EIN: 310714641
UEI: QC4HC4EH5J31
Audited by: Keith Faber, Auditor of State
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on April 14, 2026. Under 2 CFR 200.521(d), a pass-through entity that provided federal funds to this organization for this audit period must issue a management decision on these findings by October 14, 2026 (40 days from today).
What is a management decision? →2 C.F.R. § 3474.1 gives regulatory effect to the Department of Education for Appendix II to 2 C.F.R. § 200 Paragraph D which states: Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146- 3148) as supplemented by Department of Labor regulations (29 CFR Part 5, "Labor Standards Provision Applicable to Contracts Covering Federally Financed and Assisted Construction"). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The contracts must also include a provision for compliance with the Copeland "Anti-Kickback" Act (40 U.S.C. 3145), as supplemented by Department of Labor regulations (29 CFR Part 3, "Contractors and Subcontractors on Public Building or Public Work Financed in Whole or in Part by Loans or Grants from the United States"). The Act provides that each contractor or subrecipient must be prohibited from inducing, by any means, any person employed in the construction, completion, or repair of public work, to give up any part of the compensation to which he or she is otherwise entitled. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. 2 CFR § 176.190 Award term - Wage rate requirements under Section 1606 of the Recovery Act indicates when issuing announcements or requesting applications for Recovery Act programs or activities that may involve construction, alteration, maintenance, or repair the agency shall use the award term described in the following paragraph: (a) Section 1606 of the Recovery Act requires that all laborers and mechanics employed by contractors and subcontractors on projects funded directly by or assisted in whole or in part by and through the Federal Government pursuant to the Recovery Act shall be paid wages at rates not less than those prevailing on projects of a character similar in the locality as determined by the Secretary of Labor in accordance with subchapter IV of chapter 31 of title 40, United States Code. The District expended $133,330 of its Education Stabilization Fund AL# 84.425U federal grant funds for a Welding Lab Exhaust System project. Due to a lack of proper internal controls over federal grants management, the District did not have a contract with this vendor that included a provision to ensure the contractor complied with federal wage rate requirements. Additionally, the District could not provide support that weekly certified payroll was provided by the contractor. Failure to have effective controls in place over wage-rate requirements may result in the District and its contractors or subcontractors failing to pay prevailing wages when required by Federal law and could result in reduction of future Federal funding or other sanctions imposed by Federal grantors. When required by Federal grant legislation, the District should ensure prime contracts for construction in excess of $2,000 paid with Federal grant monies contain a provision the contractor comply with the Wage Rate Requirements and the DOL regulations (29 CFR Part 5). Further the District should ensure certified payroll reports are provided weekly by the contractor. The District should obtain the necessary information from the contractor to document compliance with the program requirements and if the contractor failed to comply then the District has an obligation under 29 CFR Part 5 to report all suspected or reported violations to the Federal awarding agency.
Show full finding ▾Hide full finding ▴2 C.F.R. § 3474.1 gives regulatory effect to the Department of Education for Appendix II to 2 C.F.R. § 200 Paragraph D which states: Davis-Bacon Act, as amended (40 U.S.C. 3141-3148). When required by Federal program legislation, all prime construction contracts in excess of $2,000 awarded by non-Federal entities must include a provision for compliance with the Davis-Bacon Act (40 U.S.C. 3141-3144, and 3146- 3148) as supplemented by Department of Labor regulations (29 CFR Part 5, "Labor Standards Provision Applicable to Contracts Covering Federally Financed and Assisted Construction"). In accordance with the statute, contractors must be required to pay wages to laborers and mechanics at a rate not less than the prevailing wages specified in a wage determination made by the Secretary of Labor. In addition, contractors must be required to pay wages not less than once a week. The non-Federal entity must place a copy of the current prevailing wage determination issued by the Department of Labor in each solicitation. The decision to award a contract or subcontract must be conditioned upon the acceptance of the wage determination. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. The contracts must also include a provision for compliance with the Copeland "Anti-Kickback" Act (40 U.S.C. 3145), as supplemented by Department of Labor regulations (29 CFR Part 3, "Contractors and Subcontractors on Public Building or Public Work Financed in Whole or in Part by Loans or Grants from the United States"). The Act provides that each contractor or subrecipient must be prohibited from inducing, by any means, any person employed in the construction, completion, or repair of public work, to give up any part of the compensation to which he or she is otherwise entitled. The non-Federal entity must report all suspected or reported violations to the Federal awarding agency. 2 CFR § 176.190 Award term - Wage rate requirements under Section 1606 of the Recovery Act indicates when issuing announcements or requesting applications for Recovery Act programs or activities that may involve construction, alteration, maintenance, or repair the agency shall use the award term described in the following paragraph: (a) Section 1606 of the Recovery Act requires that all laborers and mechanics employed by contractors and subcontractors on projects funded directly by or assisted in whole or in part by and through the Federal Government pursuant to the Recovery Act shall be paid wages at rates not less than those prevailing on projects of a character similar in the locality as determined by the Secretary of Labor in accordance with subchapter IV of chapter 31 of title 40, United States Code. The District expended $133,330 of its Education Stabilization Fund AL# 84.425U federal grant funds for a Welding Lab Exhaust System project. Due to a lack of proper internal controls over federal grants management, the District did not have a contract with this vendor that included a provision to ensure the contractor complied with federal wage rate requirements. Additionally, the District could not provide support that weekly certified payroll was provided by the contractor. Failure to have effective controls in place over wage-rate requirements may result in the District and its contractors or subcontractors failing to pay prevailing wages when required by Federal law and could result in reduction of future Federal funding or other sanctions imposed by Federal grantors. When required by Federal grant legislation, the District should ensure prime contracts for construction in excess of $2,000 paid with Federal grant monies contain a provision the contractor comply with the Wage Rate Requirements and the DOL regulations (29 CFR Part 5). Further the District should ensure certified payroll reports are provided weekly by the contractor. The District should obtain the necessary information from the contractor to document compliance with the program requirements and if the contractor failed to comply then the District has an obligation under 29 CFR Part 5 to report all suspected or reported violations to the Federal awarding agency.
The district purchased a welding lab exhaust system through the ESSER program as part of the welding shop renovation project. While the primary contract for the project included the required Davis-Bacon provisions, a separate purchase was made for the exhaust system that was believed to be equipment only. However, the vendor agreement included labor, and the existing contract did not cover this portion of the work. As a result, the required Davis-Bacon language was not included, and certified payroll documentation was not obtained. The district does not typically pay for construction projects involving labor with federal funds. To address this moving forward, the district is implementing additional review procedures to ensure all federally funded purchases are evaluated for potential labor components prior to approval. Any purchase involving labor will include the required federal provisions and documentation. The district will also strengthen internal communication during project planning to ensure all components are properly identified and compliant.
FAC accepted this audit on March 27, 2025 — management decision was due September 27, 2025.
FAC accepted this audit on March 25, 2024 — management decision was due September 25, 2024.
FAC accepted this audit on March 29, 2023 — management decision was due September 29, 2023.
FAC accepted this audit on April 4, 2022 — management decision was due October 4, 2022.
FAC accepted this audit on March 29, 2021 — management decision was due September 29, 2021.
FAC accepted this audit on March 22, 2020 — management decision was due September 22, 2020.
FAC accepted this audit on March 31, 2019 — management decision was due October 1, 2019.
FAC accepted this audit on March 28, 2018 — management decision was due September 28, 2018.
FAC accepted this audit on March 28, 2017 — management decision was due September 28, 2017.
Data source: This information comes from the Federal Audit Clearinghouse, the official repository of Single Audit data. All data is public domain. Verify this organization's audit history at fac.gov.
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