EIN: 816000892
UEI: QMADBDLNJGY6
Audited by: Wipfli LLP
Oversight agency: 84 [Department of Education]
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Data as of September 2, 2026
Management decision deadline — for entities that funded this organization
The FAC accepted this audit on March 30, 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 September 30, 2026 (27 days from today).
What is a management decision? →FAC accepted this audit on March 25, 2025 — management decision was due September 25, 2025.
The District did not comply with the wage rate compliance related to construction projects for expenditures paid from Impact Aid monies. Context: During the testing of significant claims for the Impact Aid related to construction, we noted claims in which there should be contracts in place and that the wage rate requirements would apply. Questioned Costs: To be determined by grantor. Effect: The District could potentially be misspending Impact Aid construction monies that were received. Cause: The District was aware of the compliance requirement, as it was included in the documented contract request for proposal, which stated that the prevailing wage rate needed to be paid. However, the contract was awarded to a two-member partnership in which the partners do all the work and do not pay salaries and had no subcontractors. As a result, the District and the contractors were unsure how to proceed with compliance with wage rate requirements and no payroll certification was completed. Auditor's Recommendation: To ensure compliance with Wage Rate Requirements, the District should review and update contracting procedures to clearly state prevailing wage rate requirements. Training sessions and guidance should be provided to contractors and subcontractors, especially those without traditional payroll structures. The District should establish a monitoring system to review certified payrolls and conduct periodic audits. In unclear cases, the District should seek guidance from the Department of Labor. Enhancing communication channels between the District, contractors, and subcontractors will help address compliance issues promptly. Implementing these steps will ensure proper use of Impact Aid construction funds. View of Responsible Official: The District has created a standard operating procedure document to follow for all construction projects. The District will also share that document with all contractors to help communicate the needs of the District regarding construction projects. If necessary, the District will provide the contractor with training to make sure all payrolls are properly certified and in compliance with applicable law. The District will also create a shared Google document for each construction project to manage the progress and payments.
Show full finding ▾Hide full finding ▴2024-006 - Wage Rate Compliance Funding Agency: U.S. Department of Education Title: Impact Aid AL Number: 84.041 Award year and number: 2024 Criteria or Specific Requirement: Section 7007 construction funds, as well as any Section 7002 or 7003(b) funds spent for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). All 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 the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141-3144, 3146, and 3147). Non-federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (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). Condition: The District did not comply with the wage rate compliance related to construction projects for expenditures paid from Impact Aid monies. Context: During the testing of significant claims for the Impact Aid related to construction, we noted claims in which there should be contracts in place and that the wage rate requirements would apply. Questioned Costs: To be determined by grantor. Effect: The District could potentially be misspending Impact Aid construction monies that were received. Cause: The District was aware of the compliance requirement, as it was included in the documented contract request for proposal, which stated that the prevailing wage rate needed to be paid. However, the contract was awarded to a two-member partnership in which the partners do all the work and do not pay salaries and had no subcontractors. As a result, the District and the contractors were unsure how to proceed with compliance with wage rate requirements and no payroll certification was completed. Auditor's Recommendation: To ensure compliance with Wage Rate Requirements, the District should review and update contracting procedures to clearly state prevailing wage rate requirements. Training sessions and guidance should be provided to contractors and subcontractors, especially those without traditional payroll structures. The District should establish a monitoring system to review certified payrolls and conduct periodic audits. In unclear cases, the District should seek guidance from the Department of Labor. Enhancing communication channels between the District, contractors, and subcontractors will help address compliance issues promptly. Implementing these steps will ensure proper use of Impact Aid construction funds. View of Responsible Official: The District has created a standard operating procedure document to follow for all construction projects. The District will also share that document with all contractors to help communicate the needs of the District regarding construction projects. If necessary, the District will provide the contractor with training to make sure all payrolls are properly certified and in compliance with applicable law. The District will also create a shared Google document for each construction project to manage the progress and payments.
The District has created a standard operating procedure document to follow for all construction projects. The District will also share that document with all contractors to help communicate the needs of the District regarding construction projects. If necessary, the District will provide the contractor with training to make sure all payrolls are properly certified and in compliance with applicable law. The District will also create a shared Google document for each construction project to manage the progress and payments.
2023-009
FAC accepted this audit on July 12, 2024 — management decision was due January 12, 2025.
The District did not comply with the wage rate compliance related to the teacher housing civil construction project or the locker room remodel for expenditures paid from Impact Aid monies. Criteria: Section 7007 construction funds, as well as any Section 7002 or 7003(b) funds spent for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Compliance Requirement - All 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 the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141-3144, 3146, and 3147). Non-federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (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). Context: During the testing of significant claims for the Impact Aid major program related to construction, we noted claims in which there should be contracts in place and that the wage rate requirements would apply. Effect: Noncompliance with the Wage Rate Requirement for the teacher housing civil construction project, and the locker room remodel project. Cause: The District was not aware of the requirement. Recommendation: The District should implement internal controls to determine the federal compliance requirements of all federal funds received. In addition, procedures should be implemented to ensure any federal funds received in which the Wage Rate Requirement is required the following are implemented: 1. any construction vendor is by contract, and that contract includes the Prevailing Wage clauses for the contractors and subcontractors 2. the weekly certified payrolls are submitted
Show full finding ▾Hide full finding ▴2023-009 Wage Compliance (Repeat Finding 2021/2022-011) CFDA Title: Impact Aid CFDA Number: 84.041 Federal Award Number: 2023 Federal Agency: U.S. Department of Education Pass-through Entity: Direct Condition: The District did not comply with the wage rate compliance related to the teacher housing civil construction project or the locker room remodel for expenditures paid from Impact Aid monies. Criteria: Section 7007 construction funds, as well as any Section 7002 or 7003(b) funds spent for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Compliance Requirement - All 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 the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141-3144, 3146, and 3147). Non-federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (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). Context: During the testing of significant claims for the Impact Aid major program related to construction, we noted claims in which there should be contracts in place and that the wage rate requirements would apply. Effect: Noncompliance with the Wage Rate Requirement for the teacher housing civil construction project, and the locker room remodel project. Cause: The District was not aware of the requirement. Recommendation: The District should implement internal controls to determine the federal compliance requirements of all federal funds received. In addition, procedures should be implemented to ensure any federal funds received in which the Wage Rate Requirement is required the following are implemented: 1. any construction vendor is by contract, and that contract includes the Prevailing Wage clauses for the contractors and subcontractors 2. the weekly certified payrolls are submitted
FINDING 2023-009: Wage Rage Compliance Response: The District will implement internal controls to ensure compliance requirements of all federal funds received. Contractors will be required to certify that they are complying with prevailing wages if the project is paid with federal funds.
2022-011
Montana local governments with a June 30th fiscal year end must submit their audit report to the MT Department of Administration and the Federal Clearing house by March 31st, following the fiscal year end. The District’s audit was not completed until May 2024. Criteria: The audit for the fiscal year ended June 30th, 2023, was due to the State and the Federal government by March 31, 2024 as required by MT Administrative Rules 2.4.411 and the Federal Uniform Guidance/A-133 rules. Context: Per review of the audit compliance requirements for both the State of Montana and the Federal government. Effect: The District is late in completing their fiscal year 2023 audit. Cause: The District was unable to provide needed documentation to complete both the financial statement portion of the audit and the federal compliance testing for the audit. Recommendation: We recommend the District complete their annual audits in compliance with MT Administrative Rules 2.4.411 and federal rules described in the Uniform Guidance/A- 133.
Show full finding ▾Hide full finding ▴2023-010 Late Audit Submission CFDA Title: Impact Aid CFDA Number: 84.041 Federal Award Number: 2023 Federal Agency: U.S. Department of Education Pass-through Entity: Direct Condition: Montana local governments with a June 30th fiscal year end must submit their audit report to the MT Department of Administration and the Federal Clearing house by March 31st, following the fiscal year end. The District’s audit was not completed until May 2024. Criteria: The audit for the fiscal year ended June 30th, 2023, was due to the State and the Federal government by March 31, 2024 as required by MT Administrative Rules 2.4.411 and the Federal Uniform Guidance/A-133 rules. Context: Per review of the audit compliance requirements for both the State of Montana and the Federal government. Effect: The District is late in completing their fiscal year 2023 audit. Cause: The District was unable to provide needed documentation to complete both the financial statement portion of the audit and the federal compliance testing for the audit. Recommendation: We recommend the District complete their annual audits in compliance with MT Administrative Rules 2.4.411 and federal rules described in the Uniform Guidance/A- 133.
FINDING 2023-010: Late Audit Submission Response: The District was in compliance with timely submissions until the auditor notified the District he was not able to complete the audit due to serious health issues. Due to the shortage of OPI approved auditors, the District was not able to acquire an auditing firm. The District will work with an auditing firm to complete future audits within the timelines required.
2022-012
FAC accepted this audit on July 12, 2024 — management decision was due January 12, 2025.
The District did not comply with the wage rate compliance related to the teacher housing civil construction project expenditures paid from Impact Aid monies. Criteria: Section 7007 construction funds, as well as any Section 7002 or 7003(b) funds spent for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Compliance Requirement - All 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 the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141-3144, 3146, and 3147). Non-federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (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). Context: During the testing of significant claims for the Impact Aid major program related to construction, we noted claims in which the wage rate requirements would apply. Effect: Noncompliance with the Wage Rate Requirement. Cause: The District was not aware of the requirement. Recommendation: The District should implement internal controls to determine the federal compliance requirements of all federal funds received. In addition, procedures should be implemented to ensure any federal funds received in which the Wage Rate Requirement is required the following are implemented: 1. any construction vendor is by contract which includes the Prevailing Wage clauses for the contractors and subcontractors 2. the weekly certified payrolls are submitted
Show full finding ▾Hide full finding ▴2021/2 022 Wage Rate Compliace CFDA Title: Impact Aid CFDA Number: 84.041 Federal Award Number: 2022 Federal Agency: U.S. Department of Education Pass-through Entity: Direct Condition: The District did not comply with the wage rate compliance related to the teacher housing civil construction project expenditures paid from Impact Aid monies. Criteria: Section 7007 construction funds, as well as any Section 7002 or 7003(b) funds spent for construction or minor remodeling, are subject to Wage Rate Requirements (20 USC 1232b). Compliance Requirement - All 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 the locality of the project (prevailing wage rates) by the Department of Labor (DOL) (40 USC 3141-3144, 3146, and 3147). Non-federal entities shall include in their construction contracts subject to the Wage Rate Requirements (which still may be referenced as the Davis-Bacon Act) a provision that the contractor or subcontractor comply with those requirements and the DOL regulations (29 CFR part 5, Labor Standards Provisions Applicable to Contacts Governing Federally Financed and Assisted Construction). This includes a requirement for the contractor or subcontractor to submit to the non-Federal entity weekly, for each week in which any contract work is performed, a copy of the payroll and a statement of compliance (certified payrolls) (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). Context: During the testing of significant claims for the Impact Aid major program related to construction, we noted claims in which the wage rate requirements would apply. Effect: Noncompliance with the Wage Rate Requirement. Cause: The District was not aware of the requirement. Recommendation: The District should implement internal controls to determine the federal compliance requirements of all federal funds received. In addition, procedures should be implemented to ensure any federal funds received in which the Wage Rate Requirement is required the following are implemented: 1. any construction vendor is by contract which includes the Prevailing Wage clauses for the contractors and subcontractors 2. the weekly certified payrolls are submitted
FINDING 2021/2022-011: Wage Rate Compliance Response: The District will implement internal controls to ensure compliance requirements of all federal funds received. Contractors will be required to submit certified payroll records to demonstrate they are complying with prevailing wages if the project is paid with federal funds.
Montana local governments with a June 30th fiscal year end must submit their audit report to the MT Department of Administration and the Federal Clearing house by March 31st, following the fiscal year end. The District’s audit was not completed until May 2024. Criteria: The audit for the fiscal year ended June 30, 2021 and June 30th, 2022, was due to the State and the Federal government by March 31, 2022 for fiscal year 2021 and March 31, 2023 for fiscal year 2022 as required by MT Administrative Rules 2.4.411 and the Federal Uniform Guidance/A-133 rules. Context: Per review of the audit compliance requirements for both the State of Montana and the Federal government. Effect: The District is late in completing their fiscal year 2021 and 2022 audit. Cause: The District did not even sign a contract with the audit firm until July 2023 and was unable to provide needed documentation to complete both the financial statement portion of the audit and the federal compliance testing for the audit. Recommendation: We recommend the District complete their annual audits in compliance with MT Administrative Rules 2.4.411 and federal rules described in the Uniform Guidance/A-133.
Show full finding ▾Hide full finding ▴2021/2022-012 Late Audit Submission CFDA Title: Impact Aid CFDA Number: 84.041 Federal Award Number: 2021 and 2022 Federal Agency: U.S. Department of Education Pass-through Entity: Direct Condition: Montana local governments with a June 30th fiscal year end must submit their audit report to the MT Department of Administration and the Federal Clearing house by March 31st, following the fiscal year end. The District’s audit was not completed until May 2024. Criteria: The audit for the fiscal year ended June 30, 2021 and June 30th, 2022, was due to the State and the Federal government by March 31, 2022 for fiscal year 2021 and March 31, 2023 for fiscal year 2022 as required by MT Administrative Rules 2.4.411 and the Federal Uniform Guidance/A-133 rules. Context: Per review of the audit compliance requirements for both the State of Montana and the Federal government. Effect: The District is late in completing their fiscal year 2021 and 2022 audit. Cause: The District did not even sign a contract with the audit firm until July 2023 and was unable to provide needed documentation to complete both the financial statement portion of the audit and the federal compliance testing for the audit. Recommendation: We recommend the District complete their annual audits in compliance with MT Administrative Rules 2.4.411 and federal rules described in the Uniform Guidance/A-133.
FINDING 2021/2022-012: Late Audit Submission Response: The District was in compliance with timely submissions until the auditor notified the District he was not able to complete the audit due to serious health issues. Du to the shortage of OPI approved auditors, the District was not able to acquire and auditing firm.
The District was not able to provide the membership support documentation for the 2021 Elementary Impact Aid Application. Criteria: The special reporting criteria for Impact Aid compliance testing would require the auditor to verify the membership reported on the applications to test compliance. Context: We requested the membership support documentation to support the 2021 and 2022 Impact Aid Applications. Effect: An internal control weakness was noted in that the District was not able to provide the membership support documentation for the 2021 Elementary Impact Aid application which used the survey date of 10/7/19, using the prior year application numbers. This was allowed as a result of the public health emergency related to the coronavirus, the Impact Aid Coronavirus Relief Act. Note: Impact Aid was audited in fiscal year 2020 with no findings. This indicates the membership amounts were supported which would have been used for the 2021 application. When compared to the 2020 application, we noted the 2021 application was understated 1 in total which was 1 child with disabilities. Cause: A change in staffing at the District in which the current staff was not able to locate the information from the 2019 Impact Aid Application. Recommendation: The District should implement internal control procedures to ensure supporting documentation is maintained for the required period.
Show full finding ▾Hide full finding ▴2021/2022-013 Impact Aid Application Support CFDA Title: Impact Aid CFDA Number: 84.041 Federal Award Number: 2021 Federal Agency: Department of Education Pass-through Entity: Direct Condition: The District was not able to provide the membership support documentation for the 2021 Elementary Impact Aid Application. Criteria: The special reporting criteria for Impact Aid compliance testing would require the auditor to verify the membership reported on the applications to test compliance. Context: We requested the membership support documentation to support the 2021 and 2022 Impact Aid Applications. Effect: An internal control weakness was noted in that the District was not able to provide the membership support documentation for the 2021 Elementary Impact Aid application which used the survey date of 10/7/19, using the prior year application numbers. This was allowed as a result of the public health emergency related to the coronavirus, the Impact Aid Coronavirus Relief Act. Note: Impact Aid was audited in fiscal year 2020 with no findings. This indicates the membership amounts were supported which would have been used for the 2021 application. When compared to the 2020 application, we noted the 2021 application was understated 1 in total which was 1 child with disabilities. Cause: A change in staffing at the District in which the current staff was not able to locate the information from the 2019 Impact Aid Application. Recommendation: The District should implement internal control procedures to ensure supporting documentation is maintained for the required period.
FINDING 2021-2022-013: Impact Aid Application Support Response: A change in staffing at the District was the reason for not being able to locate the information from the 2019 Impact Aid Application. The District will implement internal control procedures to ensure supporting documentation is maintained for each application year.
FAC accepted this audit on June 8, 2021 — management decision was due December 8, 2021.
FAC accepted this audit on April 29, 2020 — management decision was due October 29, 2020.
FAC accepted this audit on March 27, 2019 — management decision was due September 27, 2019.
FAC accepted this audit on March 6, 2018 — management decision was due September 6, 2018.
GSA_MIGRATION
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GSA_MIGRATION
2016-001
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GSA_MIGRATION
2016-002
GSA_MIGRATION
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GSA_MIGRATION
FAC accepted this audit on April 24, 2017 — management decision was due October 24, 2017.
GSA_MIGRATION
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2015-001
GSA_MIGRATION
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2015-002
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