EIN: 596000878
UEI: LLTSN4MRLTN6
Audited by: Auditor General
Oversight agency: 97 [Department of Homeland Security]
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Data as of September 7, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on February 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 August 25, 2026 (15 days ago).
What is a management decision? →FAC accepted this audit on January 17, 2025 — management decision was due July 17, 2025.
FAC accepted this audit on January 31, 2024 — management decision was due July 31, 2024.
Finding - District controls did not always ensure compliance with the Davis-Bacon Act for Federally funded construction projects exceeding $2,000, resulting in questioned costs totaling $214,559. Criteria - The ES Fund provides Federal funds for school facility repairs and improvements. Title 29, Section 5.5, Code of Federal Regulations (Davis‑Bacon Act), requires the District to include prevailing wage rate clauses in any construction contract exceeding $2,000 that is financed either wholly or in part by Federal funds and ensure that contractors pay workers the prevailing wage rates established by the United States Department of Labor. This includes a requirement for the contractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). The United States Department of Labor established “prevailing wages” by geographic area and interprets the Davis‑Bacon Act to apply to construction, alteration, or repair of public buildings or public work. Conditions - For the 2022-23 fiscal year, the District expended ES Fund moneys totaling $4.8 million, including $1,421,060 for services related to heating, ventilation, and air-conditioning replacement, flooring replacement renovation, electrical replacement, and remodeling renovations. We noted that the purchase orders, requests for proposals, and contracts for those services did not contain clauses that required compliance with the Davis-Bacon Act provisions and the contractors did not submit weekly certified payrolls to the District. Subsequent to our inquiry, District personnel obtained certified payrolls from one contractor that demonstrated the prevailing wage rates were paid for one project totaling $1,206,501. Cause - According to District personnel, the District was not aware that the Davis-Bacon Act applied to all of these Federally funded projects and, due to an oversight, did not include the appropriate wage rate clauses in the applicable procurement documents. Effect - Absent the required contract clauses and weekly certified payrolls, there is an increased risk that construction contractors paid with Federal moneys will not pay workers the prevailing wage rates established by the United States Department of Labor. Although we requested, the District did not provide certified payrolls from seven contractors demonstrating that the prevailing wage rates were paid for some services, resulting in questioned costs totaling $214,559. Recommendations - The District should enhance procedures to ensure compliance with all Davis‑Bacon Act requirements. Such procedures should ensure that applicable Federally funded facility contracts require submittal of weekly certified payrolls and that District personnel verify the payrolls are received and demonstrate that prevailing wage rates are paid. In addition, the District should document to the FDOE the allowability of the questioned costs or contact the FDOE regarding necessary corrective action. District Response - The Districts has developed and implemented procedures to ensure that weekly payroll records related to construction contracts funded via Federal funds are obtained and reviewed with every invoice. This process will ensure compliance with Title 29, Section 5.5, Code of Federal Regulations – Davis-Bacon Act. All subsequent construction contracts will include a prevailing wage clause for amounts over $2,000.00.
Show full finding ▾Hide full finding ▴Finding - District controls did not always ensure compliance with the Davis-Bacon Act for Federally funded construction projects exceeding $2,000, resulting in questioned costs totaling $214,559. Criteria - The ES Fund provides Federal funds for school facility repairs and improvements. Title 29, Section 5.5, Code of Federal Regulations (Davis‑Bacon Act), requires the District to include prevailing wage rate clauses in any construction contract exceeding $2,000 that is financed either wholly or in part by Federal funds and ensure that contractors pay workers the prevailing wage rates established by the United States Department of Labor. This includes a requirement for the contractor to submit to the District weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). The United States Department of Labor established “prevailing wages” by geographic area and interprets the Davis‑Bacon Act to apply to construction, alteration, or repair of public buildings or public work. Conditions - For the 2022-23 fiscal year, the District expended ES Fund moneys totaling $4.8 million, including $1,421,060 for services related to heating, ventilation, and air-conditioning replacement, flooring replacement renovation, electrical replacement, and remodeling renovations. We noted that the purchase orders, requests for proposals, and contracts for those services did not contain clauses that required compliance with the Davis-Bacon Act provisions and the contractors did not submit weekly certified payrolls to the District. Subsequent to our inquiry, District personnel obtained certified payrolls from one contractor that demonstrated the prevailing wage rates were paid for one project totaling $1,206,501. Cause - According to District personnel, the District was not aware that the Davis-Bacon Act applied to all of these Federally funded projects and, due to an oversight, did not include the appropriate wage rate clauses in the applicable procurement documents. Effect - Absent the required contract clauses and weekly certified payrolls, there is an increased risk that construction contractors paid with Federal moneys will not pay workers the prevailing wage rates established by the United States Department of Labor. Although we requested, the District did not provide certified payrolls from seven contractors demonstrating that the prevailing wage rates were paid for some services, resulting in questioned costs totaling $214,559. Recommendations - The District should enhance procedures to ensure compliance with all Davis‑Bacon Act requirements. Such procedures should ensure that applicable Federally funded facility contracts require submittal of weekly certified payrolls and that District personnel verify the payrolls are received and demonstrate that prevailing wage rates are paid. In addition, the District should document to the FDOE the allowability of the questioned costs or contact the FDOE regarding necessary corrective action. District Response - The Districts has developed and implemented procedures to ensure that weekly payroll records related to construction contracts funded via Federal funds are obtained and reviewed with every invoice. This process will ensure compliance with Title 29, Section 5.5, Code of Federal Regulations – Davis-Bacon Act. All subsequent construction contracts will include a prevailing wage clause for amounts over $2,000.00.
Planned Corrective Action - Procedures have been developed and implemented to ensure that weekly payroll records related to construction contracts funded via federal funds are obtained and reviewed with every invoice. This process will ensure compliance with Title 29, Section 5.5, Code of Federal Regulations - Davis Bacon Act. All subsequent construction contracts will include a prevailing wage clause for amounts over $2,000.00. Anticipated Completion Date - January 2024 Responsible Contact Person - Ashley Valentine, Finance Director
FAC accepted this audit on January 9, 2023 — management decision was due July 9, 2023.
FAC accepted this audit on February 24, 2022 — management decision was due August 24, 2022.
FAC accepted this audit on December 7, 2020 — management decision was due June 7, 2021.
FAC accepted this audit on February 11, 2020 — management decision was due August 11, 2020.
FAC accepted this audit on February 12, 2019 — management decision was due August 12, 2019.
FAC accepted this audit on January 28, 2018 — management decision was due July 28, 2018.
FAC accepted this audit on March 19, 2017 — management decision was due September 19, 2017.
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