Page Unified School District No. 8

2025-001 Certified Payroll Reporting

Federal Assistance Listing Number: 84.041 Program: Impact Aid Federal Agency: U.S. Department of Education Pass-Through Number: N/A Compliance Requirement: N. Special Tests and Provisions Award Period: July 1, 2024 – June 30, 2025 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Questioned Costs: $-0-

Repeat Finding: Similar to finding 2024-002.

Condition/Context: The District did not retain documentation sufficient to determine the Davis- Bacon compliance clause was included in advertised specifications for construction projects paid with federal Impact Aid monies. In addition, for nine of 10 vendors selected weekly certified payrolls were not collected and maintained for any relevant weeks during the fiscal year.

Criteria: 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 U.S. Department of Labor 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 adequate review procedures in place to ensure bid documents included notification that federal Impact Aid monies were to be used for payment of the construction projects and the contractors needed to be in compliance with the Davis-Bacon Act.

Effect: The District was not in compliance with the notification requirements of the Davis-Bacon Act. As a result, 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 review procedures of bid documents to ensure that any federally funded construction projects in excess of $2,000 the contractors are notified the projects are being funded with federal Education Stabilization Fund and the contractors are required to be in compliance with the Davis Bacon Act. In addition, certified payrolls should be provided when applicable on those contracts.

Views of Responsible Officials: There is no disagreement with this finding. See the corrective action plan.

2024-01 Level of Effort Federal Assistance Listing Number: 84.041 Program Title: Impact Aid Federal Agency: U.S. Department of Education Pass-Through Number: N/A Compliance Requirement: G. Matching, Level of Effort, Earmarking Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Questioned Costs: N/A

Repeat Finding: No.

Condition/Context: The District appears to be supplanting M&O funding with Impact Aid funds.

Criteria: (20 USC 7703(d)); 34 CFR Section 222.54; Title 34 Subtitle B Chapter II Part 222 Subpart 222.54. Section 7003(d) funds may not supplant any state funds (either general or special education state aid) that were or would have been available to the LEA for the free, appropriate public education of federally connected children with disabilities counted under Section 7003(d).

Cause: Management oversight. Current process and controls are not present to monitor supplanting indicators to ensure compliance is being met.

Effect: Noncompliance and internal control weakness that may result in questioned costs.

Recommendation: We recommend the District to review its internal control procedures of federal programs to ensure documentation is maintained to support monitoring supplanting of grant funds.

Views of Responsible Officials: There is no disagreement with this finding. See the corrective action plan.

2024-002 Davis-Bacon Act Compliance Federal Assistance Listing Number: 84.041 Program: Impact Aid Federal Agency: U.S. Department of Education Pass-Through Number: N/A Compliance Requirement: N. Special Tests and Provisions Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Questioned Costs: $-0-

Repeat Finding: This is not a repeat finding.

Condition/Context: The District did not retain documentation sufficient to determine the Davis-Bacon compliance clause was included in advertised specifications for construction projects paid with federal Impact Aid monies. In addition, weekly certified payrolls were not collected and maintained for any relevant weeks during the fiscal year.

Criteria: 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 U.S. Department of Labor 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 adequate review procedures in place to ensure bid documents included notification that federal Impact Aid monies were to be used for payment of the construction projects and the contractors needed to be in compliance with the Davis-Bacon Act.

Effect: The District was not in compliance with the notification requirements of the Davis-Bacon Act. As a result, 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 review procedures of bid documents to ensure that any federally funded construction projects in excess of $2,000 the contractors are notified the projects are being funded with federal Education Stabilization Fund and the contractors are required to be in compliance with the Davis Bacon Act. In addition, certified payrolls should be provided when applicable on those contracts.

Views of Responsible Officials: There is no disagreement with this finding. See the corrective action plan.

2024-003 Reporting Federal Assistance Listing Number: 10.553, 10.555, and 10.559 Program: Child Nutrition Cluster Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Pass-Through Number: ADE ED09-0001 Compliance Requirement: L. Reporting Award Period: July 1, 2023 – June 30, 2024 Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Questioned Costs: $4,397.30 of underreported claims

Repeat Finding: This is not a repeat finding.

Condition/Context: The District did not properly calculate, and report meal claims accurately for three of 4 months selected during the current year. This led to the District under-reporting $4,397.30 in student meal claims.

Criteria: The Uniform Guidance compliance supplement. Local educational agencies (LEAs), institutions, and sponsors determine eligibility by comparing the data reported by the child’s household to published income eligibility guidelines. Child Nutrition Program claim forms should be supported by documentation showing the number of meals for which reimbursement was requested and document that the meals were served prior to the date of the reimbursement request. The claim reports should be filed on a timely basis.

Cause: Management oversight. The District had insufficient controls and oversight over the Child Nutrition Program due to turnover in food service management personnel during the fiscal year.

Effect: Noncompliance and internal control weakness. Without proper controls over applications and the filing of claims, the District could over or under claim their reimbursements from the Child Nutrition Program without detecting the error.

Recommendation: We recommend that the District establish proper review procedures of meal claims received and properly track counts to ensure meals are reported accurately.

Views of Responsible Officials: There is no disagreement with this finding. See the corrective action plan.

Program: Title I Federal Assistance Listing Number: 84.010 Federal Agency: U.S. Department of Education Pass-Through Agency: Arizona Department of Education Grantor Number: 23FT1TTI-311181-01A Questioned Costs: $-0- Type of Finding: Noncompliance (Other Matter), significant deficiency in internal control Compliance Requirement: E. Eligibility Condition/Context: During our testing of school eligibility and funding, we discovered the District did not maintain records that agreed to the low-income student counts as reported to the Arizona Department of Education to properly allocate Title I funding by poverty level. Criteria: The Uniform Guidance compliance supplement. Cause: Management oversight and turnover in the federal grant department. Effect: Noncompliance and internal control weakness. Repeat Finding: This is not a repeat finding. Recommendation: We recommend the District to review its internal control procedures of federal programs to ensure documentation is maintained to support the allocation of Title I funding based on the poverty level of individual school sites. Views of Responsible Officials: The District concurs with this recommendation and will review its procedures over federal program reporting. Contact Person: Lori Wilson, Business Manager