Finding Text
Finding Number: 2023‐002
Repeat Finding: No
Program Name/Assistance Listing Title: Education Stabilization Fund
Assistance Listing Number: 84.425D, 84.425U, 84.425W
Federal Agency: Arizona Department of Education
Federal Award Number: S425D200038, S425U210038, S425W210003
Pass‐Through Agency: N/A
Questioned Costs: Unknown
Type of Finding: Noncompliance, Significant Deficiency
Compliance Requirement: Special Tests and Provisions
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 not less than
those established for the locality of the project (prevailing wage rates) by the Department of Labor
(DOL) (40 USC §§ 3141‐3144, 3146, and 3147).
Condition
It could not be determined whether laborers and mechanics employed by contractors or
subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance
funds were paid equal to or in excess of the prevailing wage rate for the locality.
Cause
The expenditures were originally not spent with Federal dollars but were later moved to a federal
funding source via adjusting journal entry. As a result, the District did not inform the
contractor/subcontractor of the wage rate requirements. Moreover, the District completed the ADE
certifications indicating they would comply with Davis Bacon; however, they did not follow through.
Effect
The District did not comply with the special tests and provisions requirement of the grant.
Context
For one of two vendors where wage rate requirements were applicable, the District did not notify
contractors and subcontractors of the requirements to comply with the wage rate requirements and
did not obtain copies of certified payrolls for construction projects funded with grant monies. The
sample was not intended to be, and was not, a statistically valid sample.
Recommendation
The District should review Federal requirements over Davis Bacon, develop policies and procedures,
and ensure those developed policies and procedures are implemented. Views of Responsible Officials
See Corrective Action Plan.