EMERSON-HUBBARD COMMUNITY SCHOOLS DISTRICT NO. 561Local Government

2024-004 INTERNAL CONTROL OVER SCHEDULE OF EXPENDITURES OF FEDERAL AWARDS PREPARATION AND REVIEW Criteria As described in our engagement letter, management is responsible for establishing and maintaining internal controls, including monitoring, and for the fair presentation of the schedule of expenditures of federal awards, including the notes to the schedule of expenditures of federal awards, in conformity with the modified cash basis of accounting. Condition The District does not have a system of internal control that would provide management with reasonable assurance that the District's schedule of expenditures of federal awards and related disclosures are complete and presented in accordance with the modified cash basis of accounting. As such, management requested us to compile the trial balance from the general ledger and prepare a draft of the schedule of expenditures of federal awards, including the related note disclosures. Cause Management does not prepare the schedule of expenditures of federal awards in accordance with the modified cash basis of accounting. Potential Effect The potential exists that a material misstatement of the schedule of expenditures of federal awards could occur and not be prevented or detected by the District's internal control. Recommendation We recommend that the District review and approve the proposed auditor adjusting entries and the adequacy of schedule of the expenditures of federal awards disclosures prepared by the auditors and apply analytic procedures to the draft financial statements, among other procedures as considered necessary by management. Views of Responsible Officials and Planned Corrective Actions The District relies on the auditor to propose adjustments necessary to prepare the schedule of expenditures of federal awards including the related note disclosures. The District reviews schedule of expenditures of federal awards and approves all adjustments.

COMPLIANCE REGARDING DAVIS-BACON REQURIMENT Criteria Federally funded construction projects using ESSER III funds must comply with Davis-Bacon Act requirements, ensuring contractors pay prevailing wages as determined by the U.S. Department of Labor. Districts must verify wage rates and collect certified payroll records before authorizing payments Condition The District included Davis-Bacon requirements in bid documents for an ESSER III-funded window replacement project, but the contractor did not submit certified payroll documentation, and the District failed to enforce compliance before issuing payments Cause Despite outlining wage requirements in the bid, the District did not follow through with enforcement, leading to non-compliance. Potential Effect The District cannot demonstrate compliance with federal labor standards, risking liability for unpaid wages and potential audit findings, corrective actions, or withholding of future federal funding. Recommendation The District should establish procedures to verify prevailing wage compliance, require certified payroll records before payments, conduct periodic audits, and assign personnel to review payroll documentation. Strengthening oversight will ensure adherence to federal labor standards and prevent similar issues. Views of Responsible Officials and Planned Corrective Actions Management acknowledges the oversight and is implementing corrective measures, including requiring certified payroll documentation, enhancing monitoring procedures, and assigning personnel to oversee Davis-Bacon compliance. The District is working with contractors and state officials to resolve the issue and improve internal controls.