Finding 957636 (2023-002)

Material Weakness
Requirement
N
Questioned Costs
$1
Year
2023
Accepted
2024-03-19

AI Summary

  • Core Issue: There is a material weakness in internal controls regarding compliance with federal education fund requirements, specifically related to prevailing wage verification for construction projects.
  • Impacted Requirements: Compliance with 2 CFR 200.303 and Davis-Bacon Act for construction contracts over $2,000 was not ensured, affecting two projects funded by federal education funds.
  • Recommended Follow-Up: PLA should implement a process to verify subcontractor compliance with prevailing wage requirements for future construction contracts using federal education funds.

Finding Text

2023 – 002: Special Tests and Provisions Federal Agency: U.S Department Education Federal Program Name: Education Stabilization Funds Assistance Listing Number: 84.425D, 84.425U Pass-Through Agency: Indiana Department of Education Pass-Through Numbers: S425D200013, S425D210013, S425U210013 Award Period: July 1, 2022 – June 30, 2023 Type of Finding: • Material Weakness in Internal Control over Compliance • Other Matters Criteria or specific requirement: Per 2 CFR 200.303, "The non-Federal entity must: (a) 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). If governors, SEAs, and or subrecipients propose to use ESF funds for construction they must also comply with applicable requirements in 34 CFR section 76.600 and 34 CFR sections 75.600–617. Approved construction projects must comply with all other applicable Uniform Guidance requirements, as well as the ED’s regulations regarding construction, as applicable, at 34 CFR section 76.600. As is the case with all construction contracts using laborers and mechanics financed by federal education funds, recipients and subrecipients that use ESF funds for construction contracts over $2,000 must meet Davis-Bacon prevailing wage requirements. Condition: PLA did not verify compliance with prevailing wage requirements with subcontractors for construction projects financed by federal education funds. Questioned costs: $342,069. Context: 2 of 2 construction projects financed by federal education funds were subject to prevailing wage requirements. Cause: PLA was not familiar with using federal education funds for construction costs and were not aware of the prevailing wage requirements Effect: Laborers and mechanics paid by subcontractors may have been paid below prevailing wage rates. Repeat Finding: No. Recommendation: We recommend that for future construction contracts financed by federal education funds PLA verify that subcontractors comply with prevailing wage requirements. Views of responsible officials: There is no disagreement with the audit finding.

Categories

Questioned Costs Special Tests & Provisions Subrecipient Monitoring Material Weakness Matching / Level of Effort / Earmarking Internal Control / Segregation of Duties

Other Findings in this Audit

  • 381194 2023-002
    Material Weakness
  • 381195 2023-002
    Material Weakness
  • 957637 2023-002
    Material Weakness

Programs in Audit

ALN Program Name Expenditures
84.425 Education Stabilization Fund $4.52M
84.010 Title I Grants to Local Educational Agencies $2.72M
10.555 National School Lunch Program $1.96M
84.027 Special Education_grants to States $468,255
84.282 Charter Schools $439,043
84.367 Improving Teacher Quality State Grants $317,853
84.424 Student Support and Academic Enrichment Program $143,783
84.031 Higher Education_institutional Aid $4,185