EIN: 636000850
UEI: VLW6L2DPH373
Data as of August 24, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on May 5, 2025. 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 November 5, 2025 (292 days ago).
What is a management decision? →Finding: Title 29, U. S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the “Davis-Bacon Act”), requires that any construction contract in excess of $2,000 that is funded wholly or in part by federal funds include prevailing wage rate clauses. The laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for locality of project (prevailing wage rates) by the Department of Labor (DOL) and the contractor or subcontractor must submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). During fiscal year 2024, the Board entered into two construction projects with the contracts totaling $13,219,577.00 without including the prevailing wage rate clauses. The Board approved $1,801,803.86 of these projects to be paid with COVID-19 Education Stabilization American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Funds. As of September 30, 2024, the Board had expended $1,567,401.21 of COVID-19 Education Stabilization Funds American Rescue Plan (Elementary and Secondary School Emergency Relief (ARP ESSER) Funds on the projects with $335,172.53 related to labor costs. The Board did not have controls in place to ensure the Davis-Bacon Act wage rate requirements were included in the construction contracts; therefore, the construction project contracts awarded did not include prevailing wage rate clauses nor did the contractors or subcontractors submit weekly certified payrolls to the Board. As a result, the Board was not in compliance with the Davis-Bacon Act as it pertains to wage rate requirements. Recommendation: The Board should comply with Title 29, U. S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the “Davis-Bacon Act”) when using COVID-19 Education Stabilization Funds (ESSER) to fund construction contracts in excess of $2,000 by ensuring prevailing wage rate clauses are included in contracts and certified payrolls are obtained. View of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Show full finding ▾Hide full finding ▴Finding: Title 29, U. S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the “Davis-Bacon Act”), requires that any construction contract in excess of $2,000 that is funded wholly or in part by federal funds include prevailing wage rate clauses. The laborers and mechanics employed by contractors or subcontractors to work on construction contracts in excess of $2,000 financed by federal assistance funds must be paid wages not less than those established for locality of project (prevailing wage rates) by the Department of Labor (DOL) and the contractor or subcontractor must submit to the nonfederal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls). During fiscal year 2024, the Board entered into two construction projects with the contracts totaling $13,219,577.00 without including the prevailing wage rate clauses. The Board approved $1,801,803.86 of these projects to be paid with COVID-19 Education Stabilization American Rescue Plan Elementary and Secondary School Emergency Relief (ARP ESSER) Funds. As of September 30, 2024, the Board had expended $1,567,401.21 of COVID-19 Education Stabilization Funds American Rescue Plan (Elementary and Secondary School Emergency Relief (ARP ESSER) Funds on the projects with $335,172.53 related to labor costs. The Board did not have controls in place to ensure the Davis-Bacon Act wage rate requirements were included in the construction contracts; therefore, the construction project contracts awarded did not include prevailing wage rate clauses nor did the contractors or subcontractors submit weekly certified payrolls to the Board. As a result, the Board was not in compliance with the Davis-Bacon Act as it pertains to wage rate requirements. Recommendation: The Board should comply with Title 29, U. S. Code of Federal Regulations, Part 5, Sub-Part A Davis Bacon and Related Acts Provisions and Procedures (the “Davis-Bacon Act”) when using COVID-19 Education Stabilization Funds (ESSER) to fund construction contracts in excess of $2,000 by ensuring prevailing wage rate clauses are included in contracts and certified payrolls are obtained. View of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions.
Views of Responsible Officials of the Auditee Management agrees with this finding and will take corrective actions. Corrective Action Plan The Board is in the process of amending the Construction Contracts so the prevailing wage rate clauses are included and the General Contractors are collecting certified payrolls to make sure the prevailing wage rates were met. Anticipated Completion Date April 30, 2025 Contact Person(s) Anthony Cooper, Chief School Financial Officer
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