SOUTH CARROLL SPECIAL SCHOOL DISTRICTLocal Government

Davis Bacon Act prevailing wage requirements were not included in the contract or discussed with the contractor and Davis Bacon Act record retention requirements were not followed during the duration of the contruction project (significant deficiency and noncompliance). ALN Titlte and number: Education Stabilization Fund #84.425. Name of the Federal Agency: US Department of Education. Internal Control over Compliance: Auditee responsibilities. Condition and Context: The District did not discuss the need to meet the Davis Bacon Act prevailing wage requirements with the roof replacement contractor before requesting bids or signing a contract. The District also did not receive wage reports during the duration of the project and in turn, did not ensure that the contractor was in compliance with the Davis Bacon Act for prevailing wage rates paid to employees that worked on the roof replacement project prior to completion. The oversight was recognized prior to reimbursement and they took action to try to remedy the noncompliance by requesting the missing documentation after the fact. Criteria: Per the 2023 compliance supplement, recipients and subrecipients that use the ESF funds for minor remodeling, renovation or construction contracts that are over $2,000and use laborers and mechanics must meet the Davis-Bacon prevailing wage requirements. Cause: The District had not implemented any controls or processes to ensure compliance with this requirement prior to executing contracts. Effect: Non-compliance with the Uniform Guidance for the Federal grant funding received. And this non-compliance could have led to additional funds being needed to compensate for a lower than prevainling wage rate paid to the Contrator's employees or it could have led to disallowed costs and a resulting repayment of federal grant funds received. Questioned Cost: Unknown. Repeated Finding: No. Recommendation: We recommend the District make the Davis Bacon Act pevailing wage requirements known as a requirement to contractors before accepting bids on projects in the future. We also recommend that the District make sure the contract ageement for the project includes a requirement for the contractor to comply with the Davis Bacon Act regarding prevailing wage rates. And we recommend the District receive weekly wage reports for the duration of the project and compare the wages paid with the prevailing wage rayes to ensure compliance with the Davis Bacon Act. Respnse: For any construction or building improvements requiring the use of contractors in the future, management will discuss adherence to the Davis Bacon Act regarding prevailing wages with the contractors and obtain documentation from the contractors demonstrating compliance with the Act.