Valley View Independent School District

Maintenance of Effort Federal Program: Title I, Part A (ALN 84.010) Federal Agency: U.S. Department of Education Federal Award Year: 2022-2023 Type of Finding: Noncompliance and Significant Deficiency in Internal Control over Compliance Criteria: Under the Uniform Guidance, the combined fiscal effort per student or the aggregate expenditures of the District from State and local funds for free public education for the preceding year must not be less than 90 percent of the combined fiscal effort or aggregate expenditures for the second preceding year, unless specifically waived by the Department of Education. Condition: During our review of the federal program, we determined that the District was not compliant with the Maintenance of Effort requirement for the 2021-2022 school year. Controls cannot detect whether the grant is in compliance with the Maintenance of Effort requirement. Cause: The District’s current controls are not at the precision level to properly detect and prevent noncompliance with the Maintenance of Effort requirement. Effect: Ineffective internal controls may result in the District not being in compliance with the grants Maintenance of Effort requirement. Questioned Costs: $0 Recommendation: We recommend the District adhere to the Uniform Guidance Maintenance of Effort requirements and set up internal controls so that the District can monitor their funding commitments to ensure compliance. Management’s view Management agrees with the finding. See corrective action plan on page 87.

Special Tests – Wage Rate Requirements Federal Program: Education Stabilization Fund (ALN 84.425D & 84.425U) Federal Agency: U.S. Department of Education Federal Award Year: 2022-2023 Type of Finding: Significant Deficiency in Internal Control over Compliance Criteria: Under the Uniform Guidance, nonfederal 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 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) (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: During our review of the federal program, we determined that the District lacks internal controls and therefore, cannot detect whether the District receives the required documentation for Davis-Bacon prevailing wage requirements on a timely manner. Cause: The District does not have sufficient detection and prevention procedures. Effect: Without proper controls, the District cannot prevent or detect instances of Davis- Bacon prevailing wage requirements noncompliance. Lack of internal controls may result in questioned costs and noncompliance with the terms of the grant. Questioned Costs: $0 Recommendation: We recommend the District adhere to the Uniform Guidance and establish internal controls to ensure the District obtains the required documentation for the Davis- Bacon prevailing wage requirements on a timely basis. Management’s views Management agrees with the finding. See corrective action plan on page 88.