EIN: 346002998
UEI: P2K7KNUJQK96
Audited by: Keith Faber, Auditor of State of Ohio
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 June 25, 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 December 25, 2026 (113 days from today).
What is a management decision? →FAC accepted this audit on August 27, 2025 — management decision was due February 27, 2026.
FAC accepted this audit on March 28, 2024 — management decision was due September 28, 2024.
FAC accepted this audit on March 28, 2023 — management decision was due September 28, 2023.
FAC accepted this audit on June 5, 2022 — management decision was due December 5, 2022.
2 CFR ? 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR ? 200. Thus, this ? gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE. 2 CFR ? 200, Appendix II (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148), provides 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 ? 5, ?Labor Standards Provisions 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. 2 CFR ? 176.190 Award term - Wage rate requirements under Section 1606 of the Recovery Act, provides 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, U.S.C. In April 2020, the District entered into an Energy Services Agreement (the Agreement) with Plug Smart. The Agreement included $535,845 for the Marlboro Elementary School Variable Refrigerant Flow (VRF) improvements. The District subsequently paid Plug Smart $536,681 from Elementary and Secondary School Emergency Relief (ESSER) federal grant monies. However, the required prevailing wage rate provision was not included in the Agreement. In addition, the District did not obtain certified payroll reports from Plug Smart to verify prevailing wages were paid. Lack of proper internal controls over federal grants management let to the noncompliance. At the time of procurement, the District intended to pay Plug Smart from the Capital Project - Nexus Fund. Therefore, the Agreement did not include prevailing wage provisions. Failure to notify contractors of the prevailing wage rate requirements may result in noncompliance with the Davis-Bacon Act requirements as well as potentially reduce future federal grant funding. The District should ensure contracts for construction in excess of $2,000 paid with federal grant monies include a provision that contractors comply with the prevailing wage rate provisions and ensure certified payroll reports are provided by the contractor weekly. The District should maintain the certified payroll reports to document compliance with the program requirements. The District should report all suspected violations to the Federal awarding agency.
Show full finding ▾Hide full finding ▴2 CFR ? 3474.1 provides the Department of Education (DOE) adopts the Office of Management and Budget (OMB) Guidance in 2 CFR ? 200. Thus, this ? gives regulatory effect to the OMB guidance and supplements the guidance as needed for the DOE. 2 CFR ? 200, Appendix II (D) Davis-Bacon Act, as amended (40 U.S.C. 3141-3148), provides 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 ? 5, ?Labor Standards Provisions 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. 2 CFR ? 176.190 Award term - Wage rate requirements under Section 1606 of the Recovery Act, provides 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, U.S.C. In April 2020, the District entered into an Energy Services Agreement (the Agreement) with Plug Smart. The Agreement included $535,845 for the Marlboro Elementary School Variable Refrigerant Flow (VRF) improvements. The District subsequently paid Plug Smart $536,681 from Elementary and Secondary School Emergency Relief (ESSER) federal grant monies. However, the required prevailing wage rate provision was not included in the Agreement. In addition, the District did not obtain certified payroll reports from Plug Smart to verify prevailing wages were paid. Lack of proper internal controls over federal grants management let to the noncompliance. At the time of procurement, the District intended to pay Plug Smart from the Capital Project - Nexus Fund. Therefore, the Agreement did not include prevailing wage provisions. Failure to notify contractors of the prevailing wage rate requirements may result in noncompliance with the Davis-Bacon Act requirements as well as potentially reduce future federal grant funding. The District should ensure contracts for construction in excess of $2,000 paid with federal grant monies include a provision that contractors comply with the prevailing wage rate provisions and ensure certified payroll reports are provided by the contractor weekly. The District should maintain the certified payroll reports to document compliance with the program requirements. The District should report all suspected violations to the Federal awarding agency.
The District is aware of the requirement in Federal program legislation to ensure inclusion of the prevailing wage rate provision in Agreements, as well as to obtain certified payroll reports to verify prevailing wages were paid. At the time the District entered into the Agreement with PlugSmart to renovate Marlboro Elementary which was April, 2020, ESSER funds were not awarded to the District. The District planned on using its Capital Projects Fund (a non-federal program sourced Fund) to pay PlugSmart. The District initially paid PlugSmart from the Capital Projects Fund for the installation of heating/hvac unit at Marlboro Elementary. Once the ESSER funds were awarded, they allowed for previous expenses related to improving air quality to be included as part of reimbursement through the ESSER Funds. The District confirmed with PlugSmart via email that prevailing wage requirements would be met, however, the Agreement was not modified, nor was the documentation to support that the prevailing wage requirements were met even after several attempts to collect from PlugSmart and the related subcontractor. The District has implemented the following Action Plan for Correction: 1) The Treasurer will ensure that all Agreements intended to be sourced through Federal Programs will contain Prevailing Wage rate provisions prior to signing such agreements. 2) The Treasurer will ensure that invoices from contractors contain the necessary prevailing wage certified payroll reports prior to approving such invoices for payment from Federal Programs. 3) The Treasurer will educate the Payables and Budgetary Clerks regarding prevailing wage documentation requirements to ensure appropriate documentation is obtained prior to payment to Contractors and prior to requesting funds from Federal Programs.
FAC accepted this audit on June 27, 2021 — management decision was due December 27, 2021.
FAC accepted this audit on March 5, 2020 — management decision was due September 5, 2020.
FAC accepted this audit on March 20, 2019 — management decision was due September 20, 2019.
FAC accepted this audit on February 13, 2018 — management decision was due August 13, 2018.
FAC accepted this audit on February 21, 2017 — management decision was due August 21, 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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