WEST LYON COMMUNITY SCHOOL DISTRICTLocal Government

2023‐003 Department of Education Elementary and School Emergency Relief CFDA No. 84.425U Special Tests – Wage Rate Requirement Significant Deficiency in Internal Control Over Compliance Criteria: Uniform Guidance and 2 CFR 656.40 through 656.41 set forth the standards nonfederal entities other than states must follow when operating federal programs for wage rates. Condition: The District did not ensure proper and timely inclusion of prevailing wage rate clauses in one construction contract. Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect: Lack of compliance to federal requirements increases the overall risk of non‐compliance. Questioned Costs: None Context/Sampling: Overall compliance requirement Repeat Finding from Prior Year: Yes Recommendation: We recommend that management establish controls to follow all applicable requirements under Uniform Guidance and applicable CFR sections. Views of Responsible Officials: There is no disagreement with the finding.

Criteria: Uniform Guidance and 2 CFR 656.40 through 656.41 set forth the standards nonfederal entities other than states must follow when operating federal programs for wage rates. Condition: The District did not ensure proper and timely inclusion of prevailing wage rate clauses in one construction contract and also did not obtain proper support to ensure required certified payrolls were submitted in a timely fashion. Cause: Lack of oversight, awareness, or understanding of all of the specific requirements under Uniform Guidance and applicable CFR sections, and controls were not adequately designed to ensure compliance with all of these requirements. Effect: Lack of compliance to federal requirements increases the overall risk of non-compliance. Questioned Costs: None Context/Sampling: Overall compliance requirement Repeat Finding from Prior Year: No Recommendation: We recommend that management establish controls to follow all applicable requirements under Uniform Guidance and applicable CFR sections. Views of Responsible Officials: There is no disagreement with the finding.

Criteria: Proper controls over cash management include an adequate system for compilation, review, and approval over federal cash draw processes. Condition: The District has limited staff involved in the process over federal cash draw requests and processes and therefore does not have segregation of duties relating to preparation, review, and approval of federal cash draws. Cause: The federal draws of the district are not reviewed or approved before submitting for reimbursement. The individual preparing the draw also submits the draw without additional review. Effect: Inadequate controls over cash management results in the likelihood that the District would not be able to detect or prevent errors in federal cash draws Questioned Costs: None Context/Sampling: A nonstatistical sample of 4 federal cash draw requests out of 12 federal cash draw requests were selected for testing. Repeat Finding from Prior Year: No Recommendation: The District should implement a review process over the cash draw process of the federal grant draws. Views of Responsible Officials: There is no disagreement with the finding.