EIN: 316400666
UEI: SVYADHDT9VM7
Audited by: Wilson, Shannon and Snow, Inc.
Oversight agency: 84 [Department of Education]
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Data as of August 28, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on January 22, 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 July 22, 2026 (39 days ago).
What is a management decision? →FAC accepted this audit on January 16, 2025 — management decision was due July 16, 2025.
FAC accepted this audit on March 11, 2024 — management decision was due September 11, 2024.
FAC accepted this audit on March 11, 2023 — management decision was due September 11, 2023.
FAC accepted this audit on March 28, 2022 — management decision was due September 28, 2022.
Title of Finding: Indirect Costs Finding Number: 2021-001 AL Number and Title: AL# 84.184 G - School Safety National Activities- School Climate Transformation Grant Federal Award Identification Number / Year: 2021 Federal Agency: U.S. Department of Education Compliance Requirement: Section A- Activities Allowed Or Unallowed/ Section B- Allowable Costs/Cost Principles Pass-Through Entity: N/A Repeat Finding from Prior Audit? No Questioned Cost/Noncompliance/Material Weakness 2 C.F.R. ? 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. ? 200.413(c) which provides, in part, that the salaries of administrative staff should normally be treated as indirect facilities and administration (F&A) costs. Direct charging of these costs may be appropriate only if all of the following conditions are met: (1) Administrative services are integral to a project or activity; (2) Individuals involved can be specifically identified with the project or activity; (3) Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and (4) The costs are not also recovered as indirect costs. 2 C.F.R. ? 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. ? 200.430 which states, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. The District's Federal UG Policies & Procedures Policy governs the controls and records needed to demonstrate Time and Effort for federal expenditures. The District used semi-annual certifications to meet the documentation requirements for direct charges and serve as established internal control over the process. The Policy further states that the District currently does not charge indirect costs to Federal grants. The Grant Award Agreement indicates any grantee charging indirect costs to a grant must use the indirect cost rate (ICR), negotiated with its cognizant agency, i.e., either the Federal agency from which it has received the most direct funding, subject to indirect cost support, the particular agency specifically assigned cognizance by the Office of Management and Budget, or the State agency that provides the most subgrant funds to the grantee. During fiscal year 2021, the District expended $46,967 in wages and $8,500 in related employee benefits from the School Climate Transformation Grant for an administrator position due to posting adjustments to the accounting system at year end. The District failed to explicitly identify this position on the budget for the School Climate Transformation Grant (AL# 84.184G) and the employee signed semi-annual certifications indicating 100% of his time was spent on another grant during the fiscal year. Therefore, we consider the salaries and related benefits for this administrator in the amount of $55,467 to be a questioned cost. The failure to document administrative positions as meeting the requirements of 2 C.F.R. ? 200.413(c) while charging them as direct costs could lead to future questioned costs, reduced future federal funding, and the requirement to repay the U.S. Department of Education. The Treasurer and Project Director should ensure all employees charging direct salaries and benefits to federal grants maintain the appropriate documentation and meet the requirements to charge directly. Further, the Treasurer and Project Director should ensure all employees charging indirect salaries and benefits to federal grants do so through the appropriate ICR negotiated with the cognizant agency.
Show full finding ▾Hide full finding ▴Title of Finding: Indirect Costs Finding Number: 2021-001 AL Number and Title: AL# 84.184 G - School Safety National Activities- School Climate Transformation Grant Federal Award Identification Number / Year: 2021 Federal Agency: U.S. Department of Education Compliance Requirement: Section A- Activities Allowed Or Unallowed/ Section B- Allowable Costs/Cost Principles Pass-Through Entity: N/A Repeat Finding from Prior Audit? No Questioned Cost/Noncompliance/Material Weakness 2 C.F.R. ? 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. ? 200.413(c) which provides, in part, that the salaries of administrative staff should normally be treated as indirect facilities and administration (F&A) costs. Direct charging of these costs may be appropriate only if all of the following conditions are met: (1) Administrative services are integral to a project or activity; (2) Individuals involved can be specifically identified with the project or activity; (3) Such costs are explicitly included in the budget or have the prior written approval of the Federal awarding agency; and (4) The costs are not also recovered as indirect costs. 2 C.F.R. ? 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. ? 200.430 which states, in part, that costs of compensation are allowable to the extent that they satisfy the specific requirements of this part, and that the total compensation for individual employees is reasonable for the services rendered and conforms to the established written policy of the non-Federal entity consistently applied to both Federal and non-Federal activities. The District's Federal UG Policies & Procedures Policy governs the controls and records needed to demonstrate Time and Effort for federal expenditures. The District used semi-annual certifications to meet the documentation requirements for direct charges and serve as established internal control over the process. The Policy further states that the District currently does not charge indirect costs to Federal grants. The Grant Award Agreement indicates any grantee charging indirect costs to a grant must use the indirect cost rate (ICR), negotiated with its cognizant agency, i.e., either the Federal agency from which it has received the most direct funding, subject to indirect cost support, the particular agency specifically assigned cognizance by the Office of Management and Budget, or the State agency that provides the most subgrant funds to the grantee. During fiscal year 2021, the District expended $46,967 in wages and $8,500 in related employee benefits from the School Climate Transformation Grant for an administrator position due to posting adjustments to the accounting system at year end. The District failed to explicitly identify this position on the budget for the School Climate Transformation Grant (AL# 84.184G) and the employee signed semi-annual certifications indicating 100% of his time was spent on another grant during the fiscal year. Therefore, we consider the salaries and related benefits for this administrator in the amount of $55,467 to be a questioned cost. The failure to document administrative positions as meeting the requirements of 2 C.F.R. ? 200.413(c) while charging them as direct costs could lead to future questioned costs, reduced future federal funding, and the requirement to repay the U.S. Department of Education. The Treasurer and Project Director should ensure all employees charging direct salaries and benefits to federal grants maintain the appropriate documentation and meet the requirements to charge directly. Further, the Treasurer and Project Director should ensure all employees charging indirect salaries and benefits to federal grants do so through the appropriate ICR negotiated with the cognizant agency.
Finding Number: 2021-001 Planned Corrective Action: Seek approval of USDOE of costs inclusion into SCTG: Upon notification of Finding 2021-001 and review of the facts, the District contacted the United States Department of Education consultant who reviews and approves costs associated with SCTG. Given the District information as provided in the Response to Finding 2021-001, these costs have been approved by the grant contact at USDOE for inclusion in SCTG. The District has provided time and effort logs as related documentation. Further, the District intends to closely follow procedural guidelines pertaining to federal grant management in order to prevent future issues as described in Finding 2021-001. Anticipated Completion Date: April 29, 2022 Responsible Contact Person: Paul F. Shaw, CPA CGMA RSBFO, Treasurer
Title of Finding: Approval and Prevailing Wage Rate Requirements Finding Number: 2021-002 AL Number and Title: AL# 84.425D - Education Stabilization Fund Federal Award Identification Number / Year: 2021 Federal Agency: U.S. Department of Education Compliance Requirement: Section A- Activities Allowed Or Unallowed/ Section B- Allowable Costs/Cost Principles/ F. Equipment And Real Property Management/ N. Special Tests and Provisions ? Wage Rate Requirements Pass-Through Entity: Ohio Department of Education Repeat Finding from Prior Audit? No Questioned Cost/Noncompliance/Material Weakness 2 C.F.R. ? 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. ? 200.439 which states, in part, that capital expenditures for general purpose equipment, buildings and land and improvements to land, buildings, or equipment which materially increase their value or useful life are unallowable as a direct cost except with the prior written approval of the Federal awarding agency or pass-through entity. 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: (D) 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 Contract 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 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 paragraphs: (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 expending $875,000 of its Education Stabilization Fund (ESSER II) AL# 84.425D federal grant funds for installation of turf for educational and athletic areas. Due to a lack of proper internal controls over Federal Grants management, the District?s contract with this vendor did not include a provision to ensure the contactor complied with Federal wage rate requirements. Additionally, the District could not provide support that weekly certified payroll were provided by the contractor. Also, the District failed to have this capital expenditure pre-approved by the pass-through entity Ohio Department of Education. Therefore, we consider the amount of $875,000 to be a questioned cost. Failure to obtain proper pre-approval for capital expenditures could lead to future questioned costs, reduced future federal funding, and the requirement to repay the Ohio Department of Education. Failure to notify contractors of the wage rate requirements may result in noncompliance with the prevailing wage requirements as well as potentially reduced future federal funding. The Treasurer and Superintendent should ensure all capital expenditures paid by federal grant funds have the proper pre-approval. Further, the District should ensure contracts for construction in excess of $2,000 contain a provision the contractor comply with the Wage Rate Requirements and 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 they have 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 ▴Title of Finding: Approval and Prevailing Wage Rate Requirements Finding Number: 2021-002 AL Number and Title: AL# 84.425D - Education Stabilization Fund Federal Award Identification Number / Year: 2021 Federal Agency: U.S. Department of Education Compliance Requirement: Section A- Activities Allowed Or Unallowed/ Section B- Allowable Costs/Cost Principles/ F. Equipment And Real Property Management/ N. Special Tests and Provisions ? Wage Rate Requirements Pass-Through Entity: Ohio Department of Education Repeat Finding from Prior Audit? No Questioned Cost/Noncompliance/Material Weakness 2 C.F.R. ? 3474.1 gives regulatory effect to the Department of Education for 2 C.F.R. ? 200.439 which states, in part, that capital expenditures for general purpose equipment, buildings and land and improvements to land, buildings, or equipment which materially increase their value or useful life are unallowable as a direct cost except with the prior written approval of the Federal awarding agency or pass-through entity. 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: (D) 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 Contract 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 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 paragraphs: (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 expending $875,000 of its Education Stabilization Fund (ESSER II) AL# 84.425D federal grant funds for installation of turf for educational and athletic areas. Due to a lack of proper internal controls over Federal Grants management, the District?s contract with this vendor did not include a provision to ensure the contactor complied with Federal wage rate requirements. Additionally, the District could not provide support that weekly certified payroll were provided by the contractor. Also, the District failed to have this capital expenditure pre-approved by the pass-through entity Ohio Department of Education. Therefore, we consider the amount of $875,000 to be a questioned cost. Failure to obtain proper pre-approval for capital expenditures could lead to future questioned costs, reduced future federal funding, and the requirement to repay the Ohio Department of Education. Failure to notify contractors of the wage rate requirements may result in noncompliance with the prevailing wage requirements as well as potentially reduced future federal funding. The Treasurer and Superintendent should ensure all capital expenditures paid by federal grant funds have the proper pre-approval. Further, the District should ensure contracts for construction in excess of $2,000 contain a provision the contractor comply with the Wage Rate Requirements and 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 they have an obligation under 29 CFR Part 5 to report all suspected or reported violations to the Federal awarding agency.
Finding Number: 2021-002 Planned Corrective Action:Pay Davis-Bacon Prevailing Wage Rates Owed to Laborers: Upon notification of Finding 2021-002, the District contacted the Motz Group, the contractor hired to perform the Logan High School Turf Project (the ?Project?), and requested documentation stating the amount paid to all personnel that worked on the Project. The District also requested that Motz provide documentation showing the amounts required to be paid to Project personnel pursuant to the Davis-Bacon Act. If Project personnel were paid less than required by the Davis-Bacon Act, the District will pay Motz the deficiency with the contractual requirement that Motz will pay the Project personnel any wages owed under the Davis-Bacon Act. This requirement will take the form of an add change order to the contract between Motz and the District. Further, the District intends to closely follow internal controls pertaining to federal grant management in order to prevent future issues as described in Finding 2021-002. Anticipated Completion Date: April 29, 2022 Responsible Contact Person: Paul F. Shaw, CPA CGMA RSBFO, Treasurer
FAC accepted this audit on December 29, 2020 — management decision was due June 29, 2021.
FAC accepted this audit on February 12, 2020 — management decision was due August 12, 2020.
FAC accepted this audit on January 14, 2019 — management decision was due July 14, 2019.
FAC accepted this audit on January 7, 2018 — management decision was due July 7, 2018.
GSA_MIGRATION
Show full finding ▾Hide full finding ▴FAC accepted this audit on January 2, 2017 — management decision was due July 2, 2017.
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