significant Deficiency Internal Control / Segregation of Duties

Other Findings in this Audit

  • 366837 2022-008
    Significant Deficiency
  • 366838 2022-010
    Significant Deficiency
  • 366839 2022-008
    Significant Deficiency
  • 366840 2022-008
    Significant Deficiency
  • 943279 2022-008
    Significant Deficiency
  • 943281 2022-008
    Significant Deficiency
  • 943282 2022-008
    Significant Deficiency

Programs in Audit

ALN Program Name Expenditures
84.425 Elementary and Secondary School Emergency Relief (esser Ii) $970,364
84.425 American Rescue Plan - Elementary and Secondary School Emergency Relief (esser Iii) $261,049
84.010 Title I Grants to Local Education Agencies $211,842
84.425 Elementary and Secondary School Emergency Relief (esser I) $28,233