Rogers School District #30Local Government

Statement of Condition: None of the current year ESSER construction contracts included the Wage Rate Requirement (Davis-Bacon Act) notification to the contractors, nor was weekly certified payroll received from contractors and their subcontractors. Criteria: 29 CFR sections 5.5 and 5.6; the A-102 Common Rule (section 36(i)(5)); OMB Circular A-110 (2 CFR Part 215, Appendix A, Contract Provisions); 2 CFR Part 176, Subpart C; and 2 CFR section 200.326 require the following for construction contracts in excess of $2,000 financed by federal assistance funds. 1) Construction contracts shall include a provision that contractors or subcontractors comply with the provisions of the Wage Rate Requirements (Davis-Bacon Act). 2) These provisions include a requirement for the contractor or subcontractor to submit to the District weekly, for each week in which any contract work is performed, a copy of certified payroll. Cause of Condition: District employees involved in the construction contract writing process were unaware of this requirement. Effect of condition: All construction contract financed by the ESSER program originated during 2022 did not include the Wage Rate Requirements provision. Context: All four applicable contract were reviewed. This finding was present in all four contracts. Recommendation: To ensure that all construction contracts in excess of $2,000 that are financed by federal assistance funds include the required Wage Rate Requirements provision, additional training in ESSER requirements should be provided for employees involved in the construction contract writing process. Further, a review process should be put in place for all such contracts written in order to ensure that they comply with all the requirements within the Compliance Supplement.

Statement of Condition: Although payroll reports supporting employees? work in the Child Nutrition Cluster program were available for inspection, time certifications were not completed for 5 out of 20 employees tested for Child Nutrition Cluster. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.430 (i)(1) (v) requires that charges to federal awards for salaries and wages must be based on records that comply with the established accounting policies and practices of the District and be supported by personnel time and effort reports. Such records may include personnel activity reports, including prescribed certifications, or equivalent documentation. Per the District?s policies, time certifications over federal expenditures should be properly completed by the appropriate personnel. Cause of condition: Procedures are in place for personnel to complete time certifications at the end of each school semester if employees work 100% in one program or monthly if the employee spends time within multiple programs. However, the District did not properly monitor time and effort record completion and maintenance for employees. Effect of condition: The District was not able to provide required documentation substantiating all time charged to the Child Nutrition Cluster program. Context: A sample of 20 payroll transactions were selected to test controls related to allowable costs. The audit testing found 5 discrepancies related to the monthly review of time certifications. Recommendation: To ensure all time certifications are completed by employees who work within federal programs, a review of completed time certifications should be compared to the employee listing for all federal program employees and procedures should be put in place to collect time certifications during the employee termination or transfer of position process. Views of responsible officials and planned corrective actions: The District agrees with the finding and will obtain time certifications on all federally paid employees.

Statement of Condition: The time certification for the director of the Child Nutrition Cluster program was improperly approved by the director him/herself, and the time certifications for the child nutrition managers were improperly approved by the child nutrition managers themselves with no approval by the director. Criteria: Title 2 U.S. Code of Federal Regulations (CFR) 200.430 (i)(1) (i) requires that salaries and wages charged to federal awards must be supported by system of internal controls that provide reasonable assurance that the charges are accurate, allowable, and properly allocated. Self-approved time certifications do not qualify as reasonable assurance of accurately charged salary and wages. Cause of condition: Procedures are not in place for proper approval of time certifications for personnel of the program by the program director and procedures are not in place for proper approval of the program director?s time certification. Effect of condition: During testing, it was noted that the time certification for the director of the Child Nutrition Cluster programs was completed and approved by the director him/herself. It was also noted that the time certifications for the Child Nutrition managers were completed and approved by the Child Nutrition managers themselves with no approval by the Director of Child Nutrition Cluster. Context: A sample of 20 payroll transactions was selected for audit to test controls related to allowable costs. The test found one discrepancy related to the approval of time certifications for the Director of Child Nutrition and three discrepancies related to the approval of time certifications for the Child Nutrition managers. Recommendation: To ensure time certifications are properly approved, all time certifications should be approved by a superior District officer or director to the person completing the time certification. Views of responsible officials and planned corrective actions: The District agrees with the finding, and time certifications of the Director of Child Nutrition will be approved by a superior District officer to the Director of Child Nutrition.

GSA_MIGRATION

GSA_MIGRATION