Klamath-Trinity Joint Unified School District

2022-002 50000 (Significant Deficiency and Noncompliance) Federal Program Affected Program Name: COVID-19: Elementary and Secondary Emergency Relief II (ESSER II) Fund Assistance Listing Number: 84.425D Federal Agency: U.S. Department of Education Pass-Through Entity: California Department of Education Compliance Requirement: Equipment and Real Property Management Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 requires the District to obtain written approval from the California Department of Education (CDE) prior to purchasing equipment for which the per unit costs exceeds $5,000. Condition The District expended $71,283 of ESSER II funds on capital expenditures that were not preapproved by the pass-through agency, as required. The District has submitted the request for a retroactive approval in March 2023; however, the District has not received a response. Questioned Costs As a result of the condition identified above, a total of $71,283 in questioned costs were identified. Context The condition was identified as a result of inquiry with the District's Business Services personnel and review of ESSER II expenditures and related invoices. Effect The District currently assumes all the risk of non-compliance with requirements stated under Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 due to the lack of preapproval from the pass-through agency, as required.Cause The condition identified appears to have materialized due to the District's lack of awareness of requirements under Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439. Repeat Finding No. Recommendation The District should review the requirements stated in Title 2, Code of Federal Regulations, Part 200, Subpart E, Section 200.439 and implement a procedure to address the deficiency currently identified. Corrective Action Plan and Views of Responsible Officials The District?s Budget and Purchasing Technician will ensure that each department manager submits the requirements with the needs to the State prior to purchasing.

2022-003 50000 (Significant Deficiency and Noncompliance) Federal Program Affected Program Name: Impact Aid Assistance Listing Number: 84.041 Federal Agency: U.S. Department of Education Pass-Through Entity: N/A ? Direct-funded Compliance Requirement: Special Tests and Provisions Type of Finding: Significant Deficiency and Noncompliance Criteria or Specific Requirements As required by Title 2, Subtitle A, Chapter II, Part 200, Appendix II to Part 200, Section (D), all prime construction contracts in excess of $2,000 awarded by non-federal entities must require contractors to pay rates that are not less than the prevailing wages specified in a wage determination made by the Secretary of Labor (Davis-Bacon Act). To comply with this requirement, contractors or subcontractors are required to submit weekly copies of the payroll records and statements of compliance to the nonfederal entity. Condition The District does not have a procedure in place to ensure compliance with the prevailing wage requirement (Davis-Bacon Act). As a result, the District was unable to provide supporting documents. Questioned Costs There were no questioned costs identified related to the condition identified above. Context The condition was identified during the course of our review of supporting documents and our inquiry with District?s personnel. Effect Since the District does not have a procedure in place to ensure compliance with the prevailing wage requirement (Davis-Bacon Act), the District has a higher risk of non-compliance with this requirement. Additionally the District was unable to demonstrate its compliance with the prevailing wage requirement. Cause The condition appears to be attributed to the District?s lack of procedures that are in place to ensure compliance. Repeat Finding No. Recommendation The District should adopt and implement procedures that are aligned with requirements outlined in Title 2, Subtitle A, Chapter II, Part 200, Appendix II to Part 200, Section (D). Failure to adopt and implement these procedures will increase the likelihood of the District?s noncompliance with this requirement. Corrective Action Plan and Views of Responsible Officials The District?s Maintenance and Transportation Director will establish a procedure guide for future projects to meet the requirements of prevailing wages as well as all other State compliances for facility projects.

GSA_MIGRATION