GANADO UNIFIED SCHOOL DISTRICT NO. 20

2022-003 Late Audit Submission Programs: Impact Aid, Covid 19 - Elementary & Secondary School Emergency Relief Federal Assistance #: 84.041, 84.425 Federal Agency: U.S. Department of Education Grantor Number: N/A Questioned Costs: N/A Type of Finding: Noncompliance, material weakness Compliance Requirement: L. Reporting CONDITION The District did not submit their audit for the fiscal year ending June 30, 2022, timely. The audit was submitted June 16, 2023, which was 77 days past the March 31, 2023 deadline. CRITERIA 2 CFR ? 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR ? 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in ? 200.512." CAUSE The District did not have proper procedures in place to ensure that the audit was completed and submitted within the designated timeframe. EFFECT Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the District from qualifying as a low-risk auditee. RECOMMENDATION The District should implement procedures to ensure that all audit documentation is available for audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe.

2021-004 Late Audit Submission Programs: Title I, Impact Aid, Elementary & Secondary School Emergency Relief , Enrollment Stabilization Grant CFDA Number: 84.010 84.041, 84.425, 21.019 Federal Agency: U.S. Department of Education, U.S Department of Treasury, U.S Department of Agriculture Grantor Number: N/A Questioned Costs: N/A Type of Finding: Noncompliance, material weakness Compliance Requirement: L. Reporting CONDITION The District did not submit their audit for the fiscal year ending June 30, 2021, timely. The audit was submitted October 21, 2022, which was 21 days past the September 30, 2022, extended deadline. CRITERIA 2 CFR ? 200.512(a) provides, in part: "The audit must be completed and the data collection form ... must be submitted within the earlier of 30 calendar days after receipt of the auditor's report(s), or nine months after the end of the audit period." 2 CFR ? 200.520 provides, in part: "That to qualify as a low-risk auditee and be eligible for reduced audit coverage the following condition must be met: Single audits were performed on an annual basis in accordance with the provisions of this Subpart, including submitting the data collection form and the reporting package to the FAC within the timeframe specified in ? 200.512." CAUSE The District did not have proper procedures in place to ensure that the audit was completed and submitted within the designated timeframe. EFFECT Not making all audit documentation available in a timely manner resulted in the audit and data collection form submissions to be late and, therefore, not available to the public within the required timeframe. This late submission also excludes the District from qualifying as a low-risk auditee. RECOMMENDATION The District should implement procedures to ensure that all audit documentation is available for audit in a timely manner and the audit report is completed and submitted within the appropriate timeframe.

2019-003 Davis-Bacon Act Compliance CFDA Number 84.041 Program Title Impact Aid Federal Agency U.S. Department of Education Compliance Requirement N. Special Tests and Provisions Finding Type Noncompliance, Significant Deficiency Questioned Costs N/A CONDITION The District did not retain documentation sufficient to determine the Davis-Bacon compliance clause was included in advertised specifications. In addition, the District did not receive weekly certified payrolls from one contractor who was working on projects funded with Impact Aid construction awards. CRITERIA Davis-Bacon Act Department of Labor (DOL) 29 CFR part 5, Labor Standards Provisions Applicable to Contracts Governing Federally Financed and Assisted Construction Non-federal entities shall include in their federally funded construction contracts in excess of $2,000, that are subject to the Wage Rate Requirements of the Davis-Bacon Act, a provision that the contractor or subcontractor comply with those requirements and the DOL regulations. 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). This reporting is often done using Optional Form WH-347, which includes the required statement of compliance. CAUSE The District did not have the proper monitoring controls to ensure that federal monies used for construction were in compliance with the Davis-Bacon Act. EFFECT The District was not in compliance with the monitoring requirements of the Davis-Bacon Act. In addition, the contractor could be subject to penalties and fines, and possible debarment from federal contracting if prevailing wages were not paid. RECOMMENDATION We recommend that the District establish proper monitoring procedures to ensure that any federally funded construction projects in excess of $2,000 are in compliance with the Davis Bacon Act.

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