Finding Text
AL 84.425D – Elementary and Secondary School Emergency Relief Fund, U.S. Department of Education.
Passed through New York State Education Department, Award Number 5891
Criteria: Requirements per 2 CFR Section 200.303 of the Uniform Guidance state that non-federal entities must
establish and maintain effective internal control over federal awards to provide reasonable assurance that the nonfederal
entity is managing the federal award in accordance with federal statutes, regulations, and terms and
conditions of the awards received.
Condition: Management had not established an adequate system of internal control over compliance with the
relevant federal statutes, regulations, and terms and conditions of the federal awards as management’s internal
control procedures did not cause the entity to comply with the Special Tests and Provisions related to Wage Rate
Requirements under the Elementary and Secondary School Emergency Relief Fund.
Cause: Management did not have adequate internal controls in place to identify and comply with Wage Rate
Requirements established under 29 CFR Part 5.
Effect or Potential Effect: Without appropriate internal controls over compliance, non-compliance could occur
which the entity may not identify. Laborers and mechanics employed by contractors and subcontractors may not
have been paid in accordance with local prevailing wage rates. We were not able to determine if the entity was in
compliance with this compliance requirement as appropriate documentation was not requested from the applicable
contractor.
Questioned Costs: N/A
Repeat Finding?: Yes, see finding 2022-001.
Recommendation: Management should implement internal controls over Wage Rate Requirements to ensure
compliance with applicable Federal statutes, regulations, and terms and conditions of the awards received.
Views of Responsible Officials:
We are in agreement with the finding. GCCS management will retain documentation to support proper operation of
internal controls and compliance with applicable Federal statutes, regulations, Wage Rate Requirements, and other
terms and conditions of awards received.
Auditor’s Evaluation of the Views of Responsible Officials:
Management’s response is appropriate to address the finding. If properly implemented, management’s response
would include procedures to prevent reoccurrence in the future.